State of the Game

Context
Section 10 of the Football Governance Act 2025 requires the Independent Football Regulator (IFR) to prepare and publish a ‘State of the Game’ report (‘the report’) on the state of English football where relevant to how the IFR carries out its functions.
The IFR must publish the report by May 2027. Before publishing, the IFR must:
- publish a notice stating its intention to prepare a report and invite suggestions on matters to be included
- prepare and consult on a draft final report
The report will help the IFR develop a clear understanding of the football industry. This includes the economics of the market, the underlying incentives and the economic drivers of behaviour. Although the IFR’s scope will focus on the top five English men’s leagues, these clubs and leagues are affected by the wider football ecosystem and other economic and societal factors. The report will also cover these.
This understanding will allow the IFR to make an objective and evidence-based assessment of any underlying risks or issues (where relevant to the IFR’s objectives and functions). This will then inform the IFR’s overall regulatory approach to club financial soundness, systemic financial resilience and heritage (as set out in the Football Governance Act).
Progress and next steps
Since summer 2025, the IFR has started work on the report by engaging with competition organisers, football clubs, academics and industry experts to build an initial understanding of the industry and the key trends and challenges.
We have also formally requested detailed club financial and ownership data from competition organisers (both current and historical) and launched a series of surveys on current approaches to fan engagement and corporate governance.
In January 2026, we published a proposed scope of the report and invited suggestions on matters to be included. We have now reviewed these suggestions and published a final ‘terms of reference’, alongside a summary of the suggestions received.
We are now progressing our analysis to inform the draft report, which we aim to publish and consult on later this year. Ahead of that, if you wish to provide additional evidence or views on any of the areas or issues identified in the final terms of reference, please contact us by 1 June via our 'Contact Us' form.