Football Governance Act 2025 (Specified Competitions) Regulations 2025

Baroness Twycross Excerpts

Wednesday 19th November 2025 Grand Committee

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[Baroness Twycross]

That the Grand Committee do consider the Football Governance Act 2025 (Specified Competitions) Regulations 2025.

Relevant document: 39th Report from the Secondary Legislation Scrutiny Committee

[The Parliamentary Under-Secretary of State, Department for Culture, Media and Sport (Baroness Twycross) (Lab)]

My Lords, I am delighted to be speaking to these regulations, which were laid before the House in draft on 13 October 2025. I would like to thank the Secondary Legislation Scrutiny Committee for the scrutiny provided on this draft statutory instrument.

This Government have now fulfilled our promise by establishing the Independent Football Regulator, following the Football Governance Act 2025 achieving Royal Assent in July. The Act was born out of necessity; just look at what has happened at Sheffield Wednesday over recent months and years. Despite the global success of English football, we have seen too many clubs overshadowed by irresponsible owners, unsuitable financial models and inadequate regulations. Too often, fans have had to fight to protect their club’s very identity and existence.

Following the Act, the Independent Football Regulator was established with three key objectives: clubs’ financial soundness, systemic financial resilience and safeguarding club heritage. The regulator is the first of its kind and is designed to protect our cherished clubs, empower fans and keep clubs at the heart of their communities. By delivering the necessary stability and long-term viability required to stimulate future investment and growth, the regulator will safeguard the football pyramid.

The Act itself did not define which clubs and competitions would fall under the regulator’s scope—an issue much discussed in this place during the passage of the Bill. This approach mirrors other sporting legislation and ensures that the regime can adapt swiftly to any changes in the football pyramid. As noble Lords are aware, amending delegated powers is quicker and easier than amending primary legislation. Following extensive discussion during the Bill’s passage, the scope set out in this statutory instrument remains consistent with the recommendations in the fan-led review and the scope proposed by the previous Government.

This statutory instrument sets out the scope of the regulator as follows: the Premier League competition, organised and administered by the Football Association Premier League; the Championship, League One and League Two competitions, organised and administered by the English Football League; and the Premier Division of the National League competition, organised and administered by the National League. The critical issues in English football that warrant the regulator’s existence, identified in the excellent fan-led review led by Dame Tracey Crouch, are most starkly and prominently evident in the top five professional tiers of men’s English football. Extending the scope beyond the top five tiers would be disproportionate, in our view, as the burden on smaller clubs would outweigh the benefits of regulation.

The independent review of domestic women’s football, led by Karen Carney and published in July 2023, recommended that the women’s game should be given the opportunity to self-regulate. We support this position.

We acknowledge that football is constantly evolving and circumstances may change, which is why the review of the Act is scheduled to take place within five years of the licensing regime’s commencement and will again review the scope. Furthermore, the Secretary of State is empowered to carry out an assessment of the regulator’s scope at any time, consulting the regulator, the FA and other stakeholders as deemed appropriate. This statutory instrument represents another pivotal milestone in the establishment of the Independent Football Regulator for the good of our national game.

[Baroness Evans of Bowes Park (Con)]

I know we are talking about English football in this debate, but I want to put on record my congratulations to the Scottish team for their epic victory last night and their qualification for the World Cup. Well done to them.

I have a brief question for the Minister about what a future process for expanding the remit of the regulator might be. During the passage of the Bill, she set out the Government’s reasons—she reiterated them just now—for not including the women’s game in the scope of the regulatory regime at this stage. Hence, it is not covered in the SI we are discussing. She mentioned the five-year review but say that in 18 months’ time, those involved in running women’s football and the clubs approach the regulator and say they would like the women’s game to be included within the regulator’s remit? If the regulator agrees with that request, what will the process be to take that forward?

Will the Government simply agree and table a revised SI to be debated again, to include the women’s game within the scope of the regime, or will Ministers and DCMS officials be more actively engaged in the process if they believe the status quo that they have argued for until now remains a sensible position? Or will they say they have to wait for five years? It would be useful to know whether the Government have given any thought to what process might be able to take place if something happens before the review.

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[Lord Parkinson of Whitley Bay (Con)]

My Lords, I first share in the felicitations that my noble friend Lady Evans of Bowes Park and the noble Lord, Lord Addington, sent to the Scottish team on their result last night. I send my best wishes to all the home nations for good results in the next World Cup.

The regulations before the Grand Committee define the statutory scope of the Independent Football Regulator created under the Football Governance Act 2025. The Government have chosen to include the top five professional leagues in English men’s football—116 clubs—on the basis that financial and governance risks are greatest at this level. As the noble Lord, Lord Addington, said, there is no surprise here; this was the policy direction that was set out in the Explanatory Notes that accompanied the Bill that became that Act.

However, he was not quite right when he said that this is more or less what the Act says because, as the Minister alluded to in her remarks, the reason we are here making this law in a rather sparsely attended Grand Committee, rather than through primary legislation on the Floor of the House, is that making that clear in the Bill would have made it a hybrid Bill. As she said, that was much discussed during our debates on the Bill, so here we are.

Nobody disputes the need for clearer oversight of the beautiful game, but the question before the Committee today is whether the Government have brought forward a regime that is proportionate, workable and credible. On each of these tests, some doubts remain, and those doubts were only heightened by the unanswered questions in the exchanges we had yesterday on the leadership of the new regulator.

The Government say that the clubs at the five levels set out in the instrument before us can absorb the new compliance obligations, but the reality, as we heard across your Lordships’ House in our debates on the Bill and from the sector itself, is rather different. Premier League clubs have the structures to cope; many League Two and National League clubs do not. Some operate with only one or two staff; many others rely on volunteers. For them, these regulations are not a technical adjustment but a material burden. In her introductory remarks, the Minister spoke of the regulatory burden that the Government have decided would be too great for clubs in lower leagues, but I hope she will acknowledge that there will be burdens on many of the 116 clubs that we are proposing to designate today.

The Government have produced no clear assessment of this disparity. We think that is an omission. If regulation becomes too onerous, investment will dry up and the base of the pyramid—the foundations of our national game—will be weakened. The very system that this Act is seeking to protect could be undermined by the way that the new law is implemented.

The timing compounds the problem. These regulations come into force in less than a month, half way through the season, giving clubs minimal time to adjust. That is not proportionate regulation; it is regulatory pressure imposed without due preparation.

These concerns become even sharper in light of yesterday’s unanswered questions on the credibility and independence of the regulator’s leadership. These matters are directly relevant to this statutory instrument because the effectiveness of the regulatory regime is inseparable from trust in those enforcing it. As I set out in the House yesterday, this matters not because of what it means for trust in the present Government but because UEFA and others have been very clear that English teams’ continued participation in international tournaments depends on the demonstrable independence of the new football regulator.

In our exchanges yesterday, the Minister said that I asked a number of questions. In fact, I asked just two and she gave full answers to neither. Before we decide whether to allow this statutory instrument to pass, I hope that she will give some clearer answers to them.

When the Urgent Question that we repeated yesterday was taken in another place last week, the Secretary of State said that the appointment of David Kogan as the chairman of the new regulator was

“not a prime ministerial appointment”.—[Official Report, Commons, 12/11/25; col. 170.]

If that is the case, why did the official read-out that the Secretary of State gave to the submission that she was sent by her department on 19 March, quoted at paragraph 27 of the report by the independent Commissioner for Public Appointments, say that her “preferred candidate” was Mr Kogan? I quote from the Secretary of State’s own words given in that report,

“subject to No. 10 giving the green light”.

Why did she send the Prime Minister a note asking for that green light? That is my first question.

Last week, the Prime Minister was forced to write to the Independent Adviser on Ministerial Standards, Sir Laurie Magnus, because of the partial information given in another place during the debate on the Urgent Question. That letter said that in the light of the hospitality that the Prime Minister had received from football clubs and the Football Association, he had agreed with Sir Laurie last autumn that:

“I would recuse myself from decisions relating to the Football Governance Bill”.


Despite that recusal, the Prime Minister was not only sent a note asking for the green light on Mr Kogan’s appointment but responded in writing to confirm that he was supportive of it. The Prime Minister now says:

“This was an unfortunate error for which I express my sincere regret”.


This note was sent in April before it became public knowledge that, like the Secretary of State, the Prime Minister had received political donations from Mr Kogan for his Labour leadership campaign.

In the light of that revelation, the Prime Minister and Sir Laurie Magnus had another meeting in June this year and, as his letter of last week puts it, agreed that he should stay out of the appointment process for the new football regulator. My second question is: given these recusals, originally made in autumn last year and strengthened and repeated in June this year, how can the Prime Minister play a part in exonerating the Secretary of State for her breaches of the appointments code? How can he determine whether she has breached the Ministerial Code in this matter?

These are not peripheral matters. They go to the heart of whether Parliament and international sporting bodies can have confidence in the regime and the regulator, whose scope we are asked to approve today. Independence, transparency and good governance are not optional extras in regulation; they are prerequisites. I hope that we will get clearer answers to those questions today. Until the Government provide full and credible answers to them, this Committee cannot be confident that the framework underpinning this instrument is as robust, independent or transparent as it must be.

I look forward to the Minister’s answers on that, as well as to the question asked by my noble friend Lady Evans about the possible future inclusion of the women’s game.

[Baroness Twycross (Lab)]

My Lords, this has been an important and useful debate; I am grateful to all noble Lords who contributed to it. In line with the noble Baroness, Lady Evans of Bowes Park, and other noble Lords, I congratulate Scotland on its impressive win last night. However, while we are congratulating home countries, I should like to note that Wales also won last night; I am sure that all noble Lords will join me in wishing that team well in its future efforts to qualify.

In relation to the SI before us, the implementation of this regime, which prioritises the protection of clubs from financial distress and protects the interests of fans nationally, remains a priority for the Government. That is why we are working at pace to deliver the next phase of the independent football regulator’s framework, for which the delineation of scope is a necessary step. Despite the concerns of the noble Lord, Lord Parkinson of Whitley Bay, we believe that the new regulator is proportionate and will not place unnecessary burdens on smaller, less affluent clubs. I am also clear that the scope of the regime has been appropriately defined.

A number of other points were made by the noble Baroness, Lady Evans of Bowes Park, the noble Lord, Lord Addington, and my noble friend Lord Faulkner of Worcester—and repeated by the noble Lord, Lord Parkinson—in relation to whether, when or how the women’s game or other leagues might be added to the scope. I want to make it clear that I would like nothing more than the women’s game being viewed as mature enough and financially independent enough to be considered to be included. I said several times during the debates on the independent football regulator in your Lordships’ House that I was not allowed to play football at school; it is of huge regret to me still, but I am delighted that my nieces have that opportunity.

The regulations that we are discussing can be updated to change the scope of the regulator’s remit. The Secretary of State must, in that instance, carry out an assessment of whether it would be appropriate to make changes, including consulting the regulator, the FA and any other stakeholders whom they consider relevant. On the process that the Secretary of State would need to go through, a report on her assessment would need to be laid before Parliament; the Secretary of State can then make regulations, if they so choose. We will continue to monitor the health of the game to ensure that the regime is regulating the right competitions. For this first use of the power, we have chosen, as was outlined during the course of the Bill, the top five leagues of men’s football. This is based on years of work, evidence and consultation, including the independent fan-led review.

My noble friend Lord Faulkner raised the issue currently being addressed by National League clubs in the 3UP campaign. The Independent Football Regulator will have a tightly defined scope, as set out in the Act, focused on ensuring the financial sustainability that will protect clubs for future generations of fans. The IFR will not legally be able to act outside of this tightly defined scope and so will not be able to intervene in matters such as the promotion and relegation model between leagues.

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[Lord Parkinson of Whitley Bay (Con)]

My Lords, I am grateful to the Minister for what she set out. We had 10 minutes yesterday for the Urgent Question; it was not quite the opportunity to set out things at length. I am grateful for the further information she has given. The Secretary of State said, when that Urgent Question was taken in another place, that this was not a prime ministerial appointment. Given that, was she wrong to have written, on the submission sent to her on 19 March, that her

“preferred candidate is Mr Kogan, subject to No. 10 giving the green light”?

[Baroness Twycross (Lab)]

I have not taken any part in the appointment process. This matter has been investigated by the Commissioner for Public Appointments. We should let this matter rest and let David Kogan get on with the job.

[Lord Parkinson of Whitley Bay (Con)]

There has been an investigation by the Commissioner for Public Appointments. The Government announced Mr Kogan and confirmed him as their preferred candidate to be chairman before the commissioner had completed his inquiry or published his report. Does the Minister regret moving with that haste, given that the commissioner has now found that three material breaches of the Governance Code on Public Appointments were committed by her department? I am casting aspersions not on the character of Mr Kogan but on the conduct of DCMS in this appointment. The three material breaches imperil the impression of his independence, which is paramount for the future of the game.

[Baroness Twycross (Lab)]

On the question about the green light from No. 10, officials sent questions about the process to the No. 10 appointments teams, but that was not formally sent to the PM for his approval.

[Lord Parkinson of Whitley Bay (Con)]

Would the Minister be willing to let the note that was sent to the Prime Minister be published in the Libraries of both Houses? It would be helpful to see the note that was sent and what the Prime Minister wrote. He has said publicly in his letter to Sir Laurie Magnus that he regrets that having been seen and written. Therefore, it would be helpful if we could see it and determine for ourselves whether that was an official submission to the Prime Minister.

[Baroness Twycross (Lab)]

I appreciate that the noble Lord wishes to prolong this debate and obstruct the progress of the IFR going forward but, no, I am not going to make the commitment that he has asked for today.

[The Deputy Chairman of Committees (Viscount Stansgate) (Lab)]

If it is acceptable, I hope that the Chair can express his congratulations to Scotland on their wonderful victory and on the wonderful goals that secured it; of course, like all noble Lords present, we wish all of the home nations every success in every sporting endeavour.