Member

We do not want, however, a large portion of club staff, senior leadership, ordinary minority shareholders or investors to be considered owners, or to unduly burden clubs with identifying and notifying these persons to the IFR. Rather, the intention is to ensure that all key persons that can, or do, act as de facto owners of a football club can be considered as such by the IFR, regardless of their ostensible role, title, shareholding or rights. That is why we are confident that the guidance laid delivers the policy intent to give the regulator the tools to identify relevant individuals, regardless of any opaque ownership models. In practice, this guidance will be most important in cases where there are complex ownership structures, helping the regulator and clubs to identify de facto owners. The regulator must be able to identify owners who can, or do, shape the key decisions and activities of a club, like an owner typically can or does, even if they do not obviously hold control or influence through their share ownership or voting rights.