Football Sponsorship Due Diligence: FCA Warns Clubs Over Unauthorised Financial Promotions

The FCA has warned football clubs about the risks of entering sponsorship agreements with unauthorised financial firms. This article explains why football sponsorship due diligence matters and the practical steps clubs should take to reduce legal, regulatory and reputational risk.

Why is the FCA targeting football sponsorships?

It’s early June 2026. The World Cup is about to kick off. In my household, the excitement is building as my sons curate their first Panini sticker albums.  

Of course, our anticipation is far from unique. A worldwide audience in the billions is gearing up, too. The English football industry is keen to capitalise on the feel-good factor. Many domestic clubs are negotiating lucrative new sponsorship deals. The hope is that new kits hit stores at the same time as national team merchandise.

The beautiful game has not only gripped supporters, pundits and sponsors, however. Regulators in the UK have also reached fever pitch, concerned that unauthorised financial firms are targeting football clubs to promote high-risk products. This prompted the Financial Conduct Authority (FCA) to write to football clubs in early June to warn them about the potential harm they may be unwittingly exposing their fans to and reinforce the importance of football sponsorship due diligence before entering into commercial partnerships.

The risks of unauthorised financial promotions

Some recent cases involving other regulators in the crypto-asset and gambling spaces illustrate the kinds of harm the FCA is keen to tackle. In 2022, the Advertising Standards Agency (ASA) criticised Arsenal FC and FC Barcelona for failing to explain the risks of NFTs and omitting key information about their acquisition. In 2025, the Gambling Commission (GC) wrote to Everton FC to express concerns about the promotion of Stake.uk.com, an unlicensed gambling website. The GC warned that club officials might be subject to prosecution if they promoted the business, which it had found to have failed to implement safer-gambling alerts.

What are the legal risks for football clubs?

The risks are not limited to consumers. Football club regulatory compliance is becoming an increasingly important consideration as clubs enter into sponsorship agreements with firms offering regulated financial services. The FCA asserted that entering into sponsorship deals with firms not authorised in breach of section 19 of the Financial Services and Markets Act (FSMA) that also make unauthorised financial promotions contrary to section 21 of the FSMA creates legal, operational and reputational risks for football clubs. For example, football clubs’ onward promotion of a sponsor’s activities might itself be caught by section 21 of FSMA. Most sobering of all, revenues derived from irregular sponsors could even constitute criminal property under the Proceeds of Crime Act 2002 (POCA).

Football sponsorship due diligence: what should clubs do?

For these reasons, the FCA urged football clubs to conduct appropriate due diligence before contracting with firms purporting to offer financial services. Whilst undertaking due diligence in football by checking the FCA’s Register and Warning List is relatively straightforward, understanding some of the products and services offered and their regulatory status is likely to be complex. Accordingly, the FCA is encouraging football clubs to seek specialist advice where necessary. Furthermore, it expects clubs to monitor their ongoing relationships with sponsors, especially as the regulatory perimeter continues to evolve.

What should football clubs check before agreeing a sponsorship?

  • Confirm the firm is authorised on the FCA Register.
  • Check whether the business appears on the FCA Warning List.
  • Understand whether the products or services being promoted are regulated.
  • Obtain specialist regulatory advice where appropriate.
  • Review sponsorship arrangements regularly as regulations evolve.

Staying onside with FCA financial promotions rules

With the FCA linking up with the UK Government and the Independent Football Regulator to “show the red card” to unscrupulous firms that seek to put “potentially dodgy products in front of millions of fans” (Lucy Castledine, Director of Consumer Investments, FCA), clubs will be anxious to ensure they stay onside. The World Cup may have now kicked off, but so have the regulators.

If you need help in understanding how financial services regulations impact sports clubs, please get in touch with us. 

Frequently Asked Questions

Why is the FCA warning football clubs about sponsorships?

The FCA is concerned that some football clubs may unknowingly promote unauthorised financial firms or high-risk financial products through sponsorship agreements. This could expose supporters to financial harm while also creating legal, operational and reputational risks for clubs if financial promotions breach UK regulatory requirements.

What is football sponsorship due diligence?

Football sponsorship due diligence is the process of assessing whether a prospective sponsor operates lawfully and complies with relevant financial services regulations before a commercial partnership is agreed. This may include checking the FCA Register and Warning List, understanding the regulatory status of the sponsor’s products or services, and seeking specialist advice where appropriate.

Can football clubs promote financial services?

Yes, but clubs should ensure that any financial services sponsorship complies with UK financial promotions rules. Where regulated financial products or services are being promoted, clubs should carry out appropriate due diligence and understand the regulatory implications before entering into sponsorship agreements or promoting a sponsor’s activities.