Football clubs that have not yet mapped their exposure to the Independent Football Regulator’s (IFR) new Owners, Directors and Senior Executives (ODSE) test are already behind. The regime came into force on 12 December 2025, making it the first live component of the IFR’s statutory framework.
According to Argus Pro, this is a far cry from the owners and directors tests previously run by the Premier League, EFL and National League. Each league once set its own criteria, mainly applied at the point of a takeover or appointment.
Once someone was approved, ongoing scrutiny was minimal. The collapses at Derby County, Bury, Reading and Macclesfield exposed how poorly that fragmented, self-regulated model coped when an owner’s circumstances shifted.
The ODSE test has been built to close those gaps. It applies to owners holding more than 25% of a club’s shares or voting rights, and to anyone exercising significant influence or control, including indirectly through companies or trusts.
It also covers six Senior Management Functions (SMFs), defined by role rather than job title. A sporting director with executive authority could fall under SMF6, while a head coach sitting on the board would count as SMF5.
The framework deliberately mirrors the Financial Conduct Authority’s (FCA) Senior Managers regime. IFR chief executive Richard Monks helped design the FCA’s equivalent, and the two regulators have signed a memorandum of understanding on information sharing.
Three shifts stand out. First, standards are higher, with individuals assessed on honesty, integrity, financial soundness and competence. Second, assessment is continuous, meaning the IFR can investigate incumbents whenever concerns arise.
Third, enforcement has real teeth: the regulator can issue disqualification orders barring individuals from roles at any regulated club, and in serious cases can direct a club to remove an owner.
Timing also matters. Assessments for prospective owners and senior managers began in May 2026. The IFR has 90 days to decide on an application, extendable by up to 60 days for complex cases. Clubs planning ownership changes or key hires must factor in a potential 150-day wait.
In practice, clubs should identify who sits within scope, update employment contracts and promotion processes, and ensure individuals disclose changes such as criminal proceedings, regulatory action or financial difficulty on an ongoing basis.
Ultimately, the ODSE test is a board-level governance issue, not merely a personal compliance hurdle. Clubs that engage early and openly are likely to earn lighter supervision, while those waiting to see how the IFR behaves face materially greater risk.
Read the full Argus Pro post here.
Copyright © 2026 RegTech Analyst
Copyright © 2026 RegTech Analyst
