The FAB Files# 6: How fan groups should prepare to use the Football Governance Act

The Independent Football Regulator (IFR) is now in place and clubs in the top five divisions must comply with the legislation. But how well do supporters’ organisations understand the Football Governance Act? And what role can Fan Advisory Boards (aka FABs which give this series its name) play in shaping decisions at their clubs?

Martin Cloake (right) has been heavily involved in the FSA’s policy work on this subject and he is kindly allowing us to reproduce this series of articles from his Substack. The latest in the series looks at how fan groups should prepare for the regulator.

In this series of articles we’ve tried to explain the opportunities the Football Governance Act gives fans to have a real influence on how our clubs and our game is run. Understanding what is and isn’t in the Act is important, and we hope we’ve provided some clarity. But understanding the opportunity is only one part of the equation. It is also vital that our own organisations are able to meet the challenge of moving from protest to participation.

Let’s be clear – the Football Governance Act makes the running of football and football clubs a highly regulated process – and one where listening to fans is a mandatory requirement for clubs that want to keep their licence to play. (Sections 17(2) and 20 and Schedule 4, paragraph 4.)

But having legal rights will mean nothing if we as fans are not organised enough to use those rights fully and properly. Put simply, the business side of our clubs is officially our business – and we need to be businesslike in our approach.

The 2026–2027 countdown

The licencing system won’t be fully implemented until the start of the 2027/28 season, but this doesn’t mean we have time to wait before we start preparing.

A pilot licencing process has already been launched with a number of selected clubs, and individual club applications for provisional licences will roll out between November 2026 and February 2027. Clubs are already doing preparatory work and are in active dialogue with the Regulator.

So supporter groups must start preparing immediately. The FSA has continued to speak to many of the people it worked with as the Football Governance Bill turned into an Act, and an interim Fan Advisory Working Group of fans from clubs throughout the pyramid has been established.

Organising for your seat at the table

The IFR must attach a “fan consultation condition” requiring all clubs to carry out regular consultations with persons elected by the fans to represent their views, or who appear to do so. (Schedule 5, paragraphs 1 and 8).

If no suitable group exists, the Regulator has the power to legally require a club to formally constitute a representative group of elected fans. (Schedule 5, paragraph 8).

So if our supporter groups want to be part of this, we can help ourselves greatly by ensuring our democratic and electoral structures are robust and transparent. The IFR will look at the size and composition of a club’s fanbase, alongside the club’s corporate governance, when determining these requirements. If your group wants to be recognised, you have a much better chance of succeeding if you can prove you are democratic and representative.

IFR supervisors will also want to find out if the people each group represents feel the job is being done properly – the days of clubs or supporter groups marking their own homework are over.

Asking the critical questions

It’s easy to be cynical when working in football. But to make the most of the influence we now have we must swap cynicism for a professional, fact-based approach if we are going to influence decision-making.

Here are some examples of this approach.

On the Strategic Business Plan: “How does our feedback on strategic direction match the business plan you submitted to the Regulator under Section 16(5)?”.

On Corporate Governance: Because clubs are legally required to publish their Corporate Governance Statements online under Schedule 5, Paragraph 5(b): “Your statement says you are improving community well-being – what is the concrete evidence of this in our local area?”.

On Heritage: If a club proposes changes to crests or colours: “Where is your documented evidence of majority fan support as required under Part 5, Section 49?”

These are just a few examples, not a definitive list, of questions and how they can most effectively be phrased. The bottom line is to base everything on factual requirement, to make what you are asking clear, and to press for clarity from the club in the way that it answers.

No two clubs are the same, and you will often be well placed to identify the crucial issues at your club that demand regulatory attention.

When to escalate

Ideally, fans and clubs will be able to work collaboratively on the basis of proper debate and consideration. The IFR is strongly signalling that it prefers to operate a system of “soft power” – which means identifying good practice, using peer review, and guiding clubs toward sustainability through licence conditions.

It will only use “nuclear options” such as licence suspension or sanctioning owners in extreme circumstances.

This means it is vital for fan groups to have clear, evidence-backed approaches if it wants to influence clubs, and to increase the likelihood of regulator support.

Fan groups must learn to monitor their club’s compliance with their submitted financial plans and corporate governance statements. If a club fails to consult fans on “relevant matters” (such as ticket pricing, stadium relocation, or strategic goals), they are committing a “relevant infringement” as set out in the FGA at section 67. Supporter groups are advised to document any failures and be ready to report them to the IFR if they want to escalate an issue.

Making regulation a success

The government has provided the legislative framework to protect our clubs’ heritage and future. It is up to us to make sure the regime works. We can only do that by stepping up, professionalising our approach, and mastering the rules. If we want to be equal partners, we need to show that we deserve that status by playing our full part in a new regime that is designed to benefit everybody who is involved in and who cares about the game.

This may appear daunting, at first sight. Not all of us are suited to this kind of work, and still fewer of us would have sought it out. The FSA can and will play a crucial support role here.

It already offers a range of training modules and other materials. There is also a lot of detailed reference material about the Football Governance Act on the FSA website. And there is considerable value in being part of the FSA’s extensive network of club representatives that allow us to talk with and consult our peers at other clubs when we face problems. All this has the potential to be invaluable.

This series is not intended to be a definitive guide to the Football Governance Bill. Robbie and I just wanted to make a start on explaining the opportunities it offers and to give a taste of the work we all need to do if we want to make a success of this.

We hope it will be built upon, and that the principle of sharing knowledge is embedded in the way we all work.

Good luck.

• Part 1: How to use the Football Governance Act at your club
• Part 2: Strategic business plans and your right to influence
• Part 3: Corporate governance – keeping the plan on track
• Part 4: Heritage issues – protecting your club’s identity
• Part 5: IFR has the power to change

This article could not have been written without the assistance of Robbie Whittaker of the Blackpool Supporters Trust, whose knowledge of the legislation has proven invaluable to Martin and the FSA. Martin wants to be transparent that some of the basic research in this piece has been conducted with the assistance of Gemini Notebook, which cites original sourcing, but those sources have been checked by Robbie and Martin. All analysis and conclusions are those of Robbie and Martin too.

Martin Cloake’s The Football Fan is available to read for free via Substack.