So we have learned that GBE and ESC are a vital part of the recruitment framework in England, but what about the situation in the other UK countries?
The devolved state of the game in the UK means that although Brexit was a UK Government process, backed, of course, by the voting of the UK people in 2016, the enforcement of the GBE strategy that has been employed off the back of that decision is a matter for the devolved nations’ football associations.
It is beyond the realms of my reach and expertise to know exactly what flexibility within the framework each of the Scottish, Welsh, and Irish FAs has to change what has been discussed with the Home Office, but there are some subtle, and some not very subtle, differences in the regulations across all four nations.
What this means in practice is that foreign players, foreign clubs, and foreign agents will need to be aware of the regulations that apply to the club that they are dealing with.
Equally, staff in the clubs in Scotland, Wales, and Northern Ireland also need to be aware of where the limitations in their system are, and plan accordingly with their recruitment strategy.
GBE in Scotland
The Scottish FA's approach to dealing with the issue of GBE has always been somewhat different to that of the other British FAs.
The motivation behind the reason for this different approach has never really been made explicit, but the SFA's chief concern is the health of the game of football in Scotland and it seems to have wanted to protect that as the number one priority.
This is not to say that there are no rules and regulations regarding the migration of footballers to Scotland, it is not an open door policy, but on my visit to the SFA in Glasgow in 2022, it was clear that they were very much aware of the different interpretation of the GBE rules that they enforced as compared to the English FA.
At the time, the regulations were practically the same in Scotland as in England, but, as was reported in the Analytics FC document I authored in 2022, there were many more players who did not meet the criteria getting GBEs in Scotland than was the case in England. This was primarily because the exceptions panel in Scotland seemed to be much more generous than its English equivalent.
There have been updates to the Scottish GBE system in football since then however. Indeed, there seems to have been a degree of independence granted to the SFA to make widescale changes to the way that the criteria are structured, which makes the whole notion of GBE an interesting one for the UK as a whole.
The SFA's changes
First of all, Scotland have not gone down the route of ESC like England have, but they have made certain concessions for youth players, which we will touch on later. The structure still requires a straightforward GBE, the criteria for which are still either an autopass through international appearances, the same structure as England, or 15 points gathered in the criteria.
Whilst the criteria are broadly the same as in England, what has changed is some of the points that the SFA have attributed to certain things.
The SFA are treating Bands 1-3 the same as each other. This means that the Portuguese, Turkish, Dutch, Belgian, Mexican, Argentinian, Brazilian, and United States’ top flights are all treated the same as Germany, Italy, Spain, France, and England top flights i.e. the league quality points for these leagues are all 12, and the maximum number of points available for domestic minutes played in any of those leagues is also 12. This massively widens the market of players available to Scottish clubs.
So, this means that, unlike any of the other British FAs, any player who plays in 30% of their teams domestic minutes in any of the Band 1-3 clubs will be eligible for a GBE. Also, any player who has been named in the squads of a team that finishes in a European qualification position is also eligible due to those criteria combining to 15pts or more.
There are many other ways to attain the 15pts required as well, as detailed in the graphics, with the overall point being that if a player plays in Band 1-3 there is a very good chance that they will be able to attain the points required for a GBE, without requiring an exceptions panel
Exceptions Panels
The exceptions panels are different than in England too. First of all, the cost isn't prohibitive, only £500 compared to the £5000 that was cited initially in 2021, and whilst the judging criteria are still fairly nebulous, it is, at least, easy to understand. If a player doesn't meet the points criteria, the exceptions panel will judge the case on whether the individual is of ‘the highest calibre’ and whether or not the individual can ‘contribute significantly to the development of the game at the top level in Scotland’.
These terms seem to me to be woolly enough to not be nailed to specifics, but directed enough for clubs to know what they have to prove to the panel in presentation.
However, the regulations have clearly been adapted to try and prevent clubs from having to use the exceptions panel as often as they had to in the past. There is a criterion that is new to the GBE Expert Hub in the SFA documents, which is referred to as points allocated for investment.
Basically, if a Scottish club wants to pay the player that they are recruiting a salary that is above the median amount for the league then they are allocated extra GBE points for that.
Youth Criteria
Where the English regulations did away with specific youth criteria in favour of introducing the ESC scheme for 2023/24, the SFA version details criteria for youth players that can be used to reach the 15pt mark for players under 21 at the date the application is made.
Firstly, if a player has played in international youth competition for their country they can receive points. The SFA have created Band 1 and Band 2 international competitions and named them within the document.
There are also points for youth players who make their debuts in senior leagues, even if only for a minute. The youth player is also eligible for points earned by their senior club as long as they have played enough youth minutes (over 30%).
The net result of these youth specific additions to the criteria is that a lot of youth players at clubs in Europe are also eligible for GBEs, even if they haven't played senior football.
What effect has this had on Scottish recruitment?
As with all UEFA leagues, the expanded programme of UEFA competition since the Conference League arrived seems to have created added incentive for the FAs to make sure that their clubs are as competitive and well-prepared as they can be.
With multiple Scottish clubs, not just the Old Firm, guaranteed group stage football in UEFA competition, and up to half of the league getting into the qualification rounds, there are definite incentives for clubs to use all the resources out there at their disposal.
There is also real incentives for agents to push their players into the Scottish Premiership given the chances of a showcase on the UEFA stage, and, of course, the proximity to England and the potential of a move south of the border if the player impresses sufficiently.
The number of transfers from Bands 4-6 in the window just about to close in Scotland certainly seems to suggest that clubs are continuing to speculate on these markets.
There has been a clear increase in players coming into the Premiership that would require a permit.
Band 4-6 transfers made up 30 of the 39 (77%) GBE transfers made in 2023/24, we are yet to have the January window so there is not a full set of data for 2024/25 yet, but a similar trend is occurring this season too. These transfers are supposedly more difficult to do post-Brexit, yet there seems to be a high level of success for these deals in Scotland.
The amount of money being spent by Premiership clubs to foreign clubs to buy players has massively increased in the last season as well. Time will tell whether all of this money going out of Scotland is a wise thing, but an increase in quality could work to the benefit of the game in Scotland.
GBE in Wales
Before we examine the documentation, the FAW have a unique issue in their jurisdiction that none of the other home FAs have to deal with. The FAW handles the registrations for the four Welsh clubs that play within the English system i.e. Swansea, Cardiff, Wrexham, and Newport County.
This means that there are obvious difficulties when looking at their regulations surrounding GBE. One would presume that there has to be an element of consistency around how the FAW structure their policy in comparison to the English FA. However, as of 2024/25 there is no mention in the FAW handbook of any use of ESC, and yet we have seen Swansea and Cardiff sign players under the ESC regulations. It is quite confusing.
Indeed, the FAW requirements are the same as The FAs, either an autopass through international minutes, or 15 points attained through criteria, are required to allow the Welsh FA to recommend a GBE for a non-British player to sign for a team under their league system, the Cymru Premier and the Cymru North and South tiers.
This is really interesting, because the standard required to attain 15 points, as discussed previously, is pretty high. Too high for most EFL clubs to even countenance signing talent from foreign clubs. So to have the same criteria in the Cymru Premier and below seems a tough ask.
There is one minor difference to register. Like the SFA regulations, there are extra points given to deals in which the club intends to pay the player money above the median average of the league. Up to 3 extra points are available here if a team is planning on paying 70% above the median. However, this does still mean another 12 points will need to be found elsewhere.
So, with a bar so high, who in Wales is signing any players who aren't British?
Short answer: nobody.
There have been no imports who either aren't British, or are brought in from other British clubs. Irish players still have an arrangement with Britain to be able to come over and be employed under the CTA (Common Travel Area), so that market is still open to Welsh clubs, and so between Ireland and the UK, Welsh clubs have their market pretty well set.
However, I wonder if the likes of perennial title winners, and current UEFA Conference League club, The New Saints, 2024 title challengers Penybont, and Connah's Quay Nomads, who both have ambitions to reach group stages in UEFA competition, might like to perhaps take advantage of players available in wider reaches of the marketplace.
Indeed, The GBE Expert Hub has scouts who are directly involved in the top tier of Welsh football who would dearly embrace the potential opportunity of enriching their club with overseas talent. This, in turn, could enrich the Cymru league system altogether.
The questions that I don’t have the answers to are whether or not there is wiggle room for the Welsh FA to be more enterprising with their regulations to perhaps allow this? Or would it make no difference as Welsh clubs wouldn't use it anyway? Or are the Welsh FAs hands tied by the UK Government?
GBE in Northern Ireland
As we know, Brexit has been a huge issue in NI even more so than any of Scotland, Wales, or England, because it is the only part of the UK that shares a land border with the EU. This has caused many complications in terms of trade and human relations, but has it had any effect on recruitment in football?
The Common Travel Area agreement between Ireland & the UK applies to football & allows for people to move fairly freely between the countries, and so we have seen Irish players move into the UK and vice versa without any issue.
However, one thing that has changed is that U19 players have not been able to move across the border. This used to be possible under EU regulations that superseded the FIFA stipulation that minors <18 were not able to move between countries for footballing reasons. This has had a profound effect on Ireland as a talent producing nation, something that I delved into for Analytics FC last year.
This has had an effect on recruitment for clubs in NI as well. Obviously, the way that families work in the two countries means that many people will have dual citizenship, in which case there are no issues with where they live or work.
In terms of the regulations, the story is a similar one to Wales. Looking at the regulations posted on the IFA website, the 24/25 regulations look like they are carbon copies of the ones that the Welsh FA use.
This means that there are the same standards of autopass criteria i.e. a certain percentage of international minutes for a highly ranked nation, very difficult for an Irish Premiership club to attain.
The 15 point threshold for the criteria is just as difficult to recruit non-Irish or non-British players from of course. There is the same extra caveat in the IFA regs as we saw in the Welsh ones in that if the proposed player was to be paid over 50% of the median wage of the league then they are granted extra points.
However, there is some leniency by way of the exceptions panel in the IFA legislation. To request an exceptions panel for a senior player, only 8 points are required, which means that any player registered to a Band 3 club or above could be taken to exceptions panel regardless of any further points accrued.
It is even better news for youth players, who can get in front of an exceptions panel regardless of what point score they attained. In the documentation there is even a suggestion of what clubs may bring to an exceptions panel to persuade the IFA of the validity of their case. This guidance is something that has not been seen before in the documentation that I have read.
So who in Northern Ireland is importing non-British or non-Irish players?
Not many. Carrick Rangers signed Aussie Will Arnold in January. Larne signed 2 Real Salt Lake players on loan last season, and a Dutch full-back the season before. None of the players signed look as though they would be anywhere near the criteria for a GBE though.
With less than 2% of recruitment being non-domestic in NI, I wonder whether we are seeing something similar to what we saw in Scotland, in which the FA are happy to grant GBE as long as the club proves that the players are going to make a big impact on the game in the country.
Larne are obviously very ambitious, again, a debutant in the league stage of a UEFA competition for the first time, and Linfield would love to make an impact in Europe too. Finding a way to help import the best talent in other regions could be a way for the IFA to help their teams do this.