On 17 March 2026, the Independent Football Regulator (IFR) issued its latest consultation on the proposed licensing framework (CP2/26) which takes into account and responds to the IFR’s earlier consultation (CP5/25) that took place between October 2025 to December 2025.

Background

The IFR acknowledges that it is important to provide further detail and guidance on the licensing framework. The first licensing consultation was conducted at a high level to establish foundational principles before developing detailed guidance informed by stakeholder feedback. This second consultation on the specifics of the draft licence, rules and guidance documents provides significant further clarity and detail. The proposed licensing framework establishes the responsibilities that clubs must fulfil to compete in the top five divisions of English men’s football.

Consultation

In CP2/26 the IFR sets out a detailed proposed licensing framework which includes:  

  • IFR Licensing Guidance: for clubs across all parts of the licensing regime. This includes guidance on the licensing processes, financial regulation, non-financial resources, corporate governance, fan engagement, annual declarations, Discretionary Licence Conditions (DLCs) and clubs’ duty not to change their crest, home colours, or name without approval.
  • The IFR Licence and Mandatory Licence Conditions (MLCs): This is the standard licence that will apply to clubs. It sets out the terms of the licence and contains the four MLCs that apply to all clubs (and to both provisional and full licences). This is attached as an annex to the Licensing Guidance.
  • Provisional Licence Application Guidance (including the Provisional Licence Application Form): This provides specific guidance in relation to the provisional licence application and assessment process. Clubs must apply for a provisional licence by submitting an application to the IFR. The indicative Provisional Licence Application Form includes the questions that clubs will need to complete as part of this. Clubs must also complete a strategic business plan forecasting template, which must cover forecasting finances until the end of the following season.
  • The Football Club Corporate Governance Code (The Club Code): This adopts a principles-based approach designed to focus on outcomes. Licensed clubs must produce a statement explaining how they apply The Club Code as part of their MLCs.
  • IFR Licensing Rules: which supplement the Licence and MLCs.
  • Standardised reporting templates: The IFR is consulting on two templates in addition to the strategic business plan forecasting template (both attached as an annex to the Licensing Guidance): (i) the annual declaration template form that licensed clubs will be required to complete and submit; and (ii) the corporate governance statement guidelines that ensure club submissions meets the minimum information requirements.

The IFR will consult on a reporting template for the financial plan ahead of the licence application window opening in November.

Next steps

The deadline for comments on the consultation is 5 May 2026. 

Following this, the IFR will consider the responses and intends to publish the final licensing rules and guidance by 1 July 2026.

The IFR will also publish a response to the second consultation.

The IFR intends to publish a supervisory approach document ahead of the first licensing application window opening (in November 2026). This will explain how IFR supervisors will work with clubs to help them achieve compliance with the licensing framework.

As set out in the Licensing Rules and Licensing Guidance, the IFR intends to license clubs before the 2027/28 season, with the provisional licence approval process conducted during the 2026/27 season. The application window is due to open 1 November 2026 and will run to 26 February 2027.

The IFR will run a pilot scheme for provisional licensing prior to the opening of the application window. All clubs in the top five tiers have been contacted and asked to express their interest by 17 April 2026.