Football Governance Bill: what does good fan engagement really look like?

LCP’s Sports Advisory practice has recently made two appointments – the recruitment of Aaryaman Banerji as Head of Football Governance, and David Millar as Head of Fan Engagement alongside his existing role as Head of Communications at LCP.

These changes provide additional focus in two key areas facing professional sport, and support our aim to provide a full range of professional, regulatory and compliance support to football clubs dealing with the requirements of the Football Governance Bill, currently progressing through Parliament.

In this first blog, David looks at the role communication plays in effective fan engagement and what the new regulations are likely to mean for clubs under the supervision of the new Independent Football Regulator.

For most of my professional life I’ve been focused on creating comms that aim to deliver the holy grail of ‘engagement’. Whether it is pension scheme Trustees encouraging members to save for the future, HR teams launching new benefits to employees, or executives instigating corporate change, what starts as a proposition ends with someone realising that the great idea agreed in the boardroom will only come to life with the right communication strategy. 

So, I’ve been following the growing conversation about ‘fan engagement’ in the world of professional football with interest, given it’s a government initiative that connects a personal interest (football – and in particular the fortunes of Norwich City) and my professional interest (the challenge of delivering engagement via communication). 
 
The Football Governance Bill as currently drafted covers many aspects of football club governance; among them there are requirements for clubs to engage with fans over certain aspects of running the club, namely: 

• The club’s strategic direction and objectives 
• The club’s business priorities 
• Operational and match-day issues, including ticket pricing 
• The club’s heritage, such as crest and name, and home ground 
• The club’s plans relating to additional fan engagement 

Furthermore, clubs will be required to consult regularly with specific fan representatives, either elected by the club’s fans to represent their views, or otherwise in some other way satisfying the Independent Football Regulator that they can do so.  

What will this mean in practice for clubs in both complying with the fan engagement regulatory requirements, and doing so in a way that genuinely engages with their fans in a positive way? There are three key areas to consider. 

1. Establishing an effective framework for fan engagement 

Engagement is something that happens in the minds of an audience, not in the content of the communication. Understanding who your audience are is a key part of the process – without that knowledge, you cannot establish what channels will be effective, what tone of voice will work best, what level of information to provide and with what frequency. While some clubs remain rooted in their location and a largely stadium-based audience, others have evolved into marketing machines and multi-billion-pound businesses. As football brands have grown, so has the global reach of the game and the location of the fan-base (increasingly via screens). Establishing true engagement means understanding the different groups who make up the audience, and this will be very different for Tottenham Hotspur and Manchester City compared to the likes of Gillingham and Darlington. A one-size-fits-all approach won’t work, and while the clubs with more significant resource pools may have in-house teams able to do this, not all clubs will have the capacity to really understand their fan base other than in the simplest terms. 

To an extent the Bill provides a solution, as the Regulator can recognise that the fan engagement threshold is met by the club engaging with representative groups. But how do you (and the Regulator) know whether that group represents the fans as a whole? It moves the problem, but the need to understand the audience doesn’t go away. There is an opportunity here for clubs to understand their audience better, and a regulatory need to think about this in a way that perhaps hasn’t been necessary in the past. 

2. Fan engagement in strategic decision-making 

The Bill seeks to set a minimum standard of fan engagement by requiring that a club “takes the views of its fans into account in making decisions”, in the five areas listed above. The comms challenge here is less about trying to engage fans with these topics (because most will find them interesting and relevant) but more about ensuring the fans have the right level of information and understanding to participate meaningfully in the process.  

Yes, fans will have an opinion, but most won’t have access to data about the club to support their view on, for example, ticket prices. If engagement is to be meaningful, clubs will need to establish a reporting framework which provides the right level of information to educate fans and fan groups to help them to understand the realities and potentially conflicting priorities of running a football club in a highly competitive financial and sporting environment (as laid out clearly in LCP’s recent report on the financial sustainability of clubs). And this will require that clubs open up to a level of transparency that is not common in an industry that has often been run based on the support of local benefactors, rich overseas owners, or more recently opaque investment vehicles.  

Research carried out by Dr Mark Middling of Northumbria University shows that a consistent reporting framework covering finance, governance, sporting matters and social factors is an essential element of effective and positive communication with fans. His research has included developing a well-structured and comprehensive template fan reporting framework, which has already been adopted to good effect by one League One side, Exeter City, for its recent Annual Supporter Report. The template sets a baseline for the provision of clear information to fans, the type of which is common in many regulated sectors (pension schemes, charities, academy trusts) but truly ground-breaking in football.  

The new Regulator will surely seek to establish such a framework and will hopefully borrow from existing best practice when it comes to content. There is a real risk here that without a strong framework, the opportunity for meaningful engagement will become an exercise in paying lip-service to the minimum regulatory requirements instead. 

There is, of course, a real incentive for clubs to do this right – greater engagement with an audience means greater propensity for fans to engage financially, purchasing merchandise and coming to events, and more people passing on the joy of participation to future generations. But to be clear, while meaningful engagement may result in financial uplift, it shouldn’t be the central purpose if it is to be genuine, authentic, and successful. 

3. Consulting on changes to football club heritage 

‘Consultation’ is a word that hides different communication challenges, and none more so than the requirements relating to a club’s heritage. Under the Bill, a change to club crest, home shirt colours, or name cannot be approved by the Regulator “unless the club has taken reasonable steps to establish that the changes are supported by a majority of the club’s fans in England and Wales”. This is quite a different threshold to the ordinary meaning of ‘consultation’, which requires clear communication of a proposal and its implications but not the approval by those affected. 

We will have to wait and see how the Regulator decides what is meant by ‘reasonable steps’ and ‘support by a majority of the club’s fans’ – but it’s unlikely that a notice in a local paper and the agreement of a single fan forum would be sufficient. Where similar requirements exist in other sectors a vote is often used as the evidence of ‘a majority’, but I can’t be the only person considering that prospect challenging when it comes to football club fans – for a start, how do you establish which of your fans can vote? And how do you stop your local rivals from voting? In its current form, the legislation all but prevents significant changes to club crests and names (which may be the purpose) - though interestingly I note that (as the Bill stands) moving grounds requires a different and arguably less challenging approval from the Regulator (rather than fans). 

Any audience engagement has its unique challenges depending on the specific characteristics of the audience and, although most membership organisations have wrestled with this topic for many years, the challenges presented for football are different to most – a highly engaged audience (but only in a limited aspect of the club) and an audience that is difficult to tightly define and quantify. 

It’s going to be a fascinating time for football communications, and at LCP we’re looking forward to helping clubs find their way in this new regulated environment, which we believe is for the long-term good of the game, and to the benefit of fans.  We believe there’s a lot here that can be learned from the successes and failures of other regulators, including in the pensions industry that we know well at LCP, as outlined in our recent blog. 

And I would conclude by highlighting three areas that clubs really need to think about: defining their audience; understanding exactly how the consultation processes will take place and to what extent; and, perhaps most importantly, how these processes can be leveraged further as an opportunity to learn more about their fanbase, and engage with them more deeply.