From doping scandals to financial mismanagement, poor governance in sport - both in the UK and internationally, has frequently made headlines, shaking public trust and exposing systemic failures. It is now almost 10 years since UK Sport and Sport England introduced ‘A Code for Sports Governance’ (‘the Sports Code’)[1], which was partly in response to such governance crises. Nearly a decade later, it is timely to reflect on how the Sports Code (current edition available here) has adapted key governance principles, and the likely impact of those included within the latest iteration of its corporate counterpart, the UK Corporate Governance Code.
The origin and evolution of the Sports Code
The UK Government’s ‘Sporting Future’ strategy (2015) envisioned a governance framework that would set a Gold Standard for sports governance and establish the UK as a world leader in the sector. In response, UK Sport and Sport England introduced a single, unified governance framework for publicly funded sports organisations. The strategy behind its inception was clear - the Sports Code should be the sporting equivalent of the UK Corporate Governance Code (‘the Corporate Code’). Stemming from the 1992 Cadbury Report, the Corporate Code had already shaped corporate governance for a couple of decades, establishing itself as the Gold Standard for UK listed Companies. As such, it provided a relevant reference for the development of the Sports Code.
Since October 2016, both Codes have evolved. The Sports Code was updated in 2021, and the Corporate Code in 2018 and most recently in 2024. Today, the Sports Code remains the cornerstone of accountability for sports organisations in England receiving government and National Lottery funding. It has also influenced sports governance globally, with several countries seeking to emulate it.
As the ink dries on the latest Corporate Code 2024 revisions, most of which came into effect on the 1st of January 2025, we are presented with an opportunity to reflect on how the Sports Code complements and adapts key governance themes from the corporate sector, while continuing to support governance in the English sports sector.
Shared foundations and distinct contexts
At their core, both Codes enshrine similar principles of good governance, such as effective leadership, accountability to stakeholders and transparency in decision-making. Both frameworks aim to ensure the long-term success of their respective organisations, whether a FTSE 350 company or a National Governing Body of a sport. They seek to do so within different contexts and via alternative structures, however.
The Corporate Code is designed to support the success of listed companies in maximising shareholder value, whereas the Sports Code seeks to ensure organisations who seek and are in receipt of UK Government and Lottery funding are accountable to participants, members and the wider public. This distinction shapes each code’s governance focus. For instance, the remuneration structures and audit requirements which are central features of the Corporate Code are less prominent in sport’s largely voluntary sector, which has a greater focus on diversity, inclusion and safeguarding instead.
A fundamental difference between the two Codes is their compliance structure. The Sports Code is ‘mandatory’, with non-compliance risking withdrawal of public funding, whilst the Corporate Code operates via a ‘Comply or Explain’ model, where decisions not to comply can be handled with appropriate justification within a company’s annual report. Despite its mandatory nature, the Sports Code introduces flexibility with its tiered approach, which is designed to ensure that governance expectations are proportionate. Tier 1 is applicable to organisations in receipt of lower levels of funding, rising to Tiers 2 and 3 for those receiving larger or longer-term investments, with Tier 3 subject to more advanced governance requirements.
Evolving Governance priorities in Sport
As the sports sector has continued to evolve, so too have the expectations placed on those who govern it. The Sports Code has responded carefully to these, gradually expanding its focus to embrace emerging priorities, whilst maintaining its core principles. Areas such as diversity, safeguarding, and the promotion of good governance at regional/local level have become integral to how success is defined, and how it can be sustained from a governance point of view.
Diversity
Approaches to infusing diversity within governance structures continue to develop, reflecting the complexity of tackling entrenched inequalities within corporate and sports governance.
The UK has taken a regulatory approach to incorporating diversity in governance. Historically, the Corporate Code stopped short of setting enforceable inclusivity targets, instead encouraging boards to consider diversity by participating in voluntary initiatives such as the FTSE Women Leaders Review. However, the Corporate Code 2024 has increased this onus by asking organisations to demonstrate how such initiatives have improved diversity over time - meaning a blanket statement stating that they’ve signed up to an initiative will no longer be sufficient.
One of the most notable impacts of the Sports Code has been its focus on diversity. In the 2016 edition of the Code, there was a requirement for funded organisations to ‘adopt a target of, and take all appropriate actions to encourage a minimum of 30% of each gender on its board’. This target was essentially achieved. There was also a requirement for funded organisations to ‘demonstrate a strong and public commitment to progressing towards achieving gender parity and greater diversity generally on the board, including, but not limited to, Black, Asian, minority ethnic (BAME) diversity and disability’. The Sports Code 2021 then introduced a more specific requirement for Tier 3 organisations to put in place Diversity and Inclusion Action Plans (DIAPs), in order to strengthen the embedding of structured and measurable diversity goals. With such requirements around diversity becoming mandatory conditions of funding, over a period of years, the Sports Code has driven significant changes. Sport England’s 2024 ‘Diversity in Sport Governance’ report shows:
● 44% of senior leadership team members, and 41% of board members (a figure similar to that within FTSE boards [2]) of funded sports bodies, are now female;
● 27% of CEOs, and 25% of Chairs of English sports boards are now female (in contrast with UK listed Companies, within which less than 20% of such roles are held by women [3]);
● Representation of Black, Asian and other ethnically diverse board members is 15%, which is relatively similar to figures within UK listed Companies [4];
● Disability representation has increased to 16% among board members (meanwhile limited stats are available in respect of UK listed Companies, reflective of a concerning gap in understanding current trends in the corporate landscape in this area).
Safeguarding and Welfare
With the nation facing a growing mental health crisis, it has become crucial for organisations to prioritise wellbeing and overall welfare as a core governance responsibility. Increasing risks within the sports sector range from athlete welfare and safeguarding, to doping scandals. Recognition of this led to the Sports Code 2021 mandating that Tier 3 organisations appoint a ‘Welfare and Safety’ lead director, ensuring direct representation of safeguarding in board level decision-making. The Corporate Code does not focus on sector-specific risks at this level, though one of its recent revisions expects boards to assess and monitor how desired company culture has been embedded into an organisation, ensuring alignment with strategic objectives.
Governance Beyond the Board
While the Corporate Code has traditionally concentrated on board-level oversight, a notable feature of the Sports Code is its commitment to cascading governance throughout an organisation, beyond board level [5]. This seeks to ensure governance principles reach regional and grassroots levels, and reinforces the idea that good governance should not be a compliance exercise, but an integral part of an organisation’s long-term sustainability and accountability. The (English) Football Association’s Code of Governance for County FAs exemplifies this.
Opportunities in a changing governance landscape
As with any framework, ongoing refinement ensures relevance in a changing landscape. With conversations around organisational resilience and sustainability intensifying, two themes are moving steadily up the governance agenda - effective risk oversight and environmental responsibility.
Risk
A robust risk management framework helps protect against the likes of financial failures leading to legal consequences and costly reputational damage. One of the key updates in the Corporate Code 2024 is the introduction of stronger risk management and internal controls. Previously the board was responsible for establishing a risk management and internal control framework, however as of 1st January 2025, the board is now expected to maintain its effectiveness. The board will also be required to: describe how it has monitored and reviewed the framework; provide a declaration on the effectiveness of material controls, and detail any controls which have not operated effectively, including the actions proposed to address these [6].
The Sports Code has an existing requirement for organisations to maintain risk management and internal control systems, and to regularly review and monitor them, to ensure they continue to be effective and provide reasonable assurance. Looking ahead, the Sports Code could continue building on this strong foundation and may choose to explore whether extending its risk oversight could further strengthen governance within Tier 3 organisations.
Environmental sustainability
The Sports Code 2021 directly identified environmental sustainability as a governance priority, requiring sports organisations to consider their environmental impact in decision-making [7]. This inclusion signalled a proactive approach, particularly in response to the increasing climate impact of sporting activity. The Corporate Code currently defers to separate ESG reporting requirements (such as the Task Force on Climate-related Financial Disclosures (TCFD)). There may be future scope for both codes to explore how strengthened expectations or reporting mechanisms could continue to support the delivery of sustainability goals, ensuring that long-term environmental responsibility is given the same priority as financial and operational governance.
The Future for English Sports Governance
The Sports Code, backed by the power of funding leverage, has set a strong foundation for integrity, accountability and progress across English sport, transforming the governance landscape and serving as a driver of lasting change across the sports sector. It has drawn on the strengths of the corporate code’s practice, adapting them thoughtfully to the context of sport, while also innovating in areas such as safeguarding, diversity and cascading governance. Its evolution over the past decade demonstrates a sector-wide commitment to raising standards for the benefit of all those involved in sport, from elite to grassroots.
With governance challenges continuing to evolve and expectations rising, the Sports Code is well positioned to continue leading the way in governance excellence.
At the time of writing, legislation is progressing that would introduce an Independent Football Regulator, including a governance code for English football clubs, which demonstrates continuing momentum in sports governance. As football clubs generally take the form of limited companies, with concentrated ownership but broader responsibilities, they are inherently distinctive from both governing bodies and listed companies. It will be interesting to see to what extent a future football club governance code builds on the existing Sports Code and Corporate Code.
Footnotes:
[1] Disclosure: Rowland Jack, the Founder of I Trust Sport was employed at UK Sport as part of the team that developed ‘A Code for Sports Governance’ in 2015-16. I Trust Sport has worked on and continues to work on projects related to implementation of the Code.
[2] As reported in the FTSE Women Leaders Review published February 2025
[3] In FTSE 100 companies, only 9% of CEOs are women, with numbers dropping further in FTSE 250 and 350 firms (as reported by the FTSE Women Leaders Review, February 2025). In terms of female Chairs, data in respect of FTSE 100 companies is limited, and sitting at 14% of FTSE 250 and 17% of FTSE 350 companies. This disparity underscores the ongoing challenge for the Corporate Code to foster diversity beyond board appointments.
[4] The stats released in March 2025 around Black, Asian and other representation at board level within the latest edition of the Parker Review (an independent report commissioned by the UK Government to assess and improve ethnic diversity on the boards of UK-Listed Companies) show figures at 19% for FTSE 350 companies, dropping to 13.5% and 15% for FTSE 250 and 100 companies.
[5] Requirement 4.1 of the Sports Code 2021
[6] Provision 29 of the Corporate Code 2024 - effective 1st January 2026
[7] Requirement 5.2 of the Sports Code 2021
