The Independent Football Regulator (IFR) has published guidance on the meaning of “significant influence or control” for the purposes of the Football Governance Act 2025.

The Act not only empowers the IFR to assess the suitability of those who own or seek to acquire regulated football clubs, but also requires clubs to submit a personnel statement identifying all of its owners. However, as the guidance recognises, it is not always a straightforward process to identify who owns a club, at least not according to traditional indicators such as shareholding or voting rights.

To address this, the Act sets out five ‘conditions’ for a person being considered an ‘owner’ of a club. Some of these relate to the ownership of voting rights or shares, while condition (1) covers cases where a person “has the right to exercise, or actually exercises, significant influence or control over the activities of the club (in whole or in part)”.

The guidance seeks to explain what this condition means in practice. It suggests, for example, that someone could exercise significant influence or control if they have the right to absolute decision-making or have veto rights in relation to key decisions over the running of the business of the club (such as amending the club’s financial plans, adopting new sponsors, renaming the home ground, or selling key assets). Importantly, the test would be satisfied even if the person does not actually exercise these rights.

Conversely, the guidance explains that a person will be treated as an owner if they ‘actually exercise’ significant influence or control over a club even if they do not have the formal rights to do so. For example, they might have a financial relationship with the club which means that their recommendations or instructions are invariably followed by other owners or officers, or they might exert influence due to their relationships with key persons at the club.

Finally, the guidance clarifies that a person cannot avoid classification as an owner by exercising their significant influence or control through a trust or other body. It also lists examples of ‘excepted roles’ (such as professional advisors) which would not, on their own, result in the holder being classified as an owner.

To read the guidance in full, click here.