Role, Remit and Composition of the Regulator


The People’s Football Association – #FAEQUALITYNOW was set up in June 2020 as a campaign group to change the archaic governance of The Football Association. The vision is simple: Equality for all in English football.

Our long term goal is to strengthen the remit, role and governance of The FA but for this to happen, it needs the biggest overhaul in 157 years.

Corporate governance best practice indicates a need for an Executive Board with the appropriate composition and skill-set to provide leadership for an organisation and to allow for timely and effective strategic decision-making. The FA organisational structure differs from that of single board organisations (the prevalent organisational form for companies in the UK) by virtue of its dual-board structure comprising the Main Board and Council. In addition, there is also the Professional Game Board and National Game Board and a plethora of committees, each having their own decision-making powers and remits.

The Football Association’s structure does not conform to the standard UK company governance model – shareholding is confined to a closed-group of individuals, the shares are non-transferrable and carry no monetary value.

In October 2020, The People’s Football Association – #FAEQUALITYNOW developed the #FAEQUALITYNOW Blueprint for change – new governance and constitution of the Football Association which, at its core is public-led and where everyone can join The FA Membership. One person, one vote. Truly inclusive and democratic. This was first communicated in our presentation on June 25th to the Fan-led review committee chaired by Tracey Crouch. On 9th September 2021, The People’s Football Association – #FAEQUALITYNOW went public with the campaign.

Tracey Crouch writes in her letter to Oliver Dowden, Secretary of State for Digital, Culture, Media and Sport, “The football authorities have also had multiple opportunities to reform – the 2011 DCMS Select Committee highlighted many of the same problems that have been clear in evidence to the panel and stated that if football did not change legislation would be needed. I and my predecessors as Sports Minister often stood at the Dispatch Box and claimed that it was the ‘last chance saloon’ for football to reform itself. It is with some sadness that I note they didn’t heed those warnings and that therefore it is time now for external assistance.”

The People’s Football Association – #FAEQUALITYNOW was set up well before the Fan-led review was commissioned. This review initiated by the government has hopefully accelerated the opportunity for change.

Whilst our #FAEQUALITYNOW Blueprint for change is core to the long term and sustainable future of The Football Association and English football, we agree from the interim fan led review letter from Tracey Crouch to Oliver Dowden that an Independent Regulator is needed as the first step to make substantial changes.

The five key points below are the mandate we believe need to come under the Independent Regulator, whose work, strategy and implementation should begin in earnest.

Role, Remit and Composition of the Regulator

The Regulator should be established by statute with the objective of building trust, transparency and sustainability in football. This can be best-achieved by having powers to set rules and requirements for football authorities and clubs and monitor their compliance with them, as well as powers to pursue enforcement where clubs and authorities do not meet their obligations. As equally important are key areas which The People’s Football Association – #FAEQUALITYNOW wish to reside with the Regulator. That primarily is the Regulator leading the implementation, compliance and research.

Appointment of Board Members of the Independent Regulator will be made by an Approval Council. The members of the Fan-led Review to be given an extended tenure and become the Interim Approval Council. The Interim Approval Council will then develop the make-up of the permanent Approval Council and how the permanent Approval Council will be selected. The final approval of all Board appointments of the Independent Regulator will lie with the government.

No Board Members may be current directors or significant shareholders in, or employees of, clubs in The Premier League, The English Football League, National League, Women’s Super League or The FA Women’s Championship, or any other football stakeholder body associated directly or indirectly with The Premier League or The Football Association. The Board shall consist of up to eleven Independent members appointed by government. This is crucially important as the vested and competing interest stakeholder model of The FA has not worked and is a core reason why Football governance in England has failed time and time again.

The Board would report on a regular basis to the Parliament, DCMS, and the public, who shall become the constituents of the Independent Regulator.

The five areas outlined below are key to transform the perception of the public and fans towards English football, and ensure there is a sense of public duty. We also agree there are other areas which the Regulator should oversee especially from a club licensing perspective, protecting the crown jewels and fan representation at clubs as outlined by the Fair Game UK campaign group.


With the Regulator established – the main goal in the medium term is the total reform of The FA as outlined in the #FAEQUALITYNOW Blueprint for change.

The #FAEQUALITYNOW Blueprint for change is currently the only proposed model for The FA’s reform. This should be the starting point for public debate and discussion, on changing the status quo and becoming a public-led body in the near future. We are a group of professional and knowledgeable parties with broad experience in the football world and over the areas of concern which we wish to see change.

Transparency is another key element of our proposal hence The FA should be a public body and come under the Freedom of Information Act.

We refer to  Letter from Tracey Crouch MP to Rt Hon Oliver Dowden CBE MP on the work of the Independent Fan Led Review of Football Governance

In the case of the FA, I welcome initial proposals from the FA Chief Executive Mark Bullingham on FA Board reform which he worked hard to secure and present to the Panel, and am inclined to recommend that at least 50% of the FA Board are genuinely independent non-executive directors and that significant reform of the FA Council is undertaken.

If the Board was the sole and main ruling organ of The FA, this would be a positive step, but as it is not and competes with the Council, Professional Game Board, National Game Board, this current proposal from the FA does not change the status quo and in reality will worsen the situation and hides what change is really required.

The Premier League has direct financial control through the ‘ Professional Game Board’ which controls the funding from professional football e.g. FA Cup & England Team TV rights, gate receipts etc. The PGB is effectively the Executive Board of the FA. The constitution of the PGB set up in 2002 caused Adam Crozier to claim it was effectively constructive dismissal of his role.

Recommendation: A fundamental overhaul of the FA needs to take place. The Government should put in place a commission to complete this process that is fully independent of The FA to undertake this work. The commission comes under the remit of the regulator. #FAEQUALITYNOW Blueprint for change is currently the only proposed model for The FA’s reform and should be the starting point for discussion. We need a FA where the membership is open, transparent and is governed independently.


The key to any strategy in Diversity and Inclusion is to collect the baseline data. This is an important starting point as it gives a thorough overview of the status quo, and indicates what needs to be improved. Unfortunately The Football Association does not have such data and without it, the FA cannot move forward. The marketing and communication on South Asian month and black history month from the FA hides the real truth and facts regarding no baseline data and key metrics regarding under-represented groups.

One key goal is to have more black managers in the 92 professional clubs, but there is no data on how many black coaches have obtained UEFA Pro, A, B Licence and qualifications.

Another key goal is to encourage participation amongst British-South Asians in England. Once again there is no data on how many British-South Asian players are playing in the 92 clubs’ academies at the different age groups.

The Football Leadership Diversity Code has no compliance and certainly no tracking of data occurs relating to participation amongst minority communities.

The Football Leadership (FA) Careers platform has of today 12 jobs in the industry of which 5 come from Liverpool. Given the ground breaking news of this 12 months ago. This has not worked either in improving the opportunities within the football industry to underrepresented groups

There are many more examples.

All these point to the governing bodies in English football being unable to collaborate and the FA’s inability to govern effectively.

Equality and diversity of inclusion is an important issue for our society, and the treatment of several non-white footballers during the Euros this year has demonstrated that there is much work to do in this area. Adequate representation in the football governing body is key to this. The baseline data is the staring point.

Recommendation: EDI needs to come under the mandate of the Regulator. Data must be collected, updated in real-time, tracked and reported (to the extent privacy laws permit) on a regular basis. There should not be quotas in terms of representation but certainly consolidated reports and individual data reports on the two key goals outlined above and a number of other key metrics.

  • Governance/Independence of English Football Stakeholders

The Premier League has been a national and worldwide success and we hope it continues to develop, grow, engage and where competitive balance should always be its core strength.

The success of The Premier League has led to its influence in shaping policies, both within the FA and other football stakeholders such as FSA, Kick It Out, The PFA, LMA, Football Foundation, being funded directly by The Premier League. In some cases, such as Kick It Out and The Football Foundation The PL are trustees and key to their governance.

Recommendation: All the football stakeholders outlined above should be independent. The Premier League and The FA should not be part of Kick It Out governance. The Premier League should not be part of The Football Foundation. For example, no other individual league in Europe has a remit for football facilities. This just shows how far the Premier League wish to go to control or influence the English Football stakeholders and whilst there should be collaboration, what has occurred has gone too far. The Football Foundation should be disbanded and come under The FA’s Facilities Division. For any of FIFA’s member association – facilities and infrastructure is a core remit, hence again why this should be The FA’s sole responsibility. The direct distribution of commercial revenues from The Premier League to football stakeholders should cease. In place should be a sub-body of the Independent Football Regulator to distribute such funds, which shall be a fixed amount over a 10-year period as determined by the Independent Regulator. It is also recommended that a similar mechanism be put in place for the EFL. The vast amounts of money invested in football, particularly by fans and the public, should be directed into areas of concern such as improving diversity and health and safety.

  • Football Health and Safety Commission

During the recent Government Inquiry into head injury in sport, DCMS committee chair Julian Knight MP stated ‘What is astounding is that when it comes to reducing the risks of brain injury, sport has been allowed to mark its own homework.’ Although legally the Health and Safety Executive assumes responsibility for management, the report noted that this had appeared to be delegated to the National Governing bodies. Since the first post mortem conclusion of a footballer’s death to be attributed to industrial injury 19 years ago, the governing bodies have taken minimal steps, with a lack of urgency and accountability, to address the risks of exposure to head injury in football. Despite scientific evidence of the significantly increased risks of neurodegenerative disease in footballers, there has been an extremely conservative approach to head injury, overtly requiring increasing levels of evidence of risk before considering changes to safety; evidence which may take decades, or may never even be fully attained. This approach is deeply concerning, and out of keeping with the overarching ethical principle of medicine, which is to ‘first, do no harm’. We advocate a precautionary approach to the risks of neurodegenerative disease in football, which involves minimizing risks to players as the urgent priority protecting players from the risk of harm, alongside the ongoing advancement of knowledge. 

The governing bodies have been given a task which is likely out of their remit – the responsibility to decide what best protects footballer health and welfare. If significant changes to the game are required for this, there may be many conflicting priorities, and the ability to internally moderate ethical judgement when the potential effects of a decision are entwined with other responsibilities, makes the case for independent oversight. The expertise and impartiality required for this lies outside the governing bodies, and requires a context in which decisions are made by professionals empowered to view footballers holistically as people, who, well beyond their short careers, have the right to make informed choices to achieve a full and healthy life. If a player is exposed to a potential risk, the benefit of the exposure is weighed against the harm. When the equation is removed from the realm of a football game and into a medical and ethical context, the health of the player can be put at the centre of the decision-making. This also encompasses accountability to act promptly in light of evolving information, transparency, and the professional assessment of funding allocation into meaningful, ethical and conflict-free research. An independent regulator would fulfil these functions.

Safeguarding has been another significant failing within the English Football family, where first hand evidence received by survivors is that the FA sweep it under the carpet, apologise again and ultimately wish to protect their brand image first. Therefore safeguarding and protecting children should come under the Independent regulator for ongoing compliance and developing better and robust reporting mechanisms. Whilst, we agree the FA should continue in terms of education and professional development, there may of course be better ways to protect children from abuse.

The recent cardiac arrest of Christian Eriksen at UEFA EURO 2020 Championships highlighted the need for a swift and timely response. What again is surprising is that under the FA competitions (county FAs) there is no consolidated data on injuries, ambulance call outs, deaths on English Football pitches up and down the country. Let alone no data on which pitches, clubs have defibrillators.  All this data should come under the auspices of the FA. This should not only protect players at a high professional level, but is relevant to the thousands of people who play football at grass roots’ level and have a right to guidance and protection.

Head for Change is a charity formed specifically for players affected by head injury in sport, with a strong scientific and academic team. They would be key in assisting with the intricacies around regulation in this area.

Thousands of people play and watch football every week. Decisions by the governing bodies affect those watching and also those playing, with regard to health and safety policy. It is therefore important that they have a voice in its direction and processes.

Recommendation: A new commission directly under the regulator should be set up to oversee all Health and safety areas within Football. This commission would have significant resources at its disposal for medical research, safety research and regulation, compliance. It would work closely with the health and safety executive. The commission would have the ability to propose further legislative change. Broadcast revenue as a fixed percentage and appropriate contributions directly by The FA and PFA to the Football Health and Safety Commission.

The Independent regulator to have direct access to all data concerning injuries, ambulance call outs, deaths and to ensure defibrillators are mandatory on every pitch with at least two trained people in attendance.


The People’s Football Association – #FAEQUALITYNOW agrees with Tracey Crouch that real-time financial reporting, cost control, and setting minimum governance standards will be central to how the Regulator supervises football clubs. The new Regulator should primarily follow the model of regulation and supervision adopted in the financial sector. We need better prevention and intervention in real-time before further financial cases such Bury and Macclesfield Football clubs make it too late.

Recommendation: Standard real-time reporting for all professional and non-league clubs (up to National League). Public and fan shall have access to all reporting. This should be the first step in transparency and intervention where needed.

Download the document