The State of the Game: What the Independent Football Regulator’s report means for Wolves supporters
A briefing from the perspective of Wolves 1877 Supporters’ Trust
Introduction
The Independent Football Regulator (IFR) has published its draft State of the Game report, providing a comprehensive assessment of the financial sustainability, governance and supporter engagement of English men’s football.
The report makes uncomfortable reading. Despite staggering growth in revenues, English football has become increasingly dependent on owner funding and debt, with rising costs, persistent losses and significant financial risks across the game.
As Sir Jack Hayward famously said in the late 1990s: “Everyone thinks I’m the Golden Tit. They think they can suck endless amounts from me.”
The IFR’s central concern is not simply that clubs spend too much money. It is that the financial structures, incentives and governance arrangements within football are increasingly leaving clubs vulnerable when on-pitch results fall away, revenues fall, or owners are no longer willing or able to provide investment finance.
This is where the IFR brings relevance to Wolves supporters. Football clubs are more than a commercial enterprise: Wolves are a football club with a long history, a loyal supporter base, and arguably the jewel in the crown of the city.
Wolves 1877 Trust believes supporters have a legitimate interest in understanding how the club is governed, how financial risks are managed, and whether the decisions made today protect the club’s long-term future.
We are not seeking to undermine our owners. We are simply raising the questions for which any stakeholder should seek answers.
The IFR report provides a framework for considering the questions we are asking locally and which are now being voiced across the national game.
This briefing draws on the IFR’s draft report published in 2026. Its financial findings cover the period 2021/22 to 2025/26, with some figures for the final season based on forecasts. The report does not, in itself, establish that Wolves has breached any regulatory requirement.
1. Football is generating more money, but financial sustainability is deteriorating
One of the report’s most alarming conclusions is that the growth of football revenues has not translated into a stronger financial position for the majority of clubs.
Across the top five English leagues, 94% of clubs were loss-making in 2025/26. The report also shows that average player wage costs increased between 2021/22 and 2025/26 by:
33% in the Premier League
32% in the Championship
71% in League One
63% in League Two
The IFR report also identifies rising agent fees, transfer costs and non-player operating expenses as contributory factors.
Competition for sporting success drives clubs to spend more, gambling on future revenue streams to balance the books. In this drive for success, clubs can become dependent on external financing to sustain their operations - the “golden tit” scenario.
Why this matters to Wolves
Supporters should be interested in the relationship between football expenditure, revenues and the club’s long-term financial position.
Following relegation, we have faced a significant reduction in income while maintaining substantial financial commitments to players, staff, infrastructure and other operating costs. An aggressive 12-month promotion plan has been put in place.
The question we are asking is not simply whether Wolves can afford to spend money in a particular transfer window. It is whether the club has a sustainable financial and football strategy that remains credible over the medium to long term.
Supporters should be able to understand the broad principles governing that strategy, even if commercially sensitive details cannot be disclosed.
2. Owner funding is not a substitute for financial resilience
The report highlights the extent to which clubs depend on their owners to meet their financial obligations.
Among the 112 clubs that responded to the IFR’s financial information request:
66% reported that they could not survive for more than 90 days without new owner funding
29% reported that they could not survive for more than 30 days
Between March 2025 and March 2026, 67 clubs received at least six funding injections, while 28 received at least 12
The IFR identifies a particular risk where clubs depend on continued funding from an owner but lack adequate contingency plans should that support become unavailable.
It also stresses that the circumstances of an individual owner matter. An owner may be willing and able to fund losses for an extended period, but a club remains exposed if its business model depends on that support continuing indefinitely.
Why this matters to Wolves
Wolves supporters have a legitimate interest in the distinction between an owner’s willingness to invest and the club’s underlying financial resilience.
Having a wealthy owner with access to shareholder funding does not, on its own, demonstrate that the club has a sustainable business model.
Equally, losses or borrowing do not automatically mean that a club is in immediate financial danger.
The terms of the funding, the availability of cash, the maturity of debt, and the owner’s capacity and commitment to continue providing support all matter.
The questions we are asking:
Does the club have sufficient liquidity to meet its obligations as they fall due?
How dependent is it on continuing shareholder support?
What contingency arrangements exist if expected funding is reduced or withdrawn?
How would the club respond to a further fall in revenues as a result of an extended period in the Championship?
Is there a credible long-term plan to reduce financial vulnerability?
These are questions about financial resilience. They are not confrontational, and it is not an unreasonable request to seek clarity.
3. Debt must be understood in terms of its purpose, cost and risk
The IFR reports that aggregate debt across English football increased from approximately £2.8 billion in 2020/21 to £4.1 billion in 2024/25, with a forecast of £5.1 billion by 2026/27.
The report distinguishes between different types of borrowing. Shareholder loans, commercial loans, transfer debt and financing secured against future transfer receipts have different implications for a club’s finances.
The report also shows that the cost of borrowing has risen. Aggregate interest costs across English football increased from approximately £97 million in 2020/21 to £455 million in 2024/25.
The IFR identifies the use of debt, the security pledged against it, and the repayment obligations arising from it as significant factors in assessing financial risk.
Why this matters to Wolves
Supporters should not judge the club’s financial position simply by looking at its reported debt total. We should seek to understand what the borrowing finances, who is owed the money, what security has been granted, and when repayment is required.
We know our stadium and training ground have been used to secure borrowing, alongside future earnings against media revenues.
For Wolves, questions about refinancing, shareholder loans and other financing arrangements should be considered in the context of the club’s wider financial position.
We have a legitimate interest in understanding whether financing arrangements:
leave the club exposed to significant repayment obligations
depend on continued owner support or further refinancing
restrict the club’s ability to respond to relegation or other financial shocks
affect the club’s capacity to invest in the playing squad, academy, stadium and other infrastructure
have implications for the club’s long-term ownership model, vision and strategic plan
Refinancing arrangements may improve short-term liquidity or simply replace an existing facility. The question we ask is do they resolve the underlying question of whether the club generates sufficient income to sustain its operations?
The IFR’s wider message is that debt should be assessed as part of an overall financial risk framework, rather than in isolation.
Wolves supporters understand that Fosun underwrite the club’s financial risk position, and we also understand what that risk means if our owners position changes.
4. Relegation exposes weaknesses in a club’s financial model
The IFR identifies relegation from the Premier League as one of the most significant financial risks facing clubs.
For clubs relegated in 2024/25, the report estimates that average total revenue fell by £70 million, or 42%. Average wage costs fell by £29 million, or 34%, which did not offset the reduction in income.
The report also found that average EBITDA fell by £32 million and external financing increased by £11 million.
Parachute payments provide some protection, but they do not remove the financial shock. The IFR argues that the current arrangements can also encourage Championship clubs to overspend in pursuit of promotion.
Note: EBITDA – Earnings Before Interest, Taxes, Depreciation, and Amortisation.
Why this matters to Wolves
The implications are very relevant following Wolves’ relegation.
The club must manage a different revenue environment while making decisions about player contracts, recruitment, sales, staffing and infrastructure. These decisions will influence not only immediate performance, but also the club’s ability to recover and remain financially sustainable.
The Trust is asking whether Wolves has a coherent plan for rebuilding the football operation and restoring financial resilience.
That means understanding the relationship between:
expected revenues and planned expenditure
player recruitment, retention and sales
the wage bill and the likely income of the club
investment in the academy and football infrastructure
the need to balance immediate competitive ambitions against longer-term financial security
A strategy based primarily on achieving rapid promotion can create its own risks if it depends on expenditure that the club cannot sustain without returning to the Premier League - and crucially what happens if that strategy fails?
The IFR’s findings reinforce the importance of a credible plan that does not leave the club vulnerable if promotion takes longer than one season.
5. Corporate governance is an essential part of financial risk management
One of the report’s most important findings for supporters concerns corporate governance.
The IFR states that effective corporate governance is an important means of mitigating financial risk. It can also help clubs attract investment, protect their identity and maintain relationships with supporters and local communities.
The report identifies significant scope for improvement in corporate governance across football. Its analysis draws on a survey of 43 clubs and publicly available information, rather than the comprehensive financial dataset used elsewhere in the report.
The IFR intends to require licensed clubs to publish a corporate governance statement every two years, beginning in October 2027. These statements will explain how clubs are applying the IFR’s ‘Football Club Corporate Governance Code’.
This is an important development because it will give supporters and other stakeholders greater visibility of governance practices that are often difficult to assess from outside the boardroom.
Why this matters to Wolves
A football club can have substantial revenues, valuable players and a wealthy owner, yet still be exposed to poor decision-making. Wolves are a case in point if the benchmark for poor decision-making is high turnover in managers and relegation.
Good governance requires more than formal compliance or the existence of a board. It involves clear responsibilities, effective challenge, proper oversight of risk, and a board capable of making informed decisions in the long-term interests of the organisation.
The Trust has a role in considering the governance of the club, relevant questions include:
Does the make-up of the board reflect the prime role of the club - football?
Does the board have a clear and credible long-term strategy?
Are financial risks properly identified, assessed and monitored?
Are directors provided with the information and expertise needed to challenge executive decisions, often made by remote owners?
Are responsibilities for financial performance, football operations and infrastructure clearly defined?
Are conflicts of interest and related-party arrangements appropriately managed?
Does the board review its own effectiveness and the quality of its decision-making?
Is there sufficient transparency to allow supporters to understand the club’s direction and priorities?
These questions do not seek to establish that Wolves has failed to meet a particular governance standard. They are legitimate areas of scrutiny in light of the IFR’s findings and the importance of good governance in achieving financial sustainability.
The forthcoming governance reporting requirements should provide an opportunity to assess the club’s approach against a recognised framework, rather than relying solely on assurances from its owners or executives. Meanwhile the Trust is raising legitimate questions directly with the club, in line with the expected reporting requirements.
6. Strategy and accountability matter as much as individual decisions
Financial sustainability cannot be assessed solely by examining individual transfers, annual accounts or a particular financing transaction.
A club’s underlying strategy determines how these decisions fit together.
The IFR identifies financial overreach, reliance on owner funding and weak governance as factors that can leave clubs particularly vulnerable to financial distress. It also stresses that risks must be assessed continuously, taking account of both financial indicators and wider circumstances.
For Wolves, this raises questions about the relationship between ownership ambitions, football operations, financial planning and the club’s long-term future.
Supporters should reasonably expect the club to have a clear strategy that explains:
its sporting and financial objectives
how those objectives will be funded
the intended development of the first team and academy
the role of player trading in the business model
plans for stadium investment and wider infrastructure
how the strategy will adapt to changes in league status and revenue
how progress will be measured and accountability maintained
Commercial confidentiality may prevent the publication of detailed forecasts and negotiations. It should, however, not prevent the club from explaining its overall direction, objectives and approach to managing risk.
A strategy that is understood by the board but not communicated meaningfully to supporters provides little reassurance about the club’s future.
The Trust seeks assurances about an underlying supporter concern about the strength of the club’s board and its influence in the decision-making process.
7. Supporters must be heard when decisions affect them
The IFR’s report is not confined to financial matters. It also examines the quality of fan engagement and its relationship with club governance.
Its findings indicate that supporters are generally more satisfied with opportunities to engage than they are with the extent to which their views influence decisions.
Only 39% of surveyed supporter groups were satisfied with how their views were considered in club decision-making, while 37% were satisfied with communication and transparency around those decisions.
The IFR concludes that clubs must demonstrate how they take supporters’ views into account. Under its proposed approach, clubs will be required to consult supporters before decisions affecting them, explain their thinking, listen to feedback and take those views into account. Annual fan consultation reports will provide evidence of how this has been done.
Why this matters to Wolves
For Wolves 1877 Trust, this is a significant finding.
Supporter engagement should not be measured simply by the number of meetings held, the existence of a Fan Advisory Board, or the opportunities provided to submit questions.
The more important issue is whether engagement is meaningful and influences the way decisions are made.
We may not agree with every decision, and consultation does not mean the club must accept every recommendation. But there should be a meaningful process through which views are gathered, considered and answered.
The Trust continues to seek:
early consultation on significant decisions affecting supporters
clear explanations of the issues on which the club is seeking views
evidence that supporter feedback has been considered before decisions are finalised
explanations where the club decides not to follow the views expressed
greater transparency about the outcomes of consultation
recognition of the role of independent, democratic supporter organisations in representing their members
The IFR’s findings strengthen the case for assessing fan engagement by its quality and influence, rather than simply by the existence of formal structures.
The Trust recognises, and welcomes, the club’s review of its fan engagement process, and looks forward to improved consultation.
8. The importance of an independent supporters’ trust
Wolves 1877 Trust has a distinctive role in this process.
As an independent, democratic, not-for-profit supporters’ organisation, the Trust can gather views from its members, scrutinise published information, identify issues of wider concern, and engage with the club on behalf of supporters.
Its role is different from that of a club-operated consultation group. The Trust is able to develop its own positions, ask questions that do not originate within the club, and maintain a continuing focus on the interests of supporters.
The IFR’s report provides a useful framework for that work across two connected areas.
Financial scrutiny
The Trust will examine published accounts, financing arrangements and the club’s stated strategy, identifying questions that warrant explanation. It can also assess whether the club communicates the financial implications of major decisions in a meaningful way.
We understand that finance is not a required skill set for a football supporter. However, among our wider fan base are individuals who will support us in carrying out this work.
Governance and accountability
The Trust seeks clarity about strategic objectives, board accountability, risk management and the processes through which supporters’ views are considered. We will use the IFR’s emerging governance and fan engagement requirements as benchmarks for constructive scrutiny.
The Trust does not seek to replace the responsibilities of the club’s directors, nor does it seek to conduct a regulatory assessment of the club or claim access to confidential information to which we are not entitled.
Our role is to provide an independent supporter perspective, promote transparency, and encourage decisions that protect the club’s long-term future.
We want to be a critical friend, we all have the same overall objectives, working together makes us stronger.
9. What should Wolves supporters expect next?
The IFR’s report sets out a programme of change intended to improve the financial sustainability and governance of football by May 2030, when clubs are required to have full licences.
For the Trust and Wolves supporters, the most important developments to monitor are:
Financial resilience: whether the club can demonstrate a credible approach to managing liquidity, debt, losses and the financial consequences of sporting setbacks.
A long-term strategy: whether Wolves communicates clear sporting, financial and infrastructure objectives, together with an explanation of how they will be delivered.
Board-level governance: whether the club can demonstrate effective oversight, clear accountability and a structured approach to financial and strategic risk.
Transparency: whether the forthcoming IFR corporate governance statements provide meaningful information about the club’s practices and priorities.
Meaningful supporter engagement: whether Wolves can demonstrate that consultation influences decisions and explain how it has responded to supporter views.
Protection of the club’s long-term interests: whether decisions about ownership, financing, player trading and infrastructure support a sustainable future rather than relying excessively on short-term outcomes.
The Trust will continue to use the IFR’s developing regulatory framework as a basis for constructive engagement with the club, while retaining its independence and its responsibility to represent the interests of its members.
Final thoughts
The IFR’s ‘State of the Game’ report makes clear that financial sustainability and good governance are inseparable.
The club’s future cannot safely depend on ever-increasing revenues (ticket price rises aren’t the answer), continued injections of owner funding, or the assumption that sporting success will eventually resolve its financial challenges. Nor is the existence of a formal governance structure sufficient if remote strategic decisions are not properly scrutinised or financial risks are not adequately managed.
For Wolves, the challenge is to establish a credible long-term direction following relegation, supported by sound financial planning, effective governance and meaningful engagement with supporters.
Wolves 1877 Trust will continue to seek appropriate scrutiny, transparency and accountability in these areas. This is not about seeking to manage the club from outside the boardroom. It is about recognising that supporters have a legitimate interest in how their club is run and in whether decisions protect its long-term future.
Wolves is our club. Its long-term sustainability should be a shared priority for the club, its owners and its supporters.
What can you do?
We all want success for our club, but we don’t want failure to cost us our future - we have been there before.
We want a vision and strategy for our club that we can all get behind. Football is at the heart of our community and of the City.
If you want to make a difference, please join the Trust. Help support the work we are doing. Our strength is through your support.
Join the Trust: https://www.wolves1877trust.co.uk/membership
References:
Download the IFR State of the game report: https://sotg.footballregulator.org.uk/
Download the IFR Corporate governance code: https://www.footballregulator.org.uk/api/downloads/file/Football%20Club%20Corporate%20Governance%20Code.pdf
https://www.wolves1877trust.co.uk/news/molineux-finances-an-overview
https://www.wolves1877trust.co.uk/news/fan-consultation-2026-27
https://www.wolves1877trust.co.uk/news/the-future-of-molineux-must-include-wolves-supporters
https://www.wolves1877trust.co.uk/news/manifesto-for-change
https://swissramble.substack.com/p/wolverhampton-wanderers-finances-04e