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English football is entering a new era: the Premier League has just handed Chelsea a record fine for hidden payments, while the Independent Football Regulator (IFR) is starting to flex its intentions to improve financial soundness and resilience across the pyramid.
The latest licensing proposals go further, allowing the regulator to categorise clubs as “high‑risk” and then issue a triple ultimatum: owners must either inject more liquid capital, reduce debt or cut costs to show their club can withstand shocks such as relegation or the sudden withdrawal of owner funding. This emphasis on shock absorption reinforces the need for better financial plumbing across the game.
The regulator’s chair, David Kogan, has already pushed back on the idea that scrutiny will scare investors away. His argument is straightforward: a more sustainable pyramid should become a better investment opportunity.
He’s right, but only if we fix the gap the regulator will inevitably expose. We are asking clubs to operate like a regulated industry while much of their financial plumbing still looks anything but fit for a regulated world.
Start with cash. Fair Game’s latest index found that 43 of the 92 clubs in the top four divisions have less than one month of cash reserves to cover operating costs. Under the Independent Football Regulator’s emerging framework, clubs with that level of liquidity could quickly fall into the “high-risk” category, triggering possible direct intervention. And this is a statistic that runs to greater urgency across both non-league and grassroots. In any other sector that’s not lean, it’s a system living on the edge.
This week’s Premier League action against Chelsea shows why this matters. The club was fined £11m after admitting to £47m in undisclosed payments to agents and third parties, transactions that sat outside normal reporting structures. That kind of opacity isn’t just a governance issue; it’s a systems issue. In a truly “bank-grade” environment, those flows would be visible, auditable and far harder to conceal.
This isn’t a criticism of the people keeping clubs alive – it’s often over-worked, understaffed or even volunteers doing institutional work. Outside the Premier League, the finance department can be a volunteer treasurer, a part‑time admin lead and a stack of spreadsheets. Signatories change, committees turn over, and processes get reinvented mid‑season.
The problem is structural. Sport, and football in particular, is mostly a seasonal and fragmented industry. We see revenue arrive in spikes, through matchdays, memberships, grants, sponsorship tranches and transfers; costs are relentless across facilities, staffing, wages, safeguarding and insurance. Many clubs sit in non-standard legal set‑ups: owner-led, community interest companies, PE firms and many other hybrids. And banks? They thrive on standardisation because it makes risk cheaper to understand. Football resists standardisation by nature. But regulation doesn’t, and that tension is now coming to the surface.
So as the Independent Football Regulator pushes the game into a licensing-and-resilience era, the question becomes: what does “good” look like in practice?
Bank-grade
In finance, “bank‑grade” means control, traceability and clarity. It means systems that make it difficult, not easy, for money to move off-books, whether accidentally or deliberately. It means you can answer basic questions quickly: Who can approve payments? Who has authority today (not last season)? What is the club’s true cash position once obligations land? Where is revenue concentrated, and what happens if it fails to arrive?
It also means identity and compliance aren’t an afterthought. In a regulated world, you don’t bolt on KYC, audit trails and governance at the end. They shape how the whole system operates. That was seen in the building of ClearBank, which became the first new full-service UK clearing bank in over 250 years, where the product is infrastructure, controls and transparency.
Football has never had that kind of infrastructure at scale. It’s patched together with generic SME banking, disconnected software, and human heroics. That’s passable when expectations are low. It is not passable when a statutory regulator is actively stress-testing your resilience.
What would “bank‑grade” foundations for clubs actually look like?
It starts with payments that behave like modern commerce that reduce leakage and admin, with real-time reconciliation so matchday income isn’t a week-long spreadsheet project. It means clean and digital authority management, so defined roles, multi-step approvals and auditable trails. The kind of auditability that would surface unusual or off-ledger payments early, rather than years later. Reporting-grade transparency: cashflow forecasting that understands seasonality, plus standardised data so that boards, leagues and regulators can see risk early. And where credit is appropriate, term structures and limits aligned to seasonality, not generic SME templates.
None of that requires football to become a bank. It requires football to stop treating finance as an afterthought.
If the regulator, leagues and clubs treat financial infrastructure as part of sustainability, standardise the basics, incentivise better governance and reduce administrative burden, then the Independent Football Regulator era becomes a catalyst.
That includes how owners are assessed too: not just on intent or wealth, but on whether their clubs are built on systems that can withstand scrutiny. Better discipline attracts better capital, and “investment in the pyramid” stops being a slogan and starts being measurable.
If we don’t, we’ll learn the hard way that you can’t regulate resilience into a system that still runs on fragility.
Andrew Smith is founder and chief at Sporta
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