Starmer outlines recusal in football regulator pick

Let’s use today’s release as a live case study in the Ministerial Code. On 12 November 2025, Downing Street published letters between Prime Minister Sir Keir Starmer and Sir Laurie Magnus, the Independent Adviser on Ministerial Standards. The Prime Minister sets out why he recused himself from football policy decisions, acknowledges he replied that he was “content” with David Kogan being appointed chair of the new Independent Football Regulator, and calls that reply a mistake. Sir Laurie welcomes the transparency and an internal review of how recusals are handled in No 10.

Here’s the simple sequence you can share with students. In autumn 2024, after receiving hospitality from clubs and the Football Association, the Prime Minister agreed to step back from decisions on the Football Governance Bill. In April 2025, after the department had run the process, a note asked if he was content with Kogan as chair; he indicated support, assuming the Culture Secretary would take the statutory decision. In June 2025, after discussing two donations Kogan made to his 2020 leadership campaign and a donation to his local party, he confirmed he would remain out of the appointment process. The letters arrive in the same week that the Commissioner for Public Appointments published his decision notice on the appointment process.

If you’re teaching “recusal”, this is a clean example. Under the Ministerial Code, each minister is personally responsible for avoiding conflicts and managing the perception of a conflict. That’s why ministers share a full list of relevant interests with the Independent Adviser and, where needed, step back from related decisions. The Adviser is independent of government and gives impartial advice to help uphold the Seven Principles of Public Life.

It also helps to know who Sir Laurie Magnus is and what authority the role now holds. The government updated the Ministerial Code in November 2024, strengthening the Independent Adviser’s powers to initiate investigations and tightening transparency around gifts and hospitality. The Adviser’s reply to the Prime Minister stresses trust, openness and the need for robust recusal processes in No 10.

So, how is the football regulator chair appointed? The law makes this a decision for the Culture Secretary, with public scrutiny built in. David Kogan was named the government’s preferred candidate on 25 April 2025 and then faced a pre‑appointment hearing with MPs, who endorsed him on 9 May. He was confirmed as chair on 6 October 2025 while an inquiry by the Commissioner for Public Appointments was still under way. This is a standard route: ministers choose from appointable candidates, and select committees test suitability in public.

Why did No 10 feature at all if the decision wasn’t the Prime Minister’s? The PM explains that when an appointment is tightly linked to government priorities, No 10 is routinely briefed on progress even though the Secretary of State is the appointing authority. He adds that, in retrospect, it would have been better not to have been asked for his view given his recusal-and he has ordered an internal review of how recusals are managed in No 10. This is a useful reminder that process matters as much as outcome.

What did the appointments watchdog actually find? In a decision published on 6 November 2025, the Commissioner for Public Appointments identified three breaches of the Governance Code: the Secretary of State did not declare and resolve an interest before selecting the preferred candidate; a potential conflict was not discussed with the candidate at interview; and the department did not disclose the candidate’s recent political activity at the time of the announcement. The Commissioner recommended clearer guidance and earlier engagement with his office on sensitive cases.

A point to underline in class: political activity isn’t a bar to public appointment, but it must be declared openly. Kogan remains in post-his appointment was confirmed by the Department for Culture, Media and Sport in October-and the Commissioner’s report focused on process, not competence. That makes this a strong example of how transparency rules work in practice rather than a verdict on a candidate’s ability.

What this means for learners and teachers: when reading official correspondence, trace three things-who has the power to decide, who is advising, and where perceptions of conflict could arise. In this case, the Prime Minister’s recusal, the Adviser’s guidance, and the Commissioner’s separate oversight show how multiple checks interact to protect public trust. It’s also a reminder that “perception” is not a soft idea; it’s built into the Code.

A quick timeline you can map on the board. Autumn 2024: PM recuses from football policy decisions. 25 April 2025: government names Kogan as preferred candidate. 9 May 2025: MPs endorse him after a hearing. 6 October 2025: appointment confirmed. 6 November 2025: watchdog publishes decision notice on process failures. 12 November 2025: PM and Adviser publish letters setting out the account and next steps.