The Football Governance Act 2025 (Commencement No. 1) Regulations 2025

Published: Fri 31st Oct 25

Department: Department for Culture, Media and Sport
Made under: Football Governance Act 2025

The first commencement regulations brought specified sections (65, 66, and 73) of the Football Governance Act 2025 into force on 1st November 2025.

These Regulations, made pursuant to the Football Governance Act 2025, enact the first set of commencement provisions, bringing specific sections of the primary Act into force on 1st November 2025.

Specifically, regulation 2 activates sections 65 (power for the Regulator to require information), 66 (provisions for expert reports on clubs), and 73 (rules on privileged communications), establishing foundational regulatory powers for the Independent Football Regulator.

Arguments For

Ensures the phased introduction of key regulatory powers established by the Football Governance Act 2025, allowing for necessary preparatory work before full implementation.
Activates specific core functions of the Independent Football Regulator, such as the power to require information (section 65) and commission expert reports (section 66), strengthening regulatory oversight early in the process.
Establishes clear legal parameters regarding privileged communications (section 73) concurrent with the commencement of other related powers, ensuring legal clarity during initial regulatory operations.

Arguments Against

Premature commencement of specific powers without the full regulatory framework being in place might lead to operational gaps or confusion among regulated bodies.
Bringing forward provisions related to information gathering and reporting without corresponding detailed guidance or statutory instruments could place immediate, unforeseen burdens on football clubs.
The phased approach delays the implementation of the Act's overall objectives, potentially postponing anticipated improvements in football governance until later commencement orders are made.

The Secretary of State makes these Regulations in exercise of the power conferred by section 100(1) of the Football Governance Act 2025.

The Secretary of State formally created these Regulations using the authority granted by subsection 100(1) of the Football Governance Act 2025.

Citation1.

These Regulations may be cited as the Football Governance Act 2025 (Commencement No. 1) Regulations 2025.

This section establishes the official, short title for these legislative instruments as the Football Governance Act 2025 (Commencement No. 1) Regulations 2025.

Provisions coming into force on 1st November 20252.

The following provisions of the Football Governance Act 2025 come into force on 1st November 2025—

(a)

section 65 (power to require information);

(b)

section 66 (reports on clubs by expert reporters);

(c)

section 73 (privileged communications).

This regulation specifies which parts of the Football Governance Act 2025 will become law on November 1st, 2025.

These parts include granting the regulator the authority to request information, enabling the commissioning of reports from expert assessors about clubs, and defining the rules around legally privileged communications.

Explanatory Note (This note is not part of the Regulations)

These Regulations bring into force specified provisions of the Football Governance Act 2025 (c. 21) (“the Act”) on 1st November 2025. They are the first commencement regulations made under the Act. Certain provisions came into force on Royal Assent by virtue of section 100(2).

Regulation 2 commences specified provisions in Part 7 of the Act: section 65 confers a power on the Independent Football Regulator to require information, section 66 makes provision about reports on clubs by expert reporters and section 73 makes provision about privileged communications.

An impact assessment has not been produced for this instrument as the sole effect of these Regulations is to bring into force provisions of the Act. A full impact assessment was prepared in relation to the Act, copies of which are available alongside the Act on legislation.gov.uk and hard copies are available from the Department for Culture, Media and Sport, 100 Parliament Street, SW1A 2BQ, London, United Kingdom.

The explanatory note confirms that these regulations initiate the enforcement of selected sections of the 2025 Act on November 1st, noting this is the first commencement order made, as some parts became law immediately upon the Act receiving Royal Assent.

It reiterates that Section 65 grants the Independent Football Regulator the power to demand information, Section 66 concerns expert club reports, and Section 73 addresses privileged communications, all found in Part 7 of the Act.

The note also states that a separate impact assessment was unnecessary for this instrument because its only function is to commence parts of the primary Act, pointing readers to the main Act's full assessment.

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