On 17 March 2026, the Independent Football Regulator (IFR) issued a consultation (CP1/26) on certain amendments to the Owners, Directors and Senior Executives (ODSE) regime.
Background
The Football Governance Act 2025 (the Act) establishes both the IFR and the ODSE regime. The ODSE regime has applied to incumbent owners, and Senior Managers (termed ‘officers’ in the Act) since December 2025, when the IFR also published guidance on, and statutory rules for, the regime. The ODSE regime will apply to all prospective owners and Senior Managers from May 2026.
Consultation
The consultation now issued covers two areas that the IFR has identified as requiring further consideration and clarification:
- Temporary appointments for unforeseen absences: The IFR proposes a 12-week temporary appointments provision to ensure operational continuity for clubs in the event of unforeseen absences in Senior Management Function (SMF) roles, while ensuring regulatory oversight.
- Technical or clarificatory amendments necessary to reflect developments since the publication of the ODSE guidance and rules in December 2025: In particular, references to the recent statutory instrument on suitability assessment time limits, statutory guidance on the meaning of significant influence and control, and clarity as to the position of incumbents.
The proposals are supported by amended IFR ODSE draft rules; amended IFR ODSE draft guidance which explains how the ODSE regime will operate and what clubs, owners, Senior Managers and others can expect from the IFR; draft temporary appointments forms and draft amended ODSE application forms. The ODSE draft guidance also includes minor additional changes the IFR will make to clarify certain provisions of the guidance published in December 2025.
Next steps
The deadline for comments on the consultation is 10 April 2026.