Women’s football is firmly in the spotlight this summer.  Following a record-breaking domestic season, where viewership and live audiences for the Women’s Super League (WSL) hit an all time high, the expanded World Cup format is showcasing the ever-increasing quality and strength in depth of the women’s game.  Despite a faltering build up for the Lionesses, not least with knee injuries ruling the captain, Leah Williamson, and star players Beth Mead and Fran Kirby out of the tournament, the European champions are showing good promise on the pitch after progressing to the knock-out stages with an emphatic win against China. 

While all signs point towards a bright future for women’s football in England and beyond, the sport is still at a nascent stage.  There remain clear opportunities for improvement and growth. 

For example, the row over the value of broadcast rights to show the 2023 World Cup meant that there was a real risk that the tournament would not be shown on TV in the UK (and elsewhere), with threats of a media blackout in key jurisdictions less than two months before the opening match. Fortunately, a deal was struck with the BBC and ITV just 5 weeks out from the start of the tournament – unlike Japan (who also have a strong pedigree in women’s football), where an agreement was not reached until the opening day.  Clearly it is important that the commercial value of women’s football is properly recognised – but so is the visibility of the most important tournament on the football calendar.  There is a similar impasse (albeit on pause for the duration of the World Cup) regarding bonus payments and commercial arrangements for the Lionesses which, as widely reported, differ starkly to their male counterparts. 

In this mixed context of great potential and challenge, the publication of former England international Karen Carney MBE’s report, Raising the Bar – Reframing the Opportunity in Women’s Football (the “Review”) in July 2023, is broadly seen as a positive step at a key time for the game.  The Review seeks to provide the vision and direction to realise the potential and take the women’s game in England to the next level. 

In this article, we summarise some of the key findings of the Review and share our take on what it means for women’s football.

Background to the Review

The Review was commissioned by the UK Government following the recommendation in Tracey Crouch’s 2021 fan-led review into football governance that “given the many, but interconnected, issues affecting a meaningful future for women’s football needing to be addressed and resolved successfully, the future of women’s football should receive its own dedicated review”.  Crouch’s review ultimately recommended an independent regulator for men’s football, which the Government in its White Paper has confirmed will be introduced “to ensure that English football is sustainable and resilient, for the benefit of fans and the local communities football clubs serve”.  In contrast, Carney has concluded that women’s football should be afforded the opportunity to self-regulate and to take learnings from the men’s game, other sports and the new independent regulator, when established. 

Summary of Recommendations

The vision is for England to set the gold standard globally, not just for women’s football but for women’s professional sport.  The Review details the idea of the “virtuous circle” as a means of achieving that aim, i.e. implementing higher minimum standards, which will lead to higher on-pitch quality and an increased fanbase, in turn attracting more investment from broadcasters, commercial partners and others, thereby resulting in more money flowing through the football pyramid and increasing standards still further (and so the cycle continues).

The Review sets out 10 key recommendations as priority areas for raising the bar and kickstarting the virtuous circle:

• 1 – World-leading standards – With The FA planning to launch a NewCo in time for the 2024/25 season (whereby the top two tiers – the WSL and the Women’s Championship – will move to an independent club-owned structure), the Review finds that this structural change will help to incentivise investment, thus raising standards at club level and attracting more revenues.   While the focus of this recommendation is on increasing the professional infrastructure and end-product in order to seek investments and new funding streams, there is an emphasis simultaneously on doing so in a sustainable way with effective financial regulation.  Ultimately the Review recommends that promotion and relegation between the women’s leagues remains in place for the time being, whilst noting that The FA’s Professional Game Working Group is considering, amongst other proposals, the possibility of a closed league for the top two tiers.
• 2 – Talent pathway – The disparity is highlighted between the funding of men’s academies, which receive £88m a year in Premier League funds, and women’s academies, where The FA’s budget is £3.25m a year.  The recommendation in the Review is for The FA to partner with a strategic investor to fund a new domestic talent pathway.  While the new pathway is being established, it is recommended that clubs should be able to access an increased pool of overseas talent by lowering the Governing Body Endorsement criteria for clubs in the short-term.
• 3 – Professional environments – As per recommendation 1, there is an ambition that the WSL and Women’s Championship become fully professional, attracting and developing the best players in the world, with the gap between the two tiers narrowing.  The Review envisages that this can be achieved through mandating (by way of licensing requirements) improvements in various areas, including contact time, salaries, training facilities, physical and mental health care, and parental packages. 
• 4 – Diversity – The Review concludes that The FA should establish, publish, and review relevant workforce data in order to implement a strategy to address and improve diversity on and off the pitch in the women’s game.
• 5 – Broadcasting – The opportunity to further monetise broadcast rights and increase live audiences is considered in the context of broadcasting scheduling conflicts.  The Review recommends that there is a dedicated broadcast slot for women’s football and puts forward the possibility of a relaxation of the Saturday 3pm blackout for the women’s game.
• 6 – Fans – The focus is on minimum standards being raised through FA licensing requirements so that clubs better value and support their fans, including in the areas of marketing, ticketing policies, stadium strategy (including increasing matches played in main stadia), and health and safety.
• 7 – School Sport – The Review calls for the Government to deliver on its recent commitments around opportunities for school sport for girls, which follows on from the Lionesses’ and FA’s post-Euros #LetGirlsPlay campaign.  The Review contains a discussion of the damaging effect of gender stereotyping in the context of primary and secondary school sport. 
• 8 – Grassroots facilities – access – The Review urges all involved in funding the grassroots game to work together to increase investment and access to the game for women and girls.  The lack of availability, affordability and quality of pitches is highlighted as a problem across the grassroots game, along with particular issues for women and girls around the lack of appropriate changing rooms and toilets, for example.
• 9 – Grassroots facilities – funding – The Review calls on The FA, Premier League and Football Foundation to create a funding strategy to ensure that targeted funding is available to the entire women’s football pyramid.
• 10 – Administration – Once the ownership structure of the WSL and Women’s Championship has been changed, The FA is encouraged to focus its efforts on the grassroots game and the Women’s National League.  The Review outlines a number of key issues for the Women’s National League around funding, fixture scheduling and support when clubs move between tiers. 

Comment

A fundamental discussion within the Review concerns the finances, regulation and structures within women’s football.  The call for increased investment into the game from external, owner and affiliate club funding is carefully balanced with the need for sterner regulation to avoid clubs biting off more than they can chew.  While the Review calls for clubs to be ambitious, the last thing the game needs is for clubs to hit the sort of financial issues we have seen in other sports and, to some extent, the men’s game.  In order to address this concern, the Review suggests that regulations should provide for clarity in accounting and that owner/ affiliate funding should come with clear commitments (amongst other things). 

The limitations in accounting have been highlighted recently in Deloitte’s Annual Review of Football Finance, which notes that there is a lack of transparency and complexity in respect of revenues and costs of WSL clubs.  For example, if a women’s club is affiliated to a men’s club and there are bundled rights, e.g. a front shirt sponsor pays for the rights to sponsor both the men’s and the women’s teams, a careful allocation will need to be made as between the clubs.  The same would apply in respect of certain costs. 

The Review considers that increasing the clarity in accounting will assist with strategic business planning and budgeting.  In this regard, it is noted that the current WSL regulations set salary cap thresholds at 40% of a women’s club’s gross annual operating budget, so one can see how, for the purposes of financial sustainability and competitive balance, it is important that accounting practices are rigorous and provide a reflective picture of the overall financial position of women’s clubs. 

Regarding owner and affiliate funding, although highlighted as vital investment into the women’s game by the Review, there is also consideration of how reliance on such funding may put women’s clubs in a vulnerable position.  As things stand, there is little protection for women’s clubs if affiliated clubs are relegated, hit financial difficulties, decide to withdraw funding, or sell up to a new owner who is not interested in providing funding to the women’s club.  The Review suggests that commitments are made for funding to be honoured, as a condition of licence to the league – for example through personal or group company guarantees.  It should be noted, however, that there are concerns from some clubs that requirements for financial guarantees may be unachievable for smaller or independent clubs within the top two tiers. 

Next steps

It is a waiting game to see how The FA, the NewCo running the top two tiers and other stakeholders will take forward the recommendations from the Review.  With self-regulation favoured over an independent regulator, at least for now, the women’s game has an opportunity to shape its own future and put the sport on the right path from an early stage.