Baroness Jones of Moulsecoomb:

Moved by Baroness Jones of Moulsecoomb

12: Clause 6, page 5, line 14, at end insert—“(d) to monitor and promote the reduction of English football’s climate and environmental impacts (referred to in this Act as “the environmental objective”).”Member’s explanatory statementThis amendment would add climate and environment impact reduction to the IFR’s objectives.

My Lords, I will not move Amendment 12 but I will speak to Amendment 13. Is that all right?

You would need to say “not moved” to Amendment 12, but if you speak to it now you can then move it.

Thank you very much.

Amendment 13 is quite an important amendment for me, because a noble Lord challenged me earlier, saying, “Surely you’re not going to bother to push this to a vote; otherwise, it could be in every Bill”. Well, yes, of course: as a Green, I would like an awareness of the Climate Change Act to be inherent in every Bill. Unfortunately, it is not at the moment. That is why this amendment is so important.

I am a football fan. Despite being a Green and despite all its flaws, I absolutely love football. I am well aware of the power that football clubs have over their fan base and their sphere of influence into wider society. We all know now that we have to limit our impact on the planet, that we need to use less plastic and that everything can be polluted by plastic—our own lungs, the sea, absolutely everything. Some clubs are trying very hard, but many, many fail.

Amendment 13 tries in particular to acknowledge the link between environmental and financial sustainability and the urgent need for the games regulator to be empowered to drive greener practices. The idea that the independent football regulator’s remit should include consideration for environmental sustainability is backed by Pledgeball and fellow sport and sustainability organisations Sports for Climate Action and Nature at Loughborough University, the Cool Down Sport for Climate Action Network, and the Football and Climate Change Newsletter.

In 2021, in response to a number of high-profile crises that had arisen in the sport, there was the fan-led review, which has been discussed already, chaired by the former Sports Minister, Tracey Crouch. Many of the review’s 10 findings focused on financial stability at the clubs, fan input, equality, inclusion, diversity and welfare, but it is also crucial that a focus on environmental standards and sustainability is part of the regulator’s remit.

In Committee, Ministers resisted amendments about environmental sustainability on the basis that such measures would put a burden and cost on the regulator and on the clubs. Ministers also argued that voluntary sustainability efforts by clubs and leagues were, and would continue to be, sufficient. However, although some clubs are doing commendable work in this area, progress is inconsistent, erratic and lacks enforcement. Without regulation, football will have fragmented, inadequate responses to climate threats.

It has been predicted that, at the current rate of climate change, one in five English clubs could be at high or very high risk of flooding by 2050. The average grass-roots pitch already loses around five weeks of play every season due to adverse weather. Approximately 120,000 fixtures are called off each year due to unplayable conditions of various kinds.

Additionally, government policy already links financial stability to climate risk. The Bank of England’s Financial Policy Committee is required to consider climate risks in its financial stability assessments. Defra has also asked several major UK regulators, including Ofcom, to submit a report on how climate risks are affecting the sector. Football should be no different.

My Amendment 13 would ensure that clubs comply with the Climate Change Act 2008 to secure the long-term environmental sustainability of English football. I simply feel that this is too important to leave, so I will move it later.

My Lords, my Amendment 25 seeks to address a key issue: how the new regulator will operate in practice and the transparency with which it will exercise its powers. But first, I welcome the Government’s decision to adjust the frequency of the Secretary of State’s statement on football governance from every three years to every five. This sensible change now aligns the timing of various key processes across the Bill, ensuring consistency, clarity and practical efficiency. I thank the Minister for listening to the points raised in Committee and responding positively with her amendment.

On guidance and consultation and my amendment, the Bill currently requires guidance only for discretionary licence conditions, leaving many critical regulatory functions without similar obligations. I want to briefly highlight three key areas where greater clarity is essential and guidance should, in my view, be mandatory.

First, financial sustainability is the regulator’s primary purpose, yet there is no obligation for the regulator to define how it will assess soundness or resilience through guidance. Clubs making long-term investment decisions deserve clarity on how these will be evaluated. Can the Minister please confirm that the regulator will define these incredibly important terms, which influence the overall approach the regulator takes and therefore what regulated parties should expect, in the “state of the game” report?

Secondly, the owners’ and directors’ test—vital for responsible investment—lacks detail in the legislation itself. Without requirements to consult clubs and existing and potential investors on its design, we risk creating unnecessary uncertainty. There is a requirement to consult on the definition of “significant influence or control” within the ownership rules, but no consultation requirements for the test itself.

Thirdly, the backstop power over financial distributions could fundamentally alter football’s economics, yet the regulator need not explain its approach or methodology ahead of a determination. For a mechanism with such profound implications, this seems to represent an obvious gap in procedural and legal safeguards. This uncertainty around guidance could create practical problems. The Premier League’s broadcast deal runs to 2030. Clubs like mine are making infrastructure decisions spanning similar timeframes or even longer.

How can responsible planning occur without regulatory clarity? Surely mandatory guidance across a whole range of areas in this Bill would be conducive to generating greater clarity and regulatory certainty. These amendments would require the regulator to provide guidance across all functions and to consult appropriately. I am not seeking to constrain the regulator’s authority, just to ensure that powers are exercised transparently and coherently. If, as the Minister assures us, this will be a collaborative regulator, I ask her to commit to embedding that principle more comprehensively in the legislation itself.

My Lords, I will speak to Amendment 13, to which I have added my name. I thank the noble Baroness, Lady Jones, for tabling this significant addition to the Bill.

Our national game has a vital role to play in support of the Government’s commitment to reach net zero by 2050, not least because there is a vital connection between the long-term financial sustainability of English football and its long-term environmental sustainability. We know that climate change impacts sport; we therefore need to equip clubs, especially those in the lower leagues, to mitigate the vagaries of extreme weather, whether in the form of droughts or torrential rain. Incorporating a duty to monitor and reduce the climate impacts of English football would only enhance its value to our nation and local communities.

Football clubs have a history of social, cultural and even moral leadership. I celebrate the example of Kick It Out, a campaign established in 1993, under the name Let’s Kick Racism Out of Football, to raise awareness and tackle all forms of discrimination in sport. Given this precedent, I invite noble Lords to imagine the difference it would make in South Yorkshire if Barnsley, Doncaster Rovers, Rotherham United, Sheffield United and Sheffield Wednesday football clubs together led the way in our region to a more climate-friendly future.

Why should English football not be on the front foot, rather than on the back foot, in the journey to net zero? I am tempted to call it an open goal. I commend the amendment.

My Lords, we had a useful debate in Committee on environmental amendments. I was one of those promoting them, but I was much reassured by the Minister’s comments that they were not necessary. I support those comments. This is where I take issue with the noble Baroness, Lady Jones: if, with a bit of research, she looks at the workings of all the other regulators, even the FCA and so on, she will find that all of them publish a commitment to sustainability and acknowledge the role and responsibility they have for ensuring that we meet net-zero targets. These amendments, well-intentioned though they are, do not need to be in the Bill. They are not necessary.

It would be better if we focused on what clubs are currently doing. My own club, Brighton & Hove Albion, has a sustainable transport policy, and most football clubs now commit to such policies. I think we get most of our fans to the grounds by some form of public transport—I am told that it is about 50% or 60%—and most clubs would recognise that as an agreeable target. Legislation is not required to do that; what is required is close working with the local authority and the transport undertakers.

While there is a good intention behind this proposal, I do not think we need to have it in the Bill. Most regulators already subscribe to statements on sustainable practices. While the right reverend Prelate the Bishop of Sheffield made a good point, clubs are already working hard in this area to promote good environmental practice. Although these amendments are well intentioned, I believe that they are unnecessary, and I hope that the noble Baroness, Lady Jones, will not push them.

I will speak very briefly to the other amendments in the group. Ticket pricing is a commercial matter for clubs; they have to work out the best way to ensure that they maximise the number of fans that come through the gates. As I understand it, it is already explicit in the Bill that clubs will consult their fans on ticket pricing as part of their fan engagement. Again, I do not think that it is something that should detain the House; it is something for the clubs to work out, to ensure that they adopt good practice on how they engage with fans in future.

My Lords, I will speak to my Amendment 27—not as a learned lawyer, like the noble Lord, Lord Pannick, who is in his place; not as a former Sports Minister with immense understanding, like the noble Lord, Lord Moynihan; and not as a senior and experienced administrator of a huge club, like the noble Baroness, Lady Brady—but as a humble fan. I have not spoken much on the Bill, but when I have, I have spoken as a lifelong football fan who pays regularly to watch my beloved club, Tottenham Hotspur, for better or worse. I very much sense, feel and hear the varied opinions of fans on the independent football regulator, reflecting a mix of hope, scepticism and concern.

I acknowledge that there is some enthusiasm on the terraces, but it is tempered by doubts about the regulator’s scope and power. Some fans are worried that it will not address their immediate concerns, such as the rising ticket prices, the loss of cup replays or clubs prioritising lucrative overseas pre-season tours over local engagement. Posts on X suggest scepticism about whether the independent football regulator can truly challenge the entrenched power of the Premier League’s wealthy owners. As one user noted:

“It can’t force clubs to lower ticket prices”.

Others fear that it may impose bureaucratic burdens without delivering meaningful change, potentially even threatening the competitiveness of English football. Fans can be quite astute in their analysis and hopes for what a regulator was intended to do, as they now meet the harsh reality of what a regulator might actually do.

This comes at a time when some clubs—dare I use the example of English football’s biggest commercial club, Manchester United—face demonstrations from their fans demanding change. Fans are themselves motivated by a myriad of reasons, and much of their ire has to do with the performance of their team on the pitch. However, one of the issues at the heart of the Manchester United fans’ fury is ticket prices. That was why a specific fan demonstration was organised—following the raising of ticket prices to £66 and the removal of some concessions in December last year—and the issue continues to rumble on. In February, the Fulham Supporters’ Trust described the decision to sell adult away tickets for the Old Trafford cup tie at between £51 and £61 as “callous”, with away tickets capped at £30 for Premier League matches.

I do not want to be accused of picking on Manchester United, especially as it is having as poor a season as my own club, where the natives are also extremely restless, as the noble Lord, Lord Maude, knows. Again, that is for many footballing reasons, but also because of the restriction on ticket concessions that was announced this season. The same can be said of a number of other Premier League clubs, where ticket prices are going only one way and potentially acting as a barrier to many fans experiencing the beautiful, great game at a ground.

It must be acknowledged that clubs, especially Premier League clubs, are facing challenges. Clubs generate huge revenues, but, equally, they have huge outgoings and are continually chasing footballing talent and investing to achieve success in a highly competitive international market. They also face national financial pressures, such as the impact of the Labour Government’s national insurance increases on their employee base; the Labour Government’s increase of the national minimum wage; the further compliance costs that will accompany the Labour Government’s new Employment Rights Bill; and then the independent football regulator’s levy. We can debate the impact of the IFR on the footballing pyramid, but a question I share with millions of football fans is: will all these additional costs and that of the IFR on EPL clubs, and every single club in the land, mean that ticket prices will go up?

Rather than meeting the aspiration of helping fans to reduce ticket prices, the cost of the independent financial regulator is likely to do the exact opposite. Therefore, I have sought to make a modest amendment to Clause 14: that the IFR’s annual report include

“a review of the impact of the activity of the IFR on ticket prices”,

to give us fans some comfort that the burden of the independent football regulator will not fall on us.

My Lords, I am conscious that the debates on this Bill have been somewhat lengthy, so I will be incredibly brief. I support, with absolute delight, the noble Baroness, Lady Jones of Moulsecoomb, on her Amendment 13. I do so for three reasons.

The first relates to the oft overused phrase “soft power”. No one can deny football’s huge following or the impression it has on so many—and that applies equally to fans in this country and abroad. As has been said already, the Premier League makes up the largest share of the UK’s television exports, and football is broadcast to over 1.5 billion people in just shy of 190 countries. As noble Lords have noted, throughout the ages football has pushed and campaigned on many important issues, so it is right that the many things that clubs promote at home and abroad should include the environment, nature and broader sustainability.

That leads me to my second point, which is, in effect, football’s hard power. Clubs can make a difference through not just all the sites they own but what they offer during matches to the fans.

My third point is broader: I wish to speak to those who cannot support this amendment, however well intentioned it is, because they do not support the idea of a regulator. The debate we are having now is about this amendment; it is not about the Bill in its entirety. Whether we agree with it or not, the Bill will end up passing. So the question to me now is not about the virtue of the regulator but about how we can improve it.

To conclude, this amendment does not have specific targets or rules on what exactly clubs should fund or what their boards should look like, or seeks to interfere needlessly in how they are run or how their games are played. The key is that this amendment calls for regard of what is already in other legislation. It is something that we are all expected to do ourselves and, as has been said, that so many clubs do already under their own steam: to play their part. If the noble Baroness presses her amendment to a vote, I respectfully urge all noble Lords to support her.

My Lords, I will speak briefly in support of my noble friend Lord Ranger of Northwood, as well as my noble friend Lord Maude’s earlier point about the individual who will become the regulator. While we are discussing Manchester United, I note that I am a season ticket holder of the club; my noble friend Lord Ranger made a point about the recent increase in ticket prices.

This regulator will be answerable to supporters, while at the same time—as my noble friend Lady Brady said—making it clear what the owners of the football clubs can expect for investment purposes. This independent football regulator will be located in Manchester. Given the sheer size and scale of the protests—75,000 people go to Old Trafford week in, week out, and they may be minded to go to the location of the regulator— I would be interested to know what calibre of person, he or she, will be able to cope with those protests, which will inevitably end up outside their premises. How will they interact with those supporters, while at the same time making sure that they act professionally and responsibly so that the owners of the football businesses can carry on with the investment that we all want? Ultimately, this is about the future success of the Premier League.

My Lords, I welcome government Amendment 24, which reduces the minimum frequency of the revised football governance statements from every three years to every five years. That is a positive direction of travel, reining in a disproportionately burdensome bureaucracy. I was fearful that clubs might be in a perpetual state of having to fulfil the paperwork rather than improve governance, let alone improve football. I am glad to see that amendment.

Another worry that some of us have raised is the need to rein in politicised mission creep, so I oppose Amendments 12 and 13. Amendment 13 seems to be the focus, linking this Bill to the Climate Change Act and linking environmental sustainability to economic sustainability and making climate and environmental impact reduction part of the IFR’s objectives. I think this is incredibly unwise for a number of reasons. It goes against the Government’s Amendment 14, debated earlier, which all sides of the House lauded and I agree with, which is a commitment to avoid any adverse effects on the financial growth of English football.

Let us be honest: outside of football, even the Government are now acknowledging that net-zero targets and environmental regulations are often expensive and burdensome barriers to economic growth. They do not allow the Government and whole swathes of the corporate world to pursue, for example, infrastructure projects such as building houses. I do not think that it is uncontentious to say that, because “environmental sustainability” and “economic sustainability” will appear in the same provision, there is no tension between them; I think there is. I also think that this would really be an example of scope creep, which the Minister has assured us will not happen; UEFA and FIFA have been promised that it will not happen, as we were told earlier.

In Committee, I spoke against adding football clubs into this ever-greater, non-football-related political territory, setting essentially politically driven environmental hoops to jump through. In Committee, the Minister assured us that the Government had no intention of accepting these Green demands into the legislation, and I was reassured. But I want the Minister to promise, if she can, that the independent regulator will not—once this Bill is passed, which undoubtedly it will be—simply slip them into the governance remit. I am worried because the green lobby is very active, persistent and wealthy and, to be honest, has an interest in pursuing this after this Bill is long gone.

Larger clubs with lots of money might well be able to go along with a lot of these things that this Bill demands. We know that there are all sorts of Premier League football clubs at the moment that are more than happy to have sponsorship by green energy companies and so on. We have seen a lot of that happen. I think this could amount to eco-virtue signalling that ticks the social responsibility boxes of the big clubs and a sort of greenwashing that we know the corporate social responsibility industry does so well. But I fear that it will distract smaller clubs from their core role of thinking about financial stability and improving their governance so that we have better football clubs, and it will drag them into this extraneous environmental sustainability world.

As we heard from the noble Lord, Lord Ranger of Northwood, when you talk to fans about this Bill—and I am rather sceptical of many elements of it—they say, “I really want this Bill because I am determined that we are going to have ticket prices brought down”. That is the main thing they say. They say that they do not want any of this “nonsense”—maybe not the word used—around EDI or net zero and all that sort of stuff. As one of them said, “I want ticket price cuts, not bloody carbon cuts”. I thought that they had a point. As the Minister is very keen that we should be led by the fans on this, I suggest that we reject these amendments, because I can assure noble Lords that, in the fans’ priorities, it is not top; in fact, it is not relevant at all.

My Lords, many clubs do what they can to promote the environment, and that is all well and good and I totally support it; what I do not support is Amendment 13 from the noble Baroness, Lady Jones. What the noble Baroness is seeking to do is to impose on the IFR a duty to exercise its functions in a way that is compatible with the Climate Change Act. If the Climate Change Act already imposes duties on everybody including the IFR, this is otiose and unnecessary; if the Climate Change Act does not impose duties in any event on the IFR, I am very doubtful indeed that it is appropriate to use this legislation, which is concerned with many other topics, to impose such a duty. In my view, it is not necessary to put this in the Bill.

My Lords, I will support the amendment from the noble Baroness, Lady Jones. The noble Lord, Lord Pannick, makes a substantial point about why in law it probably will not really help, but in spirit I am with it.

More importantly, the noble Lord, Lord Ranger, made an important point about fans not being able to afford to watch football. I have been amazed for a long time, probably about 20 years, that working people in particular, with perhaps two children, might visit two games a week. I do not know how they afford it. It has always been, generally, a working person’s game—it is not a class issue, but I think, generally speaking, it has been—and it has inelastic demand. By that, I mean that it is a tribal thing: we cannot explain the reason that we get excited and depressed about football teams. I am hoping that Sheffield Wednesday will win tonight; I will be depressed, I will be—

Amazed.

Not surprised when that does not happen.

There is something within us that is very hard. The most obvious thing a football fan could do would be to stop going to the games to effect change in a club, but it is very hard for them to do so. Therefore, a regulator asking reasonable questions of a club about why it has increased ticket prices is a very sensible option. If it is there to check on the validity and, I suppose, the due diligence around the ownership, I would have thought that this is the very least it could do in looking around the due diligence and looking after the fans.

No one else really looks after the fans. Outside the Premier League, the quality of looking after the fans is pretty awful. From the toilets to the restaurants—if they ever pass as that—it has traditionally been pretty diabolical. I would have thought that the regulator ought to be looking at such things, as well as whether the money going into the club is straightforward and comes from the sources that are alleged. I will certainly support the ticket price amendment, should it be put.

My Lords, having listened to this debate, I have discovered that I have no original points to make. I discovered, having had a quick discussion with the noble Lord, Lord Pannick, that if it is in law anyway, it is law. On enforcement capacity, probably the earlier amendment of the two was better or more relevant, but we have already said that it is out of scope following Committee.

When it comes to ticket pricing, it will be interesting to hear what the Government think will be done, or what is within the capacity of the regulator, to at least justify ticket price increases. There is enormous pressure for prices to go up, but you also have a duty to your community. I look forward to hearing what the Minister has to say on this. I will base any reaction on the Minister’s response.

My Lords, I thank the Minister for the two government amendments in this group. They reflect amendments I tabled in Committee. The first reduces the frequency with which the Secretary of State may revise the football governance statements, bringing it more in line with the parliamentary cycle rather than every three years. The second removes the Secretary of State’s power to amend the definition of the football season. This always seemed a disproportionate power. Why a Cabinet Minister ought to define a football season is a point that has bemused many football fans. I am grateful to the noble Baroness for Amendments 24 and 87, which she has brought forward on those points.

Like other noble Lords, I applaud my noble friend Lord Ranger of Northwood for his passionate speech in favour of his Amendment 27, which seeks to require the regulator’s annual report to include a review of the impact of its activities on ticket prices. The important argument here is not that the regulator should dictate ticket prices to clubs. I recognise the point that the noble Lord, Lord Hogan-Howe, made about how clubs often try the patience of their fans, but it is a commercial decision for clubs to take. There is a distinct possibility that the activities of the new regulator may force clubs to increase ticket prices further.

This is different from the point that the noble Lord, Lord Bassam of Brighton, made in pointing to the duty already in the Bill. The regulator will charge a levy to clubs. It will bring in higher compliance and legal costs, and many clubs will have to hire extra staff to comply with the new legal duties. That is all acknowledged in the Government’s impact assessment. When we couple that with the Government’s job tax, the increase in the minimum wage and the impending duties in the Employment Rights Bill, we can see that football clubs will be facing significant cost pressures over the coming years.

Inevitably, the only solution for many clubs—here I am thinking not predominantly about Premier League or Championship clubs but about clubs in League Two and the National League, which are the smaller and less well-off clubs—will be to hike ticket prices to offset these new and increased costs. It is clear that we need this assessment of the impact of the regulator’s actions on ticket prices. If Parliament is to give its assent and create this regulator, I think it owes it to fans to make sure that the impact of that cost is properly accounted for.

The noble Baroness, Lady Fox, my noble friend Lord Ranger and others have reflected on the fact that fans have very high expectations of this Bill and this regulator. They hope that the Bill, including the provisions in Schedule 4, will allow them to benefit from lower ticket prices, but I fear that the reverse is likely to be the case—higher costs leading to higher ticket prices for fans. I hope that my noble friend Lord Ranger will pursue his point on behalf of football fans across the country.

I am pleased that my noble friend Lady Brady has retabled her very sensible amendments to ensure that the regulator publishes guidance, not just to its functions under Clauses 21 to 25 but to its functions under the whole Bill. The regulator needs to translate the somewhat abstract powers and duties set out in the Bill into a more detailed and cohesive explanation of the rules it will be producing to support clubs in understanding precisely what will be expected of them. If it does that clearly, that may go some way to mitigating the costs that the new regulatory regime will impose on them. My noble friend’s Amendment 25 is a very simple one, but its impact would be helpful to all clubs facing these new regulations.

To the noble Baroness, Lady Jones of Moulsecoomb, the right reverend Prelate the Bishop of Sheffield and my noble friend Lord Gascoigne, I must regretfully say that I cannot support them on the amendment they have spoken passionately about. As I set out in Committee, we worry about the propensity for mission creep here. They have very wisely chosen to put their initiative behind Amendment 13, which is the more modest of the two and reflects an Act of Parliament that has already been passed with duties under it. While we cannot support the noble Baroness’s Amendment 13, neither will we oppose it if she presses it to a vote.

With renewed thanks to the Minister for the government amendments in this group, I look forward to her response.

I am not sure I have many original thoughts either, although I will try to address the points raised during the debate, starting with Amendments 12 and 13 in the name of the noble Baroness, Lady Jones of Moulsecoomb. I thank her for these amendments.

I am really comfortable with her absolute determination—as is her right—to raise environmental issues in every single way at every point of our deliberations in your Lordships’ House. The noble Baroness is right that we need to limit our impact. I note that she has support from the noble Lords, Lord Hogan-Howe and Lord Gascoigne, demonstrating her incredible ability to forge unlikely—some might say unholy—alliances with very noble aims. I apologise to the right reverend Prelate; I am not referring to him in that sweeping statement.

The Government are absolutely committed to environmental sustainability. One of the Prime Minister’s five national missions is to accelerate the transition towards clean energy and ensure that the UK fulfils its legal obligation to reach net-zero emissions by 2050. I agree with the noble Baroness, Lady Jones, and other speakers, including the right reverend Prelate the Bishop of Sheffield, that as a huge part of our national psyche, all sports, including football, have an important role to play in this transition.

The Government expect authorities across the sport to be working together to advance environmental sustainability. However, we do not feel it is right to add environmental sustainability to the regulator’s objectives or general duties. The bar for statutory intervention in any market should be very high. That is why the regulator’s focus should be on the problems that football has clearly shown itself to be unable to properly address through self-regulation.

By contrast, football has demonstrated the ability to take action on the environment. You only have to look at Forest Green Rovers as a brilliant example of a club taking action on environmental issues lower down the pyramid. At the highest level, the Premier League’s new sustainability pledge, involving a new minimum standard of action on environmental issues across both the clubs and the league, is another good example. This is only a starting point upon which future initiatives must build. Football authorities must take more proactive steps to accelerate their environmental initiatives. However, it is within the gift of the leagues, clubs and other authorities across the game to do so without government intervention.

This Amendment would also constitute scope creep, as highlighted by the noble Baroness, Lady Fox—something that I know noble Lords all agree we should be wary of, not least with the additional burdens it would impose on the regulator and the industry. Therefore, I hope the noble Baroness will not press these amendments.

Amendment 25 in the name of the noble Baroness, Lady Brady, seeks to bind the regulator to produce guidance on every aspect of its functions. In our view, this is disproportionate and would be a significant burden on the regulator. We are not aware of a precedent for any regulator being required to publish guidance about every single aspect of its functions. In many cases, it would be unnecessary and not relevant to clubs or competition organisers. This would involve engagement and consultation with clubs, adding significant burdens to them. The regulator will, where necessary, produce guidance in consultation with relevant stake- holders, in line with its duties and principles. I therefore hope the noble Baroness will feel sufficiently reassured to not move her amendment.

On Amendment 27 in the name of the noble Lord, Lord Ranger of Northwood, regarding ticket prices, the annual report is clearly a vital mechanism for the regulator to be held to account. I understand the desire to ensure that this report is comprehensive and covers necessary detail. It was really helpful to have his explanation of the intent of his amendment. I recognise how important ticket prices are to fans and recognise the noble Lord’s determination to raise this important issue on behalf of fans.

Ticket pricing is ultimately a matter for clubs. That is exactly why this Government have made it explicit in the Bill that clubs must consult their fans on ticket pricing as part of their fan engagement. This is the way to ensure that fans can have their voices heard on such an impactful issue; the annual report is not the most effective place to achieve this. The regulator may well choose to look at ticket pricing as part of the “state of the game” report. However, as it is a commercial decision, the regulator will not intervene, aside from ensuring that clubs consult their fans.

My understanding from the noble Lord’s contribution is that the cost of the regulation itself may cause clubs to increase prices. That was not our reading of the amendment before the debate, so I will address that point specifically. To reassure the noble Lord, if clubs increase ticket prices, we do not believe it would be a proportionate or necessary reaction to the cost of the regulator; this is something that officials have looked at. I have also written to the noble Lord, Lord Hayward, about the costs that might be incurred by clubs as a result of the regulator, and I have asked for a copy of this letter to be placed in the Library. I hope that will give a little reassurance to the noble Lord, and others, that we think the cost of the regulation will be proportionate and should not have an unnecessary impact on fans.

I turn to the Government’s amendments in this group. Amendment 24 changes the minimum frequency of revised football governance statements from every three years to every five years. I thank all noble Lords who spoke to me, officials and other Ministers about this point. The discussion on this issue in Committee was a good one, and the Government have listened to the concern over undue political influence and short-term steers that a statement every three years might generate. We are all aligned on the need for a regulator to be independent; therefore, we have changed the timing of revisions of the football governance statement from every three years to every five years.

I thank the noble Lords, Lord Moynihan, Lord Markham and Lord Parkinson of Whitley Bay, as well as the members of the Delegated Powers and Regulatory Reform Committee, for their engagement on Clause 92. The original intention of this was to allow the regulator’s regime to keep pace with any future changes to the structure and definition of seasons in the industry. However, we have recognised the concerns regarding the delegated power and are content that the risk of the definition in the Bill becoming outdated is low. That is why we have tabled an amendment removing this delegated power. I hope this will satisfy noble Lords’ concerns on these issues. I commend Amendments 24 and 87.

I thank all noble Lords who have spoken in the debate, particularly my co-signees: the very holy right reverend Prelate the Bishop of Sheffield and the very brave—and possibly slightly less holy—noble Lord, Lord Gascoigne. Their speeches were short, powerful and to the point, which I think the whole House appreciated.

I say to the noble Lord, Lord Bassam, that calling my amendment well intentioned was probably the nicest thing he has ever said about a Green Party person, so I am going to bank that. However, he is completely wrong, because acknowledging a commitment—which is what he said various organisations do—is not the same as actually doing it. So I would argue that this amendment is absolutely relevant. Subscribing to statements—which was another phrase the noble Lord used—does not mean doing it; I want clubs to do it. Therefore, the noble Lord, Lord Pannick, is totally wrong; this is not otiose or unnecessary. In fact, we added this very provision to the Water (Special Measures) Act 2025—in Section 10. If it was relevant then, it is relevant now.

The noble Lord, Lord Parkinson, was very kind in saying that the Opposition would not oppose this amendment. I am touched by the Opposition’s kindness towards me. Turning to the noble Lord, Lord Addington, I was told that the Liberal Democrats are abstaining on this, which I found quite shocking. That seems an abnegation of their concern about this issue, and I am very disappointed.

The Minister offered such kind words about my amendment, even though she said no. When she said that this Government have a complete commitment to environmental obligations, I know she was incredibly sincere. However, our views on how the Government are dealing with the environment probably differ slightly. I realise that is partly because I could be called a rabid green—I want green stuff in absolutely everything—but at the same time I think I am right, and the Government are wrong. My amendment would make it easier for clubs to do the right thing for their fans and for wider society. So we need this amendment in the Bill.

What does the noble Baroness wish to do with Amendment 12?

Not moved.

The amendment was moved. Does the noble Baroness wish to withdraw it?

Noble Lords:

Withdraw.

Yes, withdraw.

Amendment 12 withdrawn.

Clause 7: The IFR’s general duties etc