Code of Governance for Football Clubs (England): Consultation Response - Stakeholders

The government White Paper ‘A sustainable future - reforming club football governance’, issued on 23 February 2023, includes the following statement:

To address corporate governance issues in football, the Regulator will establish a compulsory ‘Football Club Corporate Governance Code’.
To date, the poor internal governance at some clubs has allowed owners to act unilaterally, pursuing short-term interests with little accountability or scrutiny. Under the new regulatory system, clubs will be required to apply a new code and report on how they have applied it, to improve transparency and accountability. The code will be applied proportionally, with regard to the size, league and complexity of the club’s business model, and where risk may exist as a result of weak corporate governance.


The Fair Game Governance Working Group has been working on developing a code of governance for clubs since February. A number of meetings of the group have been held as the document has proceeded through a series of iterations. The aim has been to prepare a code to cover all men’s clubs from the Premiership to the National League North and South, which can be presented to the Department for Media, Culture and Sport, and to the regulator (when established) on a ‘here is one we prepared earlier’ basis, as a code with rigorous and robust requirements, and with significant support among clubs.

The code reflects the requirements of other governance codes for other industries. In particular, the group based the code on the UK Corporate Governance code to allow for an entrepreneurial and commercial underpinning. This was enhanced with consultation of A Code for Sport Governance by Sport England and UK Sport, the EFL Trust’s Capability Code of Practice, the National Housing Federation Code, and the Wates Corporate Governance Principles of Large Private Companies.

The code was considered by the Fair Game Advisory Council on 22 June (which looked at the first draft) and 14 September (full draft), and by the Fair Game Board on 4 October. While support has been expressed for the documents, it has been recognised that there should be further consultation to make sure that what we are proposing can reasonably be delivered in practice.

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