The new English Football regulator should set the path to net zero

Ed Thomas

By Pierce McDaid, Ed Thomas

Following the fan-led review of football governance carried out earlier this year by the Department of Digital, Culture, Media & Sport (DCMS), the UK Government has agreed to back the creation of an independent football regulator. As we set out in our introductory article, there is a wide range of challenges a new regulator must tackle – one of which is sustainability. The sport has a significant impact on the planet, with a recent review showing that Premier League clubs produced circa 1,134 tonnes of CO₂ eq in the space of one season – the equivalent of nearly 2,000 flights between London and New York. The arrival of a football regulator provides a golden opportunity to put sustainability front and centre on the sport’s agenda.

Drawing on our experience of designing sustainability approaches in regulators for other industries, we believe there are three different stances the new regulator could adopt, from least to most interventionalist:

  • The tap in: issuing better guidance and providing enhanced support.
  • The team goal: defining common sustainability standards for all clubs to aspire to.
  • The long-ranger: setting formal rules or principles backed up by powers to enforce.

The regulator could opt to move through these broad levels of intervention over time or commit to one of them long-term. In our experience, regulators often face greater pushback if they immediately pursue stringent changes and can be better served by seeking to incrementally increase the levels of regulation over time through engagement, testing, and iteration. However, when it comes to this pressing issue, we believe the new Football Regulator must be bold, galvanising all actors in the ecosystem to deliver a more sustainable sport and planet.

But as with all industries, the regulator’s actions must be considered and proportionate to the risks at play so as not to place an unduly onerous compliance burden on the industry. Here, we take a deeper look at each of the three options for the road ahead.

The tap-in: issuing better guidance and providing enhanced support

As a first step, this softer form of intervention would see the regulator empowering football clubs to operate more sustainably: defining what good sustainable operations look like, encouraging greater transparency, and opening opportunities to recognise and reward best practices.

The regulator could, for instance, develop ‘How to become sustainable’ guides for football clubs, outlining successful policies on reducing match-day waste or carbon emissions offsetting when travelling for fixtures. Another option would be encouraging clubs to sign up to voluntary commitments such the EFL Green Clubs, an environmental accreditation scheme that aims to share environmental guidance and advice to help clubs implement change.

While issuing guidance is a great starting point and will be welcomed by many, it alone is not likely to entice football clubs to adapt and change their ways of operating. Care must also be taken not to disrupt ongoing action. For instance, Tottenham Hotspur subscribed to the ‘UN Sports for Climate Action Framework’ in 2021. But combined with regular engagement with clubs throughout the football pyramid, this approach would at least give clubs the opportunity to access support as they progress through their sustainability journey.

The team goal: defining common sustainability standards

A more assertive measure would see the regulator defining a set of standards within which all clubs are encouraged to operate. The standards would be a framework in which clubs can work, developing their own approaches to sustainability in a way that is tailored to them.

In practice, this requires the monitoring and evaluation of emissions reporting by the regulator – with clubs voluntarily publishing performance records. This will be particularly important because, right now, there are huge variances in reporting. While some clubs, such as Liverpool, Tottenham, and Manchester City, report their carbon emissions and have made public sustainability commitments, others haven’t. There is an opportunity for the Football Regulator to not only encourage all clubs to report on their carbon emissions, but to standardise the approach taken to reporting and publishing this information to provide a level playing field.

Evaluating football clubs’ emissions reporting is within reach, and the football regulator could create a league that ranks the club’s performance. By introducing appropriate incentives for top performers, the league could harness football clubs’ competitive nature in a drive to net zero. For proven methodologies and reporting metrics, the regulator could look to existing leagues such as Sport Positive Leagues, which ranks football clubs in a league system on their environmental credentials across major European leagues.

Alternatively, the regulator could offer incentives to clubs who demonstrate sustainable behaviours, such as Brentford reducing waste by switching to longer cycles for their kits. Other options could see more sustainable clubs rewarded with a greater allocation of tickets for vital games based on their sustainability performance. The usual split sees one-third of the allocation for each club plus corporate sponsors and dignitaries. This could be refactored – with appropriate dialogue, engagement, and cooperation – with an additional fraction being allocated to the most sustainable club.

The long-ranger: setting formal rules or principles

The final, harder form of intervention involves setting formal rules or principles that football clubs must follow. Clubs in English football would comply with these rules, with the regulator having at their disposal a system of censure, financial or otherwise, for those failing to achieve them.

Failing to comply with the rules could lead to financial or other penalties for the club, but this system will require careful design. For instance, the club could be forced to pay their fines into a fund that would then be dispersed across other clubs in the league, potentially strengthening rivals, or used to fund sustainability initiatives across the sport. Whether this example is appropriate remains for debate, but a strong approach will be needed if football is to make itself sustainable.

And while clubs will be expected to adhere to the rules, the regulator must consider each club’s unique circumstances and the degree to which it is proportionate to insist they comply in the immediate term. It is likely that the regulator should focus on the clubs at the top of the pyramid before phasing in the rules for clubs in the lower leagues, targeting those that have the biggest sustainability impact and the resources to adapt their operations to become more compliant more quickly.

Opening up the debate

English football has the potential to use its reach and influence to inspire a move to a more sustainable future for the game and the planet.

To do this, it must be bold but also structured and systematic in the approach it adopts. As any football manager knows, any tactical plan is only as good as the players who put it into action – and so it goes with regulation.

About the authors

Pierce McDaid PA public sector expert
Ed Thomas
Ed Thomas PA operating model expert

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