Lord Maude of Horsham (Con)

My Lords, I have a concern with the whole of this part of the Bill and the way in which operating licences will be required and the adjudication made upon them. This part of the Bill is nine very dense pages of text, backed by three or four schedules. At various stages, it includes such dark phrases as: “An application must be accompanied by … such other information and documents as may be specified by the IFR in rules”. I used to be a lawyer, a long time ago, and I am reasonably accustomed to reading Bills and Acts, but when I start to read through this part of the Bill I can feel my lifeblood draining away. What of the owner or board of a small club looking at what will be required of them? I noted that in the Minister’s winding up of the last debate she said that well-run clubs have nothing to worry about, which was meant to be reassuring. It does not matter how well-run a club is; it will have to comply with all this, and it will have to set itself up with lawyers, consultants and accountants to draw up a strategic business plan. A lot of clubs will not have a strategic business plan. That does not mean that they are badly run, but they will have to prepare such a plan. A strategic business plan is a document containing the proposed operation of a club: its estimated costs, how those costs are to be funded, the source of such funding and other information as may be specified by the IFR. That does not get done spontaneously or arise automatically. The reality is that this is a very demanding regime intended to be put into law and enforced by the new regulator. I wonder whether there has been sufficient consideration given to putting in place a halfway-house system of regulation. Think about how companies are regulated: it is a requirement that, if you set up a limited company, designed to limit the personal liability of owners of the company, it is registered with Companies House. By law, certain listings are required and a certain amount of information has to be made public, including the filing of accounts. However, you do not have to get consent from a regulator to set up a company; you just have to register that it is in existence and subject to the laws that apply to it. As we know, the state of football is pretty strong, stable, vigorous and successful compared with football in other, similar jurisdictions to ours. Have we given sufficient consideration to whether it might be good to take time, before we require small clubs up and down the country—which are not necessarily finding it easy to get through from week to week, month to month and year to year—to submit to this horrendous set of requirements just to get a licence to get on to the field of play in the first place, before they even set about winning a match, to go back to the drawing board and construct a regime that would require clubs to register in the same way that a company is registered, subject to rules and requirements for disclosure and transparency, and to changes being registered. That would reduce hugely the burden on clubs and would start to introduce the kind of consistency which, for reasons that I totally understand, is being sought. I oppose the whole of Part 3 and its accompanying schedules—I am not even going to think about the plethora of regulations, guidance and further verbiage that will come out of it—standing part of the Bill.