Downing Street has released correspondence dated 12 November 2025 between the Prime Minister and the Independent Adviser on Ministerial Standards. Keir Starmer sets out his involvement in the appointment of David Kogan as Chair of the Independent Football Regulator, following a Decision Notice issued on 6 November by the Commissioner for Public Appointments into the process run by the Department for Culture, Media and Sport.
In his letter, the Prime Minister notes that the appointment of the regulator’s Chair is a statutory decision for the Secretary of State and explains that No 10 is commonly engaged on appointments closely tied to government priorities. He confirms he had previously recused himself from decisions on the Football Governance Bill after declaring a personal interest in football, including hospitality received.
The Prime Minister records that in April 2025 officials asked whether he was “content” with the Culture Secretary’s intention to appoint Mr Kogan, ahead of pre‑appointment scrutiny by MPs. He replied that he was supportive, but states that, in retrospect, the note should not have been put to him while recused and that he should not have responded. He expresses regret for this error.
He adds that in June 2025 he and the Independent Adviser discussed two donations from Mr Kogan to his 2020 Labour leadership campaign and a donation to his constituency party around the last general election. They agreed he would stay out of the appointment process entirely. He states he has not taken or approved any decisions on the appointment since, and has commissioned an internal review of how recusals are managed in No 10.
In response, Sir Laurie Magnus welcomes the disclosure and the review, describing robust recusal arrangements in No 10 as important. He notes it was regrettable that, despite the earlier recusal, the Prime Minister was asked to confirm his contentment with the recommended candidate, and says the steps outlined demonstrate a commitment to transparency and to improving standards processes.
The correspondence follows the Commissioner for Public Appointments’ findings of three material breaches of the Governance Code in the campaign to appoint the Chair. The Decision Notice concludes that the Secretary of State did not declare and resolve an interest before selecting the preferred candidate; that a potential conflict was not discussed with the candidate at interview; and that the public announcement failed to disclose the candidate’s recent political activity. It also records that, while the Culture Secretary is the appointing authority, the role sat on the Prime Minister’s “interest list”, requiring consultation with No 10 at key points.
The statutory framework is now in place. The Football Governance Act 2025 establishes the Independent Football Regulator, with appointments made under the Act by the Secretary of State. After the Culture, Media and Sport Committee endorsed Mr Kogan following a pre‑appointment hearing in May, the government confirmed his appointment on 6 October 2025.
For the centre of government, the immediate operational consequence is the internal review commissioned by the Prime Minister into how recusal directions are recorded, communicated and enforced, so that officials and advisers do not route “content” requests to a recused office‑holder. The Independent Adviser frames the issue as one of standards process and welcomes the corrective action.
For departments running regulated competitions, the Commissioner’s Decision Notice reiterates two Governance Code requirements: discuss any potential conflict with a candidate at interview and disclose relevant political activity in the public announcement. The CMS Committee’s earlier endorsement and the subsequent confirmation of the appointment mean the regulator’s establishment work continues under the Football Governance Act.