FCA warns football clubs over sponsorship deals with unauthorised financial firms — 5 key steps to take now

Football clubs are facing heightened scrutiny over their commercial partnerships, with the Financial Conduct Authority (FCA) warning against deals with unauthorised financial firms. 

The warning comes as clubs look beyond gambling sponsorship and towards new commercial opportunities in the financial and crypto sectors where regulatory compliance and due diligence are under increasing attention.

Here, Lauren Hicks from our sports sector team explores the FCA’s concerns, risks for clubs and steps that they should take to stay compliant.

Why is the FCA warning football clubs?

Back in February, we reported on the Government’s plans to consult on banning unlicensed gambling operators from sponsoring British sports teams. Now, the FCA has written directly to football clubs to raise concerns about partnerships with unauthorised financial firms that may be breaching UK financial services laws by providing or promoting financial products without authorisation. This includes unauthorised firms operating cryptocurrency exchanges or trading platforms.

With the Premier League ban on front-of-shirt gambling sponsorships coming into effect at the end of the 2025/26 season, many clubs are exploring alternative sponsorship opportunities, including in the financial and crypto sectors. However, clubs must tread carefully when engaging with firms in the financial sector, as high standards of due diligence and compliance are expected.

What are the risks of sponsorships with unauthorised firms?

While football clubs aren’t regulated by the FCA, sponsorship deals give unauthorised firms exposure to UK consumers. This visibility can inadvertently confer legitimacy to unregulated operators and increase the risk of consumers buying harmful financial products. The FCA has stated that unauthorised firms appear to be providing regulated services without authorisation (in breach of section 19 Financial Services Markets Act 2000 (FSMA) and making unauthorised financial promotions (in breach of section 21 FSMA). Clubs may also be in breach of the Proceeds of Crime Act 2002 (POCA) as funds received from an unauthorised firm may constitute criminal property under POCA.

Five key steps that football clubs should take now

The FCA expects clubs to act responsibly by conducting robust compliance checks before entering into sponsorship deals. 

The FCA’s recommended steps include:

1. Understanding the sponsoring firm: Confirm whether the firm is authorised or registered with the FCA — or is relying on a valid exemption — and assess whether its products or services constitute regulated activities under UK law.
2. Due diligence: Verify whether the sponsor is authorised by using the FCA Firm Checker and review the FCA Warning List for firms suspected of operating without proper permissions.
3. Enhanced monitoring: Where a firm appears on the FCA Warning List, the FCA expects clubs to carry out enhanced due diligence to consider whether the arrangement should continue.
4. Consumer protection measures: Put in place controls such as geo‑blocking, disclaimers, onboarding checks and monitoring controls to limit UK consumers’ access to any unauthorised services.
5. Independent review: Where appropriate, seek specialist legal advice to confirm the firm’s regulatory position.

Key legislative developments: FSMA & cryptoassets

In February 2026, the Government passed the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, bringing cryptoassets within the FCA’s regulatory remit. This new regime is scheduled to take effect on 25 October 2027, marking a significant expansion of FCA oversight. Clubs should be aware of this new regime if entering into long-term sponsorship arrangements with a crypto firm, particularly where arrangements involve the promotion of cryptoasset services or other activities that may fall within the regulatory perimeter.

Collaborative regulation 

The FCA isn’t acting in isolation. It continues to work with the Government and external partners — including the Premier League and Independent Football Regulator (IFR) — to address these issues across football. Notably, the FCA has recently signed a memorandum of understanding with the IFR, setting out how both bodies will share information and cooperate in regulating the sector. This collaboration reflects a wider shift towards tighter oversight of football’s commercial practices which is a trend that clubs can’t afford to ignore.

What does this mean for clubs?

Regulatory scrutiny of sponsorship arrangements in football is evolving rapidly. Clubs must take a proactive approach, as entering into agreements without appropriate safeguards can expose them to legal risk, financial liability and reputational damage.

How can we help?

Our award-winning sports law team advises clubs, leagues and rights‑holders across the full spectrum of regulatory, commercial and governance issues affecting the sector.

In light of the increasing focus on sponsorship arrangements with unauthorised financial firms, we support sports organisations by:

• Advising on regulatory compliance, including the risks associated with sponsorship and partnership arrangements involving financial firms and their compliance with UK financial services laws.
• Supporting clubs with sponsorship due diligence, helping to work through the FCA’s recommended steps and understand the practical steps required to mitigate regulatory and reputational risk.
• Reviewing and negotiating sponsorship and commercial agreements, ensuring that appropriate contractual protections are in place.
• Providing strategic advice on evolving regulatory developments, helping clubs to anticipate and prepare for potential changes arising from the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026.
• Advising boards and senior management on governance and risk, including directors’ duties and potential personal liability where sponsorship arrangements intersect with unauthorised financial firms.

Talk to us by calling 0333 004 4488, emailing hello@brabners.com or completing our contact form.