Richard Monks, chief executive of the Independent Football Regulator (IFR), said: “A new era in football governance has arrived.”
It’s been a while.
The Football Governance Act was passed in July, David Cogan was appointed chair of the IFR in October, and offices have been set up in London and Manchester, but the IFR has yet to take action.
This is not a criticism. How the IFR exercises its powers within its statutory powers requires due process, adoption and proper consultation, which takes time.
However, from next week, Friday 12th December to be precise, the IFR will be able to step in and exercise some of its powers against owners as far as football supporters are concerned.
IFR has now published the Owners, Directors and Senior Executives (ODSE) regime. This is the final version of a test that has been in the works for some time and will allow the IFR to take action against what it calls an “improper owner.”
IFR said the new ODSE test will be significantly different from what was previously in place, will hold owners, directors and senior executives to “higher standards than currently exist” and will apply to more positions. We will clarify which senior executives fall under the new structure and provide further details about the treatment of current owners, but we will work with clubs to resolve the issue before launching an investigation or enforcement action.
ODSE has always been one of the key elements of the IFR and the governance of the English game, and those wishing to own and lead a club have had to prove their financial health and ability.
But let’s be clear: IFR is still moving forward in this new world. The powers at their disposal from December 12 only concern existing owners.
“IFR gives fans confidence that their club will be protected.”
How Sheffield Wednesday fans wished this had come sooner. Digiphone Chansiri is now the club’s “former” owner after relinquishing control on Wednesday, putting one of England’s oldest clubs and a founding member of the Premier League into administration, meaning the IFR has no powers to act.
But if there is a reason for the IFR to launch an investigation into current football club owners in England’s top five men’s football from December 12, it can and will do so. Importantly, if it deems it necessary to intervene with sanctions, it can do so. Compliance can be forced through financial penalties, public censure, and, in extreme cases, forcing owners to sell.
When it comes to potential new owners of the club, it’s a slightly different process.
From May 2026 onwards, all new owners, directors and senior executives will be required to be approved by the IFR’s ODSE test.
IFR Chairman Cogan only took office in October, and his appointment was widely expected, but not without some controversy.
Appearing before the Culture, Media and Sport Select Committee in May, when he was the “leading candidate” for the job, he admitted on record that he had previously donated to two prominent Labor MPs, Prime Minister Keir Starmer and Culture Secretary Lisa Nandy. Ms Nandy would have been the person to appoint the chair of the IFR until she withdrew from the process.
An investigation was conducted, and opposition members made accusations of a conflict of interest. Still, not everyone is happy with David Kogan’s appointment process.
However, as the IFR’s powers begin to materialize, Cogan said: “Following Royal Assent in July, the IFR has steadily put its regulatory regime in place through a public consultation process on its new powers. This is the latest step in ensuring the provisions of the law are complied with, so as to enhance stability and sustainability across the football pyramid.”
Commenting on the new ODSE test, IFR CEO Richard Monks added: “A new era in football governance has arrived. This test applies to all clubs in the top five tiers and we have the tools to act quickly to drive sustainable investment in the game.”
“We will be able to gather information, investigate and, in the most serious cases, demand action, including the removal of unsuitable owners.”
Although the IFR is not part of the IFR as it is “independent” from government, Sport Minister Stephanie Peacock said: “Our message has been clear throughout: owners and directors are first and foremost stewards of the club and must act with the best interests of the club in mind.”
“Regulators now have the power to hold accountable those who are not, and our fans can have confidence that the institutions at the heart of their communities and lives will be protected well into the future.”

