BASIS - The British Association for Sustainable Sport

BASIS Response to IFR State of the Game Consultation

The Independent Football Regulator (IFR) was created by Parliament to strengthen the financial sustainability of English football. Its core purpose is to protect club soundness, improve resilience across the leagues, and safeguard the long-term future of the game following a series of high-profile financial and governance challenges.

During the passage of the legislation, there were lively debates about whether environmental sustainability and climate change should fall within the Regulator’s remit. Ministers ultimately chose to keep the scope tightly focused on financial oversight and fan protection, rather than expanding it into broader environmental regulation.

However, the State of the Game report is different from the IFR’s day-to-day regulatory role. It’s designed as a periodic, system-wide assessment of the structural health of football’s finances – to look at long-term risks, resilience, and emerging challenges.

Across UK economic policy, climate change is now recognised as a material financial and macroeconomic risk. At the same time, climate impacts – from extreme weather disruption to rising insurance pressures — are already affecting football and other sports.

For that reason, BASIS submitted a response suggesting that, where financially material, climate-related risks should form part of this broader systemic review. We have not argued for an expansion of the Regulator’s remit or for new environmental regulation. We have simply suggested that a comprehensive assessment of football’s long-term financial resilience should consider the full range of risks that may affect it.

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