ISR-GEM Licence Readiness Pre-Audit
Executive Briefing Note
EBN-BRD-PAQ-001 · Independent Advisory Review · v1.0
- Club / licence holder
- Harborough City Football Club
- Assessment reference
- BRD-PAQ-2026-HCB-001
- Assessment date
- 12 September 2026
- Executive sponsor
- Gerald Fitzpatrick, Chief Executive
- Governance lead
- Priya Ramanathan, General Counsel & Company Secretary
- Independent reviewer
- S. Aldridge FCA, ISR-GEM Independent Reviewer
- Prepared by
- ISR-GEM Advisory (Lead Reviewer)
- Decision date
- 29 September 2026
1. Purpose and decision requested
To seek Board approval of the recommended diagnostic entry decision for the ISR-GEM Licence Readiness Pre-Audit and to endorse the 30/60/90-day improvement plan to close two minor conditions before the full diagnostic commences.
Formal board recommendation
Proceed to full diagnostic
2. Executive summary and RAG status
The pre-diagnostic covered all questions across nine ISR-GEM sections, including 19 gateway questions. The club demonstrates a strong IFR licensing baseline, a ratified three-year financial plan, a constituted Fan Advisory Board, a complete annual declaration and a controlled evidence repository. Zero gateway blockers are open. Two minor conditions — covenant stress-testing of the downside scenario and a refresh of the fan feedback loop — should be closed during the 30-day window but do not block the full diagnostic.
| Assessment completion | 92% (of questions answered) |
|---|---|
| Gateway tests | 21 total · 0 blocked · 2 partial |
| High-priority open items | 0 |
| Open material findings | 4 (all low or medium) |
| Corrective actions open | 5 (closure rate 40%) |
3. Gateway analysis
No gateway blockers are open. The club passes all 19 gateway tests, with two partials (D04 covenant resilience and F02 fan feedback reporting) that are non-blocking. The full diagnostic can proceed immediately.
05-01 · D04 · Material Weakness
Three-statement financial model exists but the downside scenario for a 20% broadcast-income reduction has not been stress-tested against the covenant ratio.
Impact: Low residual risk; MLC 1 plan is sound but covenant resilience should be evidenced before full diagnostic fieldwork. — Owner: Director of Finance, target 20 Oct 2026.
05-02 · F02 · Governance Gap
Fan Advisory Board meets quarterly but the published feedback loop to supporters was last updated six months ago.
Impact: Minor MLC 3 gap; the consultation mechanism is constituted and active but reporting transparency should be refreshed. — Owner: Supporter Liaison Officer, target 15 Nov 2026.
05-03 · B06 · Governance Gap
Board effectiveness review is conducted biennially; the Club Code recommends an annual cycle.
Impact: Low; a documented rationale is on file but aligning to annual would strengthen the MLC 2 narrative. — Owner: Chair of the Board, target 31 Jan 2027.
05-04 · H03 · Governance Gap
Evidence repository has named owners and retention rules for 96% of items; four historical contracts pre-2024 lack a designated owner.
Impact: Negligible; legacy items should be assigned or archived to complete the index. — Owner: Head of Compliance, target 10 Nov 2026.
4. Key findings across MLC areas
| Area | Yes | Partial | No | Open gateways | Position |
|---|---|---|---|---|---|
| Board governance & oversight | 7 | 1 | 0 | 0 / 2 | Ready |
| Board composition & effectiveness | 7 | 0 | 0 | 0 / 2 | Ready |
| MLC 1 — Financial plan readiness | 6 | 1 | 0 | 0 / 3 | Ready with conditions |
| MLC 2 — Corporate governance statement | 6 | 0 | 0 | 0 / 2 | Ready |
| MLC 3 — Fan consultation | 5 | 1 | 0 | 0 / 3 | Ready with conditions |
| MLC 4 — Annual declaration & notifications | 5 | 0 | 0 | 0 / 3 | Ready |
| Evidence management & assurance | 6 | 0 | 0 | 0 / 2 | Ready |
5. Prioritised 30/60/90-day improvement plan
30-day
- 07-01 (Medium): Stress-test the 20% broadcast-reduction downside scenario against the covenant ratio and document the Board's response. — Director of Finance, due 20 Oct 2026, In progress.
60-day
- 07-02 (Low): Publish an updated fan feedback loop summary and refresh the Fan Advisory Board reporting calendar. — Supporter Liaison Officer, due 15 Nov 2026, Open.
- 07-03 (Low): Assign or archive the four pre-2024 legacy contracts in the evidence repository. — Head of Compliance, due 10 Nov 2026, In progress.
90-day
- 07-04 (Low): Approve the transition to annual board effectiveness reviews and update the governance calendar. — Chair of the Board, due 31 Jan 2027, Proposed.
- 07-05 (Medium): Deploy automated evidence-expiry alerts and a quarterly Audit Committee compliance dashboard. — Head of Compliance, due 28 Feb 2027, Not started.
6. Sign-off
Board Chair
—
Signature and date
Executive Sponsor
Gerald Fitzpatrick, Chief Executive
Signature and date