On 10 November 2026 the Independent Football Regulator opened a six week consultation on how much money clubs should hold in reserve. The proposal sets the amount by how risky the regulator judges a club's finances to be.
The proposed levels
- High risk clubs: reserves equal to five months of operating losses.
- Medium risk clubs: two months of operating losses.
- Low risk clubs: one month of wages.
Premier League clubs would have no fixed figure and would be assessed one by one. The requirement would be phased in over three years from June 2027, with the full reserve expected by 2030.
Why it matters now
Clubs in the top five tiers of the men's game need a provisional licence from the regulator to play in the 2027/28 season. Licence applications, governance reviews and the fitness test for owners, directors and senior executives are already under way, and a reserve rule changes the numbers every board has to plan around.
What clubs can do
Boards can respond to the consultation before it closes, work out which risk band their club is likely to sit in, and build the reserve into their budgets for the next three seasons. We help clubs prepare consultation responses and the governance records the regulator will ask for.
Written on 12 November 2026, while the consultation was open. The final rule may differ from the proposal.
Sources
- ESPN, 10 November 2026: football regulator reserves plan (opens in a new tab)
- Mills and Reeve: the regulator's final regulations (opens in a new tab)