The White Paper on Football Governance
The case for the Football Regulator to have a role on environmental sustainability
The plans for a football regulator in England deal with important and deep-seated issues for the game's future. The news that they have taken another step forward are to be strongly welcomed. But one critical challenge has been overlooked so far: climate change.
More and urgent action in football is needed and has support
The latest IPCC report makes clear that the pace and scale of climate action is insufficient and accelerated action is needed. To tackle its emissions, football needs to rethink and innovate how it operates in relation to travel, tournaments, scheduling, energy use, merchandise and more. Alongside this, with extreme weather being the new norm, football needs to adapt to changing climate conditions and how these affect players, fixtures, and infrastructure.
As the Government’s new Sports Strategy says, football has a unique global reach and cultural platform to lead from the front on net zero and influence, instigate, and inspire change by others, but a lot more work is needed in all sports to turn talk on reducing environmental impact into more action.
In a report last year, Deloitte said that they “hope that great swathes of signatories from within football” will sign up the United Nations ‘Race to Zero’ for sport. At present only six Premier League clubs have so far made a net-zero commitment1. In addition, only four clubs in the league have measured their full carbon footprint, albeit using very different methods. Some clubs are taking more action than others, though Sport Positive, who have produced matrices of action by clubs in different leagues “underline there is still much to do in many areas”.
While fans are increasingly doing their bit, they too want more progress. A recent Capgemini survey says 67% of fans feel disappointed that the teams they follow are insufficiently prioritising environmental sustainability. The Football Supporters’ Association 2023 Survey shows that only a quarter agreed their club was doing enough to cut down on the climate change impact of their activities.
Without more urgent action football is at a high and growing risk of not making its contribution to climate goals. But key barriers are limiting progress.
Fundamental barriers are holding back action
The White Paper on Reforming Football Governance was developed with a “tightly defined scope” focusing on football’s financial sustainability. Nevertheless, the three fundamental problems it identifies apply equally to environmental sustainability and clearly link to financial sustainability. Looking at each of these in turn shows why the regulator has a role to play on this front too, proportionate to the size of clubs.
Firstly, there are perverse incentives in the game where a focus on short-term goals can mean placing insufficient weight on long-term consequences. Take, for instance, Premier League clubs pre-season tours. As one example, Spurs (who have made progress on climate issues in some areas) flew to Australia for one match, before heading to Bangkok for another, which was cancelled due to heavy rain, and then to Singapore for one more. On domestic flights by clubs, research by the BBC has highlighted its extent, the reasons clubs give for it, and the negative environmental impacts.
Also, decisions on the number, location and timing of games can also push fans into more travel, or into using less environmentally friendly travel options. For instance, fans in the North of England may have to travel to London to play their nearby rivals in a cup game that could be hosted closer to them. Or a game being scheduled for the evening for TV may mean fans have to drive to a game as no trains are available after the final whistle. These are just a few examples of the many issues raised by campaigners which point to a market failure in the current approach to the environment in football.
Secondly, the White Paper identified an issue with poor governance. Good governance can help clubs deliver the appropriate climate strategy, delivery plans, and resource allocation.
At present there is a lack of transparency, and often a seeming absence, on environmental governance within football clubs and authorities. This includes on leadership, oversight, and decision-making processes. Who leads on sustainability at Board level in the club you support? How are decisions made?
Issues with data and information as part of good governance are particularly notable too, for instance when it comes to the Streamlined Energy and Carbon Reporting which all large businesses provide in their annual accounts. In football, these rules primarily applies to Premier League clubs and a handful of Scottish Premiership and Championship clubs.
A look at these and other publicly available information from clubs shows that they are not reporting in a standard format and information of action varies hugely in detail. Reporting appears to be a ‘tick-box’ exercise for many rather than an essential part of assessing progress and informing strategic decisions. This also means we are left to compare apples and pears and have no idea how big the overall scale of the challenge is in football.
Elsewhere, the Government’s Mobilising Green Investment Strategy sets out how financial and environmental sustainability are intertwined including the many activities that other UK financial regulators play in regard to the environment. It also sets out further tools and rules that are in the pipeline to support climate action by businesses which clubs will also need to take on board.
This highlights the evolving landscape of climate governance and reporting. Alongside this, the unique challenges in measuring emissions in football underline the benefit an independent regulator could bring on these issues - including enabling smaller clubs with less capacity for action.
Thirdly, the White Paper pointed out a problem of defective industry self-regulation. This is also the case with environmental issues, as demonstrated by the lack of progress on strategies from clubs and governing bodies.
We are yet to see a sustainability strategy for the Premier League or the EFL. The recently published FA Sustainability Strategy lacks detail on many key points. For instance, it provides no clarity on what the FA’s full carbon footprint currently is, what the newly announced funding will go towards (apart from Wembley), or how it will address further extreme weather. Elsewhere, the FA told Parliament earlier this year that “something like 120,000 games a season [are] cancelled because the pitches are not playable”. With climate change making severe weather more frequent, what action is needed to ensure pitches and grounds are resilient, how much will this cost, and how will it affect smaller clubs in particular?
In both Germany and France, football authorities are moving forward in embedding environmental sustainability criteria in their licensing systems. Spain and Italy have strategies covering all their top leagues. In England, there has not been any public mention of collaboration to date between the FA, Premier League and EFL on environmental issues, or any plans to do so. The slow progress of discussions between these bodies on football funding does not inspire hope that they will move at pace together as needed in response to climate change.
The role of the regulator
The challenges set out above show the regulator could help overcome barriers that would not happen without it. Its primary purpose is expected to be to ensure football's sustainability and resilience. To do so it will operate a licensing system with conditions clubs must meet. This is expected to include having “the appropriate financial and non-financial resources and controls in place”. This should include in relation to environmental issues too.
What might its environmental work look like in practice? It could include, for instance, incorporating environmental factors in the proposed ‘Football Club Corporate Governance Code’ which clubs will need to report against and/or be part of the threshold conditions clubs need to meet. Environmental issues could be part of the regular ‘State of Football’ studies the regulator will undertake. It could also “disseminate guidance, and share best practice in an effort to maintain and improve standards” as it already plans to do on other fronts. And it could draw on the plans for a collaborative and escalating approach to intervention when environmental progress is not being met.
There will be plenty of other perspectives on where its focus would best be and there should be consultation to ensure the full range of views is taken into account. It could be informed by a Government-commissioned research report to objectively assess the environmental progress of English football, similar to the research on financial health that has just reported. Alternatively, a full Independent Review could be commissioned.
Does this need to be legislated for as part of the regulator plans? Or could it simply be for the football regulator, when it is up and running, to then look at these issues? Fair Game, who are seeking to improve the governance of football, has called the omission of environmental and equality standards in the plans short-sighted. This follows a number of organisations that came together to argue for the inclusion of environmental responsibilities in the regulator.
In response to a question from Siobahn Baillie MP in Parliament, the Minister for Sport seemed to rule out a role for the regulator on this front saying “The independent regulator will primarily be focused on financial stability, but I assure her that, whenever I have opportunities to raise issues such as sustainability, I always do so”. Nevertheless, this statement in White Paper, albeit in a different context, applies equally to environmental sustainability …
“Any option that does not involve legislation would be a continuation of industry self-regulation. This would mean the same incentives, governance structures, and lack of independence that have led to poor regulation in the industry to date, with no guarantees that reform would not just be reversed down the line.”
The problems are clear and action is urgent. Without further commitments now, football's climate action could be held back unnecessarily. There’s broad support for the football regulator, widespread public concern about climate change and support from fans for more climate action. The Government has said it “will continue to engage in the coming months”. There’s still time to show support for the regulator working with the football community to do its bit on climate change too.
Fran James
with thanks to those who commented on this in draft
Fran James is the founder of The Football and Climate Change Newsletter. It provides reports on how climate change impacts football and how football impacts climate change.
Arsenal, Liverpool, Newcastle, Spurs and Wolves are Sports for Climate Action signatories on the Race to Zero which includes a target “to reduce GHG emissions by 50% by 2030 at the latest” and a “long term target to reach net zero GHG emissions by 2040”. Manchester City have set out plans for “a credible net zero by 2030” here.