Regulatory activities consultation

Background

In July 2022, the football sector secured a historic change of policy, with the introduction of licensed standing for grounds subject to the all-seater licence conditions. This has seen engineering solutions being used to address the known safety risks associated with persistent standing in areas designed for seating.

Since this change, persistent standing has reduced significantly in England and Wales due to the commitment of grounds and the sector to address the risks. Over 200,000 seats now have infrastructure that enable fans to safely stand when watching football.   

But more work is needed. Fans persistently standing in seated areas without that protection is still a significant occurrence in many grounds. Established, independent research has found that persistent standing can lead to involuntary and uncontrolled crowd movements and subsequent related safety risks.

This All-Seater Enforcement Approach document reinforces our sustained efforts to address persistent standing in seated areas, using a measured, proportionate approach, but also an approach that reflects the fact the option of licenced standing has been available for  several years.

Our message is simple: seats without any safe standing infrastructure are for sitting only. If fans persistently stand in seated areas, whether home or away, the ground has a duty and legal responsibility to address this known safety risk. 

What does the consultation cover?

Following an internal review, the SGSA is proposing changes to how the SGSA assesses compliance with the all-seater policy.

The majority of the All-Seater Enforcement Approach content remains the same, in particular the ‘initial steps’ and ‘further actions’ grounds are expected to take to demonstrate compliance with the all-seater licence conditions.

The proposed revisions relate primarily to the internal SGSA processes for assessing compliance, refining the method based on experience gathered since 2019/20.

The SGSA is proposing the evaluation of compliance be based on two overarching components and supporting assessments:

• Foreseeable risk – the extent to which safety risks could be reasonably anticipated based on the existing control measures in place.
  • Is there currently identified persistent standing at the ground?
  • Has there been a persistent standing-related incident and/or ‘near miss’ at the ground?
• Confidence – the level of assurance that the ground’s arrangements will address the risks and achieve compliance.
  • Has the ground already undertaken further action to address persistent standing?
  • Does the ground accept that more remains to be done?
  • Does the ground have a plan in place with a reasonable timeframe?
  • Are there any technical issues related to the construction/layout of the ground?

Additionally, SGSA has taken the opportunity make some further proposed changes to aid clarity and transparency. All of the proposed changes  are summarised at Annex A of the revised document.

Throughout the consultation document, boxes outline what, if any, changes have occurred within each section.

In addition to the All-Seater Policy Enforcement Approach, we are consulting on a proposed minor change within the Oversight and Licensing Policy, which is solely to clarify the SGSA’s existing well-established licensing and oversight responsibilities under the Football Spectators Act 1989 to avoid the risk of misinterpretation.