Chansiri was still in default on late payments to his players and employees when the Football Governance Act became law on 21st July. He'd not back-paid by then, so he was still carrying this baggage with him when he walked through that 'time gate', consequently becoming liable for it, at that point, under the new law.
And if there was any lingering doubt about the law being applicable to him only after coming into force by 21st July, he defaulted again at the end of July on payments on time and in full to staff and players.
This allows the IFR to investigate root causes and effects and take them into account i.e. the history of late payments to HMRC and late wages payments four months out of five in 2025 directly related and linked, in cause and effect, to what he was instantly liable for when the Act became law.
The IFR can enforce the law (in building a case for an owner removal order) by itemising his explicit non compliances with the Act but they are also permitted to take the line, as written into the Act, 'or are treated as having determined' that a person is unsuitable to be an owner or officer of a regulated football club. This is a catch-all provision which allows obviously harmful mismanagement acts and omissions to be taken into account, not explicitly stated in the Act, but obvious in fact.
It's very similar to the legal doctrine used to prove negligence in accident and injury cases, Res Ipsa Loquitur, which means that 'it speaks for itself' the harm caused by the actions of the person whom we hold accountable.