An earlier proposal to introduce salary limits in League One and League Two was abandoned in 2021 after the PFA claimed the regulations would be illegal and impossible to enforce.
The PFA continues to oppose the latest measures because it believes they could reduce the earnings of its members.
Birch said the union believes the rules may hold down wages and restrict investment in playing squads, adding that its concerns should be taken seriously.
However, he said there is also a valid fear that leaving the system unchanged would allow clubs’ existing financial difficulties to continue, particularly when owners cannot or will not provide additional funding.
He explained that the controls are intended not to curb ambition but to establish sensible safeguards, allowing clubs to invest carefully, compete effectively and avoid expenditure that could threaten their long-term survival.
Oxford United were temporarily banned from registering players last month after the League One club failed to meet the new requirements.
The club cannot currently recruit players through permanent deals, loans or free transfers, and has suggested that fulfilling the new obligations could take several months.
Meanwhile, Sheffield Wednesday spent much of last season in administration after former owner Dejphon Chansiri stopped financing the club.
The Owls received an 18-point penalty for financial violations and narrowly avoided collapse, prompting concerns about how the situation affected the division’s competitive balance.
Birch said supporters want clubs to possess the financial stability and resources needed to remain central to their communities for years to come.
He added that fans value ambition, but also expect genuine hope, fair competition and leagues that remain accessible, trustworthy and entertaining both in stadiums and on television.
They also want meaningful promotion and relegation battles, lasting local identity and clubs capable of surviving beyond the tenure of a single owner.
Birch argued that legal action would not address the sport’s fundamental problem: a financial structure that encourages too many clubs to pursue success by accumulating losses that owners must repeatedly cover.
He described that approach as financially unsustainable.
Birch also said a more balanced and equitable system for distributing revenue from the Premier League would be essential for EFL clubs, noting that the solidarity arrangement has remained unchanged since 2019.
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