The Independent Football Regulator -IFR-, the public body established to oversee the sustainability of English clubs, warned on Tuesday that their finances were “dangerously exposed”. Its first draft report found that 94% of clubs across the top five divisions recorded losses in 2025-26. During the presentation, its chair, David Kogan, also denied receiving political pressure over the Manchester City case. The two issues highlight different responsibilities for the regulator: preventing financial crises and assessing the suitability of those who own and run clubs.
The findings show that commercial growth does not guarantee stability. English football generated around £9 billion in 2025-26, but 29% of the clubs consulted said they would not survive more than thirty days without fresh funding from their owners; 66% put that limit at ninety days. That dependence requires a distinction between having an owner willing to cover losses and having the resources to meet obligations if that support stops. The study draws on information obtained directly from clubs and competition organisers, combining actual figures and forecasts for the latest season.
Higher revenues do not guarantee stability
More than 60% of clubs across the English Football League -EFL-, which comprises the three divisions below the Premier League, and the National League, the fifth tier, have liabilities exceeding the book value of their assets. The report describes this as technical insolvency, which does not mean that all these clubs have entered formal insolvency proceedings or stopped paying their bills. The IFR proposes increasing available liquidity, improving risk management and preparing contingency plans for the withdrawal of owner funding. Its plan also addresses revenue distribution, losses, fan engagement and club governance.
The Premier League supported the preference for a football-led agreement on revenue distribution and said additional funding must be accompanied by financial controls and reforms. According to reports cited by ‘Reuters’, its proposal to the EFL offers an additional £1.8 billion over ten years, while the EFL is seeking £1 billion over five. These are proposals covering different periods, rather than a concluded agreement. The discussion concerns both how much money reaches the lower divisions and the incentives to spend: the report identifies substantial revenue gaps between tiers that increase the risks associated with chasing promotion or suffering relegation.
City and the oversight of club owners
The Manchester City case raises a separate oversight issue. An independent commission concluded on 29 September that the club had committed serious breaches of the Premier League’s financial rules between 2009-10 and 2017-18, alongside failures to meet its cooperation obligations. Its findings included commercial agreements that, according to the commission, concealed owner funding and misrepresented reported revenues and costs. City lodged its appeal on 1 October, argues that the decision contains material errors of law, principle and fact, and maintains its innocence. Any sanction will be determined at a separate hearing.
The Premier League’s disciplinary process and the IFR’s powers have different remits. The public body assesses owners’ honesty, integrity and financial soundness, as well as the competence of those in senior management roles. Its powers include investigating existing owners and executives and taking action against those it considers unsuitable, through its own procedures. The City findings could be relevant to such an assessment, but they do not constitute an IFR decision on the club’s owners or trigger automatic intervention. Nor does the wider report establish that City faces the financial vulnerability described at other clubs.
Independence and the next decisions
Kogan addressed the political question during the presentation at the National Football Museum in Manchester, England. “Any form of political interference on the way we operate is going to result in my resigning from this role,” he said. He also clarified: “We’ve come under absolutely no political pressure whatsoever on this or any other topic.” His remarks represent a commitment to independence and a denial of pressure, rather than the announcement of an investigation into City. Any action concerning its owners would require a separate assessment under the regulator’s statutory powers.
The report is open for consultation until 8 December, with a final version expected in early 2027. Meanwhile, the Premier League and EFL continue negotiating revenue distribution, and City’s appeal remains pending. The IFR already has powers over owners and senior executives and is preparing to implement its licensing system: clubs within its remit must apply for a provisional licence during the 2026-27 season. That licence will enable oversight of compliance with the new regime’s financial and governance requirements, while breaches of competition rules remain subject to the football authorities’ disciplinary procedures.
