Author: Maxime Van Den Dijssel

What you need to know ahead of the January transfer window.

On 21 December 2023, just 11 days before the opening of the January transfer window, the FA released its national implementation of the FIFA Agent Regulations.

The FA Football Agent Regulations will enter into force on 1 January 2023. These Regulations are set to apply to:

1. all representation agreements with a national dimension;
2. all conduct relating to national transactions; and
3. all approaches made by agents to Players, Coaches and Clubs in relation to providing football agent services.

To help you navigate the changes ahead of the January transfer window – here are the key things you need to know about the Regulations:

· Registration with the FA: any football agent wishing to conduct football agent services must now be registered with the FA. To register as an FA Registered Agent (“FA Agent”), you must hold a FIFA Agent License (via passing the FIFA Agent Exam or the Legacy Path). Once you have obtained your FIFA Agent License, you will need to complete the following form: FA Agent Registration Form.

If you do NOT hold a FIFA Agent License, you cannot act as a football agent in January. If this applies to you, please contact us for further advice.
Working through an Agency: while FA Agents can conduct their business through agencies – only natural persons that are registered with the FA can conduct agent services under a representation agreement. Agencies and companies can no longer register with the FA. Accordingly, it is important to check your representation agreements to ensure an FA Agent is a party to it and is the one providing the agent services.

Working with Minors: additional authorisation is required to work with minors. You will need to obtain authorisation through both FIFA and the FA before you are able to work with minors. The Regulations further prohibit an FA Agent from approaching a minor before 1 January in the academic year (i.e. starting 1 September) in which the minor reaches the age of 16. Prior written consent is also required from the minors legal guardian.

Representation Agreements: FA Agents must lodge player representation agreements on the FA Agent Portal (this includes both new and existing representation agreements). Club / Agent representation agreements (including tripartite agreements) need to be lodged by the Club via email to within 14 days upon execution. Before entering into a representation agreement, FA Agents must notify the Player / Coach that they should seek independent legal advice. Written confirmation that the Player / Coach has either received or decided not to take legal advice must be evidenced and annexed to the representation agreement.

Agent Payments (the “Player Pays Approach”): a P11D benefit in kind payment is only permitted if a Player’s salary is under $200k (equivalent to approximately £158k per annum and not including any conditional payments). Where a Player’s salary is more than $200k, Player’s will be permitted to make payments to the FA Agent via a net deduction from their salary. Until FIFA requires all payments to FIFA Licensed Agents to be made through the FIFA Clearing House, at this stage payments must be made directly to the Agent by the Club or Player. Proof of payment will need to be uploaded by the Club to IFAS where payments are made by a net salary deduction or as a P11D payment. Agents will need to upload proof of payment to the FA Agent Portal where the payment is made directly by a Player.

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