The IFR personnel statement: who really decides at your club?

Every club applying for a provisional licence sends the Independent Football Regulator two documents: a strategic business plan and a personnel statement. Applications open on 2 November. The business plan will get most of the attention. The personnel statement deserves as much, and its hardest question has a football answer.

What the statement has to show

The Football Governance Act 2025 sets it out in section 16. The personnel statement has to:

• identify each of the club's owners and officers
• identify the club's ultimate owner
• give the job title, or a description of the role, of each officer
• set out which senior management functions each senior manager performs

It goes in with your application, alongside a statement explaining why the club considers it accurate. Once the regulator approves it, it is published, and it has to be updated after any material change.

So it is a signed, public account of who runs your club. If it's wrong, you've told the regulator, and everyone else, something that isn't true.

The six functions

The regulator's rules set out six senior management functions: chair, chief executive, chief finance, chief operations, director (including shadow directors), and a sixth for other key decision makers.

The first five are mostly obvious. You know who chairs the board and who signs off the accounts. The sixth is where the thinking is needed.

The SMF6 question

SMF6 exists so that someone with real influence can't sit outside the regime just because their job title isn't on the list. It follows what people do, not what their business card says. In its consultation, the regulator described it as having "a significant influence on the management or conduct" of one or more parts of the club.

In most businesses that is a narrow group. In football it often isn't. Ask yourself who really decides:

• which players the club signs, and what it pays them
• whether the manager stays or goes
• how much the owner puts in, and when

If the honest answer is someone who isn't a director or one of the named executives, that person may be performing SMF6. If so, the board will want to look closely at whether they belong in your statement, because anyone performing a function needs the regulator's suitability approval.

Why this is a football question as much as a legal one

The clearest view of who decides on signings often sits in the football operation, alongside the board. Anyone who has worked in the game knows the organisation chart and the corridor don't always match. A sporting director may agree fees within a budget. A head of recruitment may have authority to agree personal terms. An adviser the owner trusts may have a say on the shortlist. Each is worth a careful look before the statement is signed.

It matters beyond the application too. Nobody can take up a senior management function until the regulator has assessed them as suitable. Get the picture right now and your next appointment, a new sporting director in January say, runs to a known process rather than a scramble. Cover for a genuinely unforeseen absence is allowed for up to 12 weeks in any 12-month period, but that is a safety net, not a plan.

Four questions to answer before you sign

1. Could you name today every owner with more than 25% of the shares or votes, or with significant influence or control, including anyone who holds it through a company or trust?
2. For each director and named executive, does the role description match what they actually do?
3. For each signing, contract and managerial decision in the last 12 months, who had the final say, and is each of those people in the statement?
4. Who will keep the statement current after a change, and how will they hear about it?

If any of those made you pause, our seven-question assessment will show you where you stand in about five minutes.

This article explains the regime in general terms. It isn't legal advice, and it isn't a view on whether any individual is a senior manager at your club. Aegis is independent and isn't affiliated with or accredited by the Independent Football Regulator.