England’s New Independent Football Regulator: Are You on the Ball?

Executive Summary

What’s new: Following severe financial distress at a number of English football clubs and pressure from fans about club governance and ownership, the UK government established the Independent Football Regulator. The IFR is currently consulting on the draft rules, guidance and documentation for a licensing regime which will apply to all clubs in the top five tiers of English men’s football.
Why it matters: The IFR could revolutionise the regulation of English football. This consultation and a pilot licence scheme where clubs can trial the licence application process present valuable opportunities for clubs to engage with the new regulator and provide feedback on its draft regulations before they are finalised in July. Under the proposals, clubs will need to receive a provisional licence in order to compete in the 2027-28 season.
What to do next: Clubs have until 5 May 2026 to provide feedback on the IFR’s current consultation. Even clubs that don’t choose to respond, should familiarise themselves with the IFR’s proposals and consider the implications for their operations, including whether they have the necessary internal and external resources to achieve compliance.

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Background

Sheffield Wednesday, Bury, Macclesfield Town, Derby County, Wigan Athletic, Bolton Wanderers, Bury… again. These names represent just a handful of English football clubs that have entered one form of insolvency process or another over the past decade. The complete list is much longer and doesn’t include the “near misses.” Following pressure from fans concerned about perceived financial mismanagement and inappropriate football club owners, then-Prime Minister Boris Johnson committed to a “fan-led” review of football governance in 2021.

Fast-forward to 2026: The fan-led review of football governance has been completed and the current Labour-led government has implemented the Football Governance Act 2025 (Act). Most notably, the Act established the Independent Football Regulator (IFR). The remit of the IFR extends to supervision of men’s football clubs competing in the top five divisions of English football: the Premier League; the Championship; League One; League Two; and the National League (together Regulated Clubs).

The introduction of the IFR could cause a landmark shift for English football clubs, as football transitions from self-regulation to independent regulation. Whilst the sport has already made some moves in this direction, as shown through existing financial regulation such as the Premier League’s Profitability and Sustainability Rules, the new legislation and the specific approach the IFR chooses to take once its licensing rules are finalised may cause the football industry to more closely resemble other regulated industries, like financial services, telecoms or utilities.

In particular, the parallels between the IFR and the Financial Conduct Authority (FCA) are notable: They share similar statutory objectives and the IFR will introduce regulated positions for individuals of Regulated Clubs, analogous to the FCA’s “senior management functions.” Moreover, the IFR has recruited heavily from the FCA. Those with experience working within or advising firms authorised by the FCA or the Prudential Regulation Authority (PRA) are likely to find the new IFR regime easier to navigate and advise on as a result.

The IFR has released its draft rules, guidance and documents for its licensing regime, under which all clubs in the top five tiers of English men’s football will require a licence to participate in the game. Clubs will be required to file detailed financial reports and plans, and information about their ownership and management. The IFR is currently consulting on these drafts. Based on the current consultation’s draft documents, the IFR is going to have significant supervisory discretion when reviewing applications, and on an ongoing basis, so appropriately managing engagement is going to be important for all clubs.

Given key upcoming deadlines, football clubs need to engage with the IFR proposals sooner rather than later, if they have not already done so. Specifically, clubs must engage with, and should consider responding to, this latest consultation and those pencilled in for later this year, and they should start giving thought to their licence application.

The key — and most immediate priority — for Regulated Clubs is the need to receive a provisional licence from the IFR in order to compete in the 2027-28 season. In this article, we examine:

The existing regulatory framework for English men’s football.
The new framework introduced under the Act.
The similarities of the proposed regime to certain pre-existing regulatory frameworks in the UK, such as those overseen by the FCA and the PRA.
Commentary on the proposed new licensing regime and what it means for Regulated Clubs.

Existing Regulatory Framework

Men’s football in England is governed by a series of leagues, together with relevant national and international federations and bodies. In the first instance, English football leagues are run independently but operate under the jurisdiction of the Football Association (FA) as the national governing body and ultimate authority for English football. Where clubs compete internationally, they are subject to additional requirements imposed by the Union of European Football Associations (UEFA) and the Fédération Internationale de Football Association (FIFA).

The Leagues

The Premier League, the top division of men’s football in England, is structured as a private limited company owned by the 20 clubs competing in any given season. Under the FA framework, the Premier League controls its broadcasting rights, other commercial rights and is entitled to impose its own rules, which are set out within the “Premier League Rule Book” (as discussed below). Regular shareholder meetings are held during the course of the season with respect to such rules, and each club is afforded one vote per matter. All rule changes and major broadcast and commercial proposals require the approval of at least a two-thirds majority, or 14 clubs.¹

The remainder of the top five tiers of the professional men’s game in England comprises the Championship, League One and League Two, all under the umbrella organisation of the English Football League (EFL), and the National League. The EFL is broadly similar to the Premier League from a legal perspective, in that it is structured as a private limited company whose shareholders are the member clubs.

Regulatory/Sporting Bodies

The FA, as the ultimate governing body of English football, is a member of both UEFA and FIFA. Whilst the FA does not run the day-to-day operations of the Premier League or the EFL, the FA has certain “reserved matters” where its approval is required, such as the appointment of directors to the board of the Premier League.² In addition to the rules set by the Premier League, the EFL and the National League (as applicable), clubs must also comply with the “FA Rules,” including:
UEFA, as the European football governing body, operates under and cooperates with FIFA on regulatory, competition and development matters, convening an ordinary congress of 55 European football national associations on an annual basis to make decisions on football, each having one vote. UEFA approved financial sustainability rules in June 2023, introducing requirements with a view to safeguarding European club football, which focus on solvency, stability and control.
FIFA, as the international self-regulatory governing body of association football globally, is responsible for the regulation, promotion and development of football at international level. FIFA’s rules and regulations are maintained by the International Football Association Board (IFAB). While FIFA sets global football standards, financial regulation for clubs is largely implemented by continental, national and local authorities.

Improved Governance: Initial Steps

The Premier League Rule Book, contained within the Premier League Handbook, acts as a contract between the Premier League and the member clubs. It includes, for example, the expected levels of conduct from clubs and their officials, along with processes for adjudicating and sanctioning misconduct and the minimum standard of governance and operation across many areas.⁶ Where a club or individual subject to the rules fails to comply, the Premier League Board has a range of disciplinary options, including the power to issue fines of up to £100,000, the power to agree sanctions and, where appropriate, to refer the breach to an independent commission.⁷

As an initial step to ensure the fitness and propriety of football club owners, Premier League clubs agreed to an Owners’ Charter in 2022, which states that owners and directors of the football clubs are custodians of their clubs and are responsible for upholding certain commitments, such as listening to fans, protecting club heritage, upholding the football pyramid, promoting the strength and financial sustainability of English football, and running clubs in an economically stable, sustainable and socially responsible manner.

Supplementing the Owners’ Charter, the Premier League’s Owners’ and Directors’ Test was originally introduced in 2004, pursuant to which approval from the Premier League Board is required in order to acquire control of a Premier League football club, or appoint a proposed director.

During the 2015-16 season, the Premier League introduced The Premier League’s Profitability and Sustainability Rules (PSRs), which require clubs to operate within certain financial constraints with a view to enhancing financial stability. From the start of the 2026-27 season, the PSRs will be replaced with new rules on Squad Cost Ratio (SCR) and Sustainability and Systemic Resilience (SSR), more aligned to existing UEFA regulations.⁸

New Legislative Framework

The Act supplements the existing football regulatory framework in particular through the introduction of the IFR, an independent regulator established to mitigate the perceived risks arising from the current framework of self-regulation.

Pursuant to the Act, the IFR has three statutory objectives:⁹

The IFR must protect and promote the financial soundness of individual regulated clubs.
The IFR must protect and promote the overall financial resilience of the English football pyramid.
The IFR must safeguard the heritage of English football.

Perhaps notably, these statutory objectives bear many similarities to — and have clearly drawn inspiration from — the objectives of the FCA and PRA, imposed under the Financial Services and Markets Act 2000 (FSMA). For example, the FCA’s statutory objectives include “securing an appropriate degree of protection for consumers,” “protecting and enhancing the integrity of the UK financial system” and “promoting effective competition in the interests of consumers.”¹⁰ Structurally, this is just one example of where the Act and FSMA resemble one another.

The other requirements of the Act are structured as follows:

Part 3 imposes a requirement for relevant football clubs to obtain an operating licence from the IFR in order to compete. It also provides for the IFR to grant and revoke such licences and it sets out the factors to be taken into account for these purposes (Licensing Regime or LR).¹¹
Part 4 sets out the Owners, Directors and Senior Executives regime (ODSE Regime) and provides for the IFR to make determinations about the suitability of individuals to serve as owners or officers of football clubs.¹²
Part 5 imposes various duties on football clubs, their owners and officers, and the organisers of football competitions,¹³ such as a club’s duty not to dispose of or grant security over its home ground, or to relocate the location of its home ground without IFR approval.
Parts 7 and 8 provide the investigation and enforcement powers of the IFR.¹⁴

Licensing: What Do Regulated Clubs Need to Know?

Following an initial consultation in late 2025,¹⁵ the IFR has published draft rules setting out a detailed licensing framework proposal which will require all Regulated Clubs to obtain an operating licence from the IFR. Such an operating licence is required for continued participation in the Premier League and the EFL (as applicable) from the 2027-28 season onwards.¹⁶

The specific proposed details of the licensing framework are the subject of a second, ongoing IFR consultation (Consultation), in which views on draft rules, guidance and documents are being sought. Further details of these draft regulations are set out below. The Consultation is open to responses until 5 May 2026. The IFR intends to reflect on the feedback received to the Consultation and publish its final licensing rules and guidance by 1 July 2026.

We provide detail on the proposals within the Consultation below.

Timing

It is proposed that Regulated Clubs must apply for provisional licences ahead of the start of the 2027-28 season. The application window for clubs in the top five divisions opens on 1 November 2026 and closes on 26 February 2027.¹⁷

It will be crucial for Regulated Clubs to seek appropriate advice well in advance of this deadline, so that they are well prepared for the process at an early stage. Although the refusal of a licence application will be treated as a response of last resort,¹⁸ Regulated Clubs should be aware that the IFR will carry out risk assessments to identify any clubs with higher levels of risk, potentially requesting additional information and applying amended Mandatory Licence Conditions (MLCs) or Discretionary Licence Conditions (DLCs) to a club’s eventual licence. Proper thought, care and resourcing when planning for and drafting the licensing application will therefore be essential.

Form and Method of Application

In accordance with the IFR’s proposals, applications for provisional licences would be completed through an online application form, which will include: (i) a strategic business plan and (ii) a personnel statement, each based on a prescribed IFR template (the form of which are included in the scope of the Consultation).

The strategic business plan must include a narrative on strategy, funding, fan engagement and corporate governance, plus financial forecasts to the end of the following season. Clubs should only include line items relevant to their financial circumstances and should prepare their financial forecast based on a 30 June financial year end, irrespective of the date of their statutory accounts and using adjustments as necessary.¹⁹ Notwithstanding the different context, we think it is likely that the IFR will expect a document that is similar to a “regulatory business plan” submitted to the PRA and FCA in the context of authorisation and change in control applications in respect of UK financial services firms.
In contrast, the personnel statement gives an overview of a club’s governance and management structure, which must identify each of the club’s owners and officers, including its ultimate beneficial owner, together with the job title or role of each officer, in addition to the functions performed by each senior manager. The personnel statement must be published online as soon as reasonably practicable after it is approved by the IFR. If there are any material changes, clubs must submit an updated statement to the IFR and again publish this online following IFR approval.²⁰ As with the strategic business plan, the personnel statement appears to have been inspired by a requirement to which certain UK financial services firms are subject: namely, the preparation of ‘Management Responsibility Maps’ under the PRA’s and FCA’s Senior Managers & Certification Regime (SMCR).

The IFR proposes to assess and return decisions on “complete” provisional licence applications within three months, if possible, so there is clarity before each league’s AGM.²¹ Applications will be deemed “complete” where the club provides the IFR with sufficient information to make an assessment.²² Where an application is incomplete, the club will be asked to resubmit the application or provide additional information, and the IFR can request additional supporting information at any stage. Clubs can work with their assigned supervisor, which the IFR will assign in May 2026,²³ together with external advisors throughout the process.

All provisional licences will come into effect on the same date, regardless of when a club’s application itself is submitted.

Provisional Licences

In order to grant a provisional licence, the IFR must be satisfied that the Regulated Club in question would operate a relevant team and will comply with the MLCs and the freestanding duties set out in the Act.²⁴ Examples of these freestanding duties include the duty on regulated clubs not to relocate where a club plays its home matches without approval,²⁵ or the duty on Regulated Clubs, and clubs which in the immediately preceding prior five-year period qualified as a Regulated Club, not to dispose of, or grant security over, the club’s home ground without approval.²⁶

The IFR intends that a provisional licence will be valid for up to three years in the ordinary course, and in any event no shorter than one year given the IFR will only grant a full licence after at least one round of reporting under the four MLCs (see below).²⁷ Therefore, the earliest that a full licence could be granted for clubs licensed ahead of the 2027-28 season is June 2028, following the submission of the annual declaration by 1 June.

Path to a Full Licence

The IFR will grant a full licence only once it is satisfied that the Regulated Club in question meets the full licence test,²⁸ namely that the IFR has not made a determination that any of the Regulated Club’s owners or officers are unsuitable, and that the IFR is satisfied that the Regulated Club in question (among other things):

Meets all three “Threshold Requirements” (see Threshold Requirements below).
Complies with, and would continue to comply with, the MLCs (see Ongoing Licensing Requirements – MLCs below) and the freestanding duties (see Provisional Licences above).

The IFR will maintain an online register of licensing decisions, including any amendments or conditions imposed in relation to a club’s licence.²⁹

Threshold Requirements

In order to progress from a provisional licence and move to obtain, and retain, a full licence, Regulated Clubs must meet the three Threshold Requirements:

Appropriate financial resources requirement. Regulated Clubs must have appropriate financial resources relative to their specific circumstances. The IFR will not set fixed financial limits and expect clubs to follow a risk-based approach. Appropriate financial resources can be shown by submitting financial plans and other financial data required by the IFR, and by acting in accordance with those plans.³⁰
Appropriate non-financial resources requirement. Regulated Clubs must have appropriate non-financial resources relative to their individual circumstances. This is attested to in the annual declaration, and Regulated Clubs can further demonstrate compliance through the financial plan and corporate governance statement.³¹
Appropriate fan engagement requirement. Regulated Clubs must have an adequate and effective way of consulting fans on relevant matters, and must take fans’ views into account when making decisions on such relevant matters. This is reported to the IFR annually in the Annual Fan Consultation Report. The IFR may request additional information and/or evidence from Regulated Clubs to substantiate that this threshold is being met.³²

Once again, it is notable that the above appear to have taken inspiration from the Financial Services and Markets Act 2000, which imposes threshold requirements that financial services firms must satisfy in order to receive (and maintain) authorisation from the PRA or FCA.

Ongoing Licensing Requirements: MLCs

Regulated Clubs must continue to comply with these duties once granted a provisional licence, and must comply with the four MLCs:³³ Financial Plan Condition

Regulated Clubs must submit a financial plan (FP) using the IFR forecasting template (to be consulted on in Autumn 2026) within the first year of holding a provisional licence, with most Regulated Clubs submitting by 31 May 2028.³⁴
The IFR can request the FP at any time during the provisional licence period and can determine how frequently updates are required. However, the expectation is that most Regulated Clubs will only be required to resubmit a FP on an annual basis.³⁵
The FP must be formally approved by board resolution.³⁶
Regulated Clubs must act in accordance with their FP and notify the IFR of any material changes. The FP must demonstrate how the Regulated Club intends to hold and maintain appropriate financial resources, which refers to the total amount and quality of funding from equity and debt, assets, income streams and financial capacity that a Regulated Club can reliably access.³⁷
Regulated Clubs must consider and assess relevant risk factors, which include business model risk, liquidity and cash flow risk, solvency and debt risk, and governance risk, in addition to all others identified by the relevant Regulated Club as relevant to their specific business model.³⁸
The FP should be forward-looking, and where Regulated Clubs submit their financial plan on 31 May, it must cover the remainder of the current year of submission in addition to the following two years. It should include expected financial position, financial performance and cash flow, and should demonstrate how the club in question is:³⁹
- Financially sound under normal operating conditions, including any proactive management steps taken to maintain or achieve appropriate financial resources once risks have been identified.
- Resilient in adverse scenarios, as analysed through stress tests of three core scenarios:
  - A 10% reduction in the club’s annual income.
  - Relegation.
  - The removal of a club’s main sources of external funding (where external funding is relied upon to cover deficits).
  - Any bespoke scenarios the Regulated Club sees fit to stress test.
Regulated Clubs must provide mitigation plans for the risks identified through stress testing, ensuring any FP is realistic, appropriate and sufficiently detailed for IFR scrutiny.⁴⁰

Corporate Governance Condition

Regulated Clubs are required to submit to the IFR and publish a corporate governance statement (CG Statement) by 31 October 2027 (or the year of promotion, where applicable) and every two years thereafter, or after any material change.⁴¹
This relates to the IFR’s proposal to introduce the Football Club Corporate Governance Code, on which football clubs must report on an “apply and explain” basis, which mirrors the application of the UK Corporate Governance Code to certain UK publicly listed companies. The five principles in the Football Club Corporate Governance Code can be summarised as follows:
The CG Statement must be formally approved and signed by a club director or individual with appropriate authority to confirm the statement is, to the best of their knowledge, accurate and complete at the time of submission, and should be published online as soon as reasonably practicable following submission to the IFR.⁴⁷

Fan Consultation Condition

Regulated Clubs will be required to establish an elected or appointed group to act as the representative of fans and conduct regular, meaningful consultations with such representative on relevant matters, including the Regulated Club’s strategic direction and objectives, business priorities, operational and matchday issues, club heritage and plans relating to additional fan engagement.⁴⁸
Not later than 15 August each year, clubs must submit an Annual Fan Consultation Report to the IFR which must be formally approved and signed by a club director or individual with appropriate authority to confirm that the report is, to the best of their knowledge, accurate and complete at the time of submission, and this should be published online as soon as reasonably practicable once submitted to the IFR.⁴⁹

Annual Declaration Condition

Not later than 1 June each year, it is proposed that Regulated Clubs must submit an annual declaration pursuant to which they must attest as to whether they have assessed their non-financial resources and if they have a reasonable expectation that the Regulated Club has, and will continue to have, sufficient non-financial resources to operate for 12 months from the date of the annual declaration.50
The IFR has defined non-financial resources to include human capital, physical assets such as a safe football ground, technological resources, intellectual capital, and management and governance structures. When assessing non-financial resources, Regulated Clubs should maintain adequate records and evidence of the assessment and should consider:⁵¹
In addition, the annual declaration must either include a description of any matter notified (or which should have been notified) to the IFR over the previous 12 months, or a statement confirming that there were no such matters to notify. Matters requiring IFR notification include the likely appointment of any new owners or officers, or a material change in circumstances affecting the club in question that is relevant to the IFR’s functions.⁵²
Any notifications to the IFR must be made as soon as reasonably possible once a club becomes aware of the notifiable event, in accordance with relevant duties under the Act, and should not be deferred until the annual declaration.⁵³

Additional Licensing Powers

In addition to the MLCs and Threshold Requirements, which apply to all Regulated Clubs, the IFR has the discretion to amend a Regulated Club’s licence to reflect specific circumstances or risks to that Regulated Club by applying “amended” MLCs or DLCs.⁵⁴

Amended MLCs. The IFR may amend aspects of the usual MLCs for a particular Regulated Club or set of Regulated Clubs based on specific circumstances, for example, by requiring more frequent reporting of a club’s financial plan or corporate governance statement.⁵⁵ This may occur on any date following receipt of the provisional licence application.⁵⁶ The IFR will engage with the relevant competition organiser where appropriate, however it will not formally invite the competition organisers to provide commitments in lieu of MLCs, as is the case with financial resources DLCs explored below.⁵⁷
DLCs. The IFR can apply DLCs where compliance with the DLC would help the specific Regulated Club to meet or continue to meet one of the Threshold Requirements or advance the IFR’s statutory objective to promote systemic financial resilience.⁵⁸ There are four types of proposed DLCs, with each corresponding to a specific Threshold Requirement or the IFR’s statutory objective:
- Financial resources DLCs.
- Non-financial resources DLCs.
- Fan engagement DLCs.
- Systemic resilience DLCs.

Both amended MLCs and DLCs may be applied to both provisional and full licences.⁵⁹ Before imposing or varying a financial resources or systemic resilience DLC, the IFR will engage with the relevant competition organiser to offer the opportunity for them to make a commitment instead of imposing a DLC, provided that this will not jeopardise one or more of the IFR’s objectives.⁶⁰

If accepted by the IFR, the competition organiser must comply with the commitment itself. The commitment will be subject to ongoing monitoring, and the IFR will release the competition organiser from their commitment if it is no longer needed, no longer working, or if the organiser fails to comply.⁶¹ Where possible, the IFR will seek to engage with competition organisers before and after the process to ensure the correct outcomes are achieved.⁶² In cases where (i) an offer of commitment is rejected or (ii) a competition organiser is released due to the commitment no longer working or the organiser’s failure to comply, the IFR can impose the original DLC on the club itself, and in the case of the latter, it can impose an alternative condition on the club.⁶³

The IFR has been afforded a high degree of discretion regarding the imposition and scope of MLCs and DLCs. Given imposing those requirements could have a material impact on the day-to-day operations of a Regulated Club, and/or its ability to compete financially, care will need to be taken by clubs to mitigate the risk that the IFR imposes any MLC or DLC. While any situation needs to be assessed on its merits, open and transparent regulatory engagement is typically advisable in the event that concerning facts are identified by a regulated entity, irrespective of the specific regulated sector in question. As football clubs become more similar to other regulated entities, including financial services firms, they are likely to benefit from the learnings in other traditionally regulated sectors.

Next Steps: Timeline

From July 2026 to October 2026, the IFR will run a pilot scheme, allowing a representative section of Regulated Clubs to better understand the application process; the results of this will be published in October 2026. Clubs may express their interest in the scheme to the IFR directly.

With respect to the Consultation, Regulated Clubs have until 5 May 2026 to submit responses to the IFR on the draft licensing rules and guidance set out in the Consultation. Regulated Clubs may make submissions via the IFR’s website. After the conclusion of the Consultation, the IFR will publish its final licensing rules and guidance by 1 July 2026.

Following this, the IFR will meet with Regulated Clubs to explain the licensing process and finalised requirements. Regulated Clubs in the top five tiers can then familiarise themselves with these ahead of the provisional licence application window opening on 1 November 2026.

Arguably most importantly, however, Regulated Clubs should consider the implications of the IFR’s establishment and proposed rules more holistically. While there will necessarily be a period of adjustment for Regulated Clubs, those that consider the necessary enhancements to their organisational and compliance structures sooner rather than later are likely to find the transition more manageable. In particular, there are lessons that Regulated Clubs can learn from entities in other regulated sectors and their advisers, especially those in financial services in light of the clear similarities between the IFR, the PRA and the FCA.

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¹ Premier League: Governance.

² Ibid.

³The FA Handbook 2025/2026, Section 8 – Rules of the Association, pages 141 to 143.

⁴ Ibid., page 144.

⁵ Ibid., pages 155 to 157.

⁶ Premier League: Governance.

⁷ Ibid.

⁸ Ibid..

⁹ Football Governance Act 2025 (Act), Section 6.

¹⁰ Financial Services and Markets Act 2000, Chapter 1.

¹¹ Act, Part 3.

¹² Ibid., Part 4.

¹³ Ibid., Part 5.

¹⁴ Ibid., Part 7 and Part 8.

¹⁵ IFR, First Licensing Regime Consultation.

¹⁶ Ibid.

¹⁷ IFR, Second Licensing Regime Consultation (Second LR Consultation).

¹⁸ Ibid., Draft Provisional Licence Application Guidance, page 4.

¹⁹ Ibid., pages 7 to 8.

²⁰ Ibid., page 9.

²¹ Ibid., page 3.

²² Ibid., page 2.

²³ IFR’s Second LR Consultation, Licensing Consultation Response, page 6.

²⁴ IFR’s Second LR Consultation, Draft Provisional Licence Application Guidance, page 10.

²⁵ Act, Section 48.

²⁶ Act, Section 46.

²⁷ IFR’s Second LR Consultation, Draft Provisional Licence Application Guidance, page 4.

²⁸ Act, Section 18.

²⁹ IFR’s Second LR Consultation, Draft Licensing Guidance, page 11.

³⁰ Ibid., page 7.

³¹ Ibid., page 8.

³² Ibid., page 8.

³³ Ibid., page 6.

³⁴ Ibid., page 28.

³⁵ Ibid..

³⁶ Ibid..

³⁷ Ibid., page 14.

³⁸ Ibid., page 15.

³⁹ Ibid., pages 23 to 27.

⁴⁰ Ibid., page 27.

⁴¹ Ibid., pages 38 to 39.

⁴² IFR’s Second LR Consultation, Draft Club Corporate Governance Code, pages 4 to 5.

⁴³ Ibid., pages 6 to 7.

⁴⁴ Ibid., pages 8 to 12.

⁴⁵ Ibid., pages 13 to 15.

⁴⁶ Ibid., pages 16 to 17.

⁴⁷ Ibid., page 38.

⁴⁸ IFR’s Second LR Consultation, Draft Licensing Guidance, pages 41 to 42.

⁴⁹ Ibid., page 50.

⁵⁰ Ibid., pages 35 to 36.

⁵¹ Ibid., pages 34 to 35.

⁵² Ibid., pages 52 to 53.

⁵³ Ibid., page 53.

⁵⁴ Ibid., page 8.

⁵⁵ Ibid., pages 8 to 9.

⁵⁶ Ibid., page 9.

⁵⁷ Ibid., page 9.

⁵⁸ Ibid., page 9.

⁵⁹ Ibid., page 9.

⁶⁰ Ibid., page 56.

⁶¹ Ibid., page 56.

⁶² Ibid., page 57.

⁶³ Ibid., page 56.

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