The Football Governance Act, introducing a new regulatory framework and independent football regulator for the top five tiers of men’s football in England, has now passed as legislation. This LawFlash sets out some of the final changes made to the act.
The UK House of Commons concluded its final reading of the Football Governance Bill on 8 July 2025, with various amendments proposed. Those final amendments were approved by the House of Lords on 15 July 2025, and the Football Governance Act (the Act) received Royal Assent on 21 July 2025, coming into force as an Act of Parliament.
The final stages through the UK Parliament saw additional changes to how the new independent football regulator (IFR) will engage with the Football Association (FA), how possible disputes will be resolved, distribution orders dealing with the distribution of revenue earned by leagues, and the introduction of a requirement for the Secretary of State to review the operation and effect of the legislation within five years.
For more insights on the topic, read our previous LawFlash, New Football Governance Act Relaunched in UK Parliament, where we discussed the bill in more detail upon its relaunch in Parliament in October 2024.
The dispute resolution process considered by the Act is designed to tackle any disputes between parties in connection with the distribution of revenue. This revenue could derive from the broadcasting of football matches, as well as other revenue streams. The Act sets out a dispute resolution process to resolve disagreements regarding the distribution of revenue from broadcasting or other sources. A specified competition organiser can apply to the IFR to apply for the resolution process to be triggered, giving the IFR the power to determine whether the resolution process could be triggered in relation to one or more of the questions raised in the application.
IFR Consultation with the FA
The previous draft of the Act allowed for the IFR to make its own decision on whether the dispute resolution procedure should be triggered. However, the latest and final amendments to the Act requires the IFR to consult the FA on the matters to be resolved, before the IFR can determine whether the full dispute resolution process shall be triggered. As discussed as part of the final House of Lords reading, this process will ensure that the national governing body for football continues to have a say in the process and can raise any views about the scope of the backstop process.
Proposal Stage
If the dispute resolution process does go ahead (following any necessary consultation with the FA), the disputing parties are required to appoint a mediator as part of the initial mediation stage. However, if this is not successful, the process moves into a new stage. The Act previously referred to this as the “final” proposal stage, which would require the IFR CEO to establish an executive committee of the expert panel, which would then give notice inviting both disputing parties to submit final proposals together with supporting evidence as to how the dispute should be resolved.
Final amendments have simplified this stage of the process by eliminating the need for an executive committee to be set up, and instead permits the IFR to give notice to the disputing parties directly, setting out the outstanding issues to be resolved and setting out any findings in the IFR’s most recent state of the game report that the IFR considers relevant to the issues. The notice continues to invite both parties to submit their proposals with supporting evidence and will set the initial response deadline.
The original drafting allowed the committee to use its discretion to decide, if they deemed it relevant, that the disputing parties should be asked to explain how their proposals will promote the financial sustainability of clubs which operate teams relegated from a competition organised by the disputing party distributing the relegation revenue. On the basis that a committee is no longer required, this element is less discretionary: the parties must be required to provide such explanations in all cases where the dispute relates to relegation revenue.
Once the initial deadline has been reached (or earlier, if the IFR confirms that both parties have submitted a qualifying proposal), the IFR is now required to send a second notice to the disputing parties. This additional step gives the parties the opportunity to confirm their proposal or to make any permitted modifications, and to confirm a date on which such proposals shall be resubmitted to the IFR and to the other party.
Distribution Orders
Once final proposals are received from the disputing competition organisers, the final amendments now require the IFR to firstly give notice confirming which of the organisers have submitted a qualifying proposal and inviting each to either confirm or make any permitted modifications to their proposal.
The IFR must then notify the organisers of the distribution order it intends to make within 60 days of the first notice being given and prior to the order actually being made (with scope for the deadline to be extended by a further 14 days). The parties are invited to make representations about the proposed distribution order within a timeframe which cannot be less than 14 days.
The distribution order must still be in line with two fundamental principles: (1) that the order does not place an undue commercial burden on the commercial interests of either disputing party and (2) that the order should not result in a lower amount of relegation revenue being distributed to a club than would have been had an order not been made. However, as a new addition from the latest amendments, the IFR is now required to explain clearly how these principles have been applied.
The amendments also now require the UK Secretary of State to perform a review of the operation and effect of the legislation and publish a report to UK Parliament within five years of the legislation coming into force. The report will focus on whether the Act’s core objectives have been achieved, whether the objectives remain appropriate, and the impact of the Act and the IFR’s actions on English football, among other requirements. The Secretary of State must consult the IFR, FA, each specified competition organiser, and any other parties they consider appropriate prior to publishing the report.
Investors in the men’s game in England would be well advised to revisit our previous summary of the key provisions of the Act, as well as consider these final amendments, to ensure they are well-equipped for compliance now the Act has passed as law in the UK. While many of the final amendments clearly seek to solve concerns regarding engagement with the FA and any future disputes between competition organisers particularly with respect to relegation payments, those at the club level will need to be familiar with the IFR’s independence and far-reaching powers covered by the Act as a whole.
Separate reviews and UK government responses have been published in respect of women’s football in England, and there has been some discussion as to a potential broadening of the Act in the future. However, the current consensus remains that bringing women’s football within scope at this stage may hinder its progress and growth due to certain key differences to the state of the men’s game. We continue to monitor these developments.
If you have any questions or would like more information on the issues discussed in this LawFlash, please contact any of the following: