On the implementation of the fan-led review of football governance

The Fan-Led Review (“Review”), published in November 2021, provided an examination of the English football system with the aim of analysing ways of enhancing the governance, ownership structure and financial sustainability of football clubs . In particular, the Fan-Led Review foresees the establishment of an independent regulator for English football
(“IREF”).

This Report considers how the measures included in the Fan-Led Review should be
implemented and their legal viability. We consider the Governance & Financial Regulation
aspects in Part I, challenges to the existence of an independent regulator in Part II, and
challenges to individual decisions of an independent regulator in Part III. This report does not
consider the issues of equity, diversity, and inclusion, the owner & director tests, women’s
football issues, or player welfare issues that also formed part of the Fan-Led Review. This
report also does not consider in detail other initiatives aimed at sustainability, for example
UEFA’s new financial sustainability regulations.2 Outside the scope of this report are also the
EU’s soon to be enacted Foreign Subsidies Regulation.