The IFR provisional licence: what your club must prepare and when

What the provisional licence is

The Independent Football Regulator (IFR) was set up by the Football Governance Act 2025 to license clubs in the top five divisions of English football: the Premier League, the three EFL divisions and the National League. Every club in scope needs a licence to keep playing in those competitions. The provisional licence is the first stage. It gives the regulator a baseline picture of each club: who owns and runs it, how it is funded, how it is governed and how it hears from its fans.

The regulator has published provisional licensing guidance that sets out the application form question by question. What follows summarises that guidance. Where your club's position is unusual, the guidance and the regulator's portal are the authority, not this article.

The dates that matter

For clubs in the top five divisions in the 2026/27 season, the application window runs from 2 November 2026 to 26 February 2027. Clubs in National League North and South apply once their promotion to the National League is confirmed. The IFR has three months to decide on a complete application, and aims to decide all of them by the end of May, before the leagues hold their annual general meetings. A licence is needed to play in 2027/28.

Nearly four months sounds like plenty. In practice the slow parts are not the form fields. They are getting a current group structure agreed, getting the owner or lender to confirm funding in writing, and getting a board meeting in the diary to approve the final set. Work back from the board date, not from the deadline.

What the application asks, part by part

Annex A of the guidance lists 38 questions. Most clubs can answer the first part in an afternoon. The second and third parts take the time.

You can browse every question, with the related preparation work, on our IFR licensing requirements page.

The two documents that carry the weight

The strategic business plan forecast template

Question 2.1.1 asks for the regulator's own forecast template: a profit and loss account, a balance sheet and a cash flow forecast. The forecast runs to 30 June 2028 on a 30 June year end basis, whatever your statutory year end, with actual results from 1 July 2026 up to the month before you submit. Question 2.1.2 asks for financial statements for the 2024/25 and 2025/26 seasons. The forecast has to reconcile with the narrative answers about strategy, infrastructure projects and funding. If the plan relies on an owner injecting cash, question 2.3 asks for the source, amount, timing, purpose and terms, how it will be secured, and what happens if it does not arrive. We cover this in detail in our guide to the IFR financial plan.

The personnel statement

Questions 3.1.1 and 3.1.2 ask for all owners, the classification of the ultimate owner, and all senior managers with their roles and functions. Question 4.1.1 then asks the club to explain why the statement is accurate. That second question is the one clubs underestimate. It needs a short account of how the club checked its own records, not just a signature. Once the IFR approves the statement, the club must publish it online, and update it after any material change. Our guide to ownership and personnel checks explains what to gather.

Where applications usually go wrong

The questions are not hard on their own. The difficulty is that a club's records were never written to agree with each other. Four mismatches come up again and again.

• The forecast assumes owner funding until June 2028, but the only written commitment covers twelve months.
• The group diagram shows the stadium in one company, but the lease or title sits somewhere else.
• The governance answer describes a finance committee that has not met, or has no terms of reference.
• The fan consultation answer lists a supporters' trust meeting, but there is no record of what was discussed or what the club did next.

What comes after the provisional licence

The provisional licence is the start, not the end. The regulator's licensing framework describes mandatory licence conditions that continue after licensing. These include submitting, updating and acting in accordance with a financial plan, submitting a corporate governance statement against the regulator's Club Code, consulting fans on key matters, and making an annual declaration. A club that builds clean records for the application has most of what it needs for those ongoing duties.

The Club Code has five principles: the board, purpose and strategy, risk oversight and controls, composition and accountability, equality, diversity and inclusion, and stakeholder relationships. The application and the governance statement are different obligations, and the guidance keeps them separate.

A practical timetable

1. October. Gather the accounts, management accounts, funding letters, group records and the last year of board and committee minutes. Name one person at the club who owns the application.
2. November. Draft the forecast in the IFR template and the group diagram. Ask the owner or lender for any funding confirmation the forecast relies on.
3. December. Draft the narrative answers and the personnel statement. Reconcile them against the forecast. List the questions only the board can answer.
4. January. Take the full draft to your lawyers and accountants for the specialist points. Hold the board meeting that approves the set.
5. February. Final checks, signature and submission through the IFR portal, with time left for questions before 26 February.

This is the sequence we follow when we prepare an application with a club. The club keeps the decisions and signs the application. We do the analysis, drafting and coordination in between.

Last updated 5 October 2026. This article is general information about the published regime, not legal or financial advice for your club.