An application to lift a stay on the prosecution of Hillsborough match commander David Duckenfield has been adjourned until later this year.
Judge Sir Peter Openshaw granted an application for a voluntary bill of indictment, paving the way for potential criminal proceedings against the 73-year-old, at Preston Crown Court on Monday.
The bill was only granted to allow Duckenfield to obtain legal aid funding for an abuse of process hearing due to be held on April 26, the judge said.
Duckenfield did not appear in court for the hearing.
Last June, the Crown Prosecution Service (CPS) announced plans to charge the former South Yorkshire Police chief superintendent with the manslaughter by gross negligence of 95 victims of the 1989 disaster.
Under the law at the time, there can be no prosecution for the death of the 96th victim, Tony Bland, as he died more than a year and a day after his injuries were caused.
Before Duckenfield can be formally charged, the CPS must apply to lift the stay - halting further legal proceedings - which was imposed by a now-retired judge in 2000 after Mr Duckenfield faced trial in a private prosecution brought by families.
Five other men, including former Merseyside chief constable Norman Bettison, have been charged with offences relating to the disaster and its aftermath.
Ninety-six Liverpool fans died in the crush at the Leppings Lane end of Hillsborough stadium on April 15 1989, as the FA Cup semi-final against Nottingham Forest began.