ISR-GEM Licence Readiness Pre-Audit
Executive Briefing Note
EBN-BRD-PAQ-001 · Independent Advisory Review · v1.0
- Club / licence holder
- Northbridge Athletic Football Club
- Assessment reference
- BRD-PAQ-2026-NBA-001
- Assessment date
- 5 October 2026
- Executive sponsor
- Karen Voss, Chair of Trustees
- Governance lead
- Trevor Selby, Club Secretary
- Independent reviewer
- M. Penhaligon FCA, ISR-GEM Independent Reviewer
- Prepared by
- ISR-GEM Advisory (Lead Reviewer)
- Decision date
- 22 October 2026
1. Purpose and decision requested
To seek Board endorsement of the Hold / Remediate recommendation, approval to recruit into the vacant Supporter Liaison Officer and Head of Compliance roles, and authorisation of the prioritised 30/60/90-day improvement plan with external advisory support.
Formal board recommendation
Hold / Remediate — do not proceed to full diagnostic
2. Executive summary and RAG status
The pre-diagnostic identified significant readiness gaps across all nine ISR-GEM sections. Six gateway blockers are open, spanning IFR licensing registration, MLC 1 financial-plan readiness (no three-year plan, no downside scenarios), MLC 3 fan consultation (no mechanism in place) and MLC 4 annual declaration (late submission, missing directors' declarations, unfiled change-of-control notifications). Two critical roles are vacant, and no controlled evidence repository exists. The club is not in a position to proceed to the full diagnostic until the 30-day blockers — registration and declaration resubmission — are closed.
| Assessment completion | 34% (of questions answered) |
|---|---|
| Gateway tests | 21 total · 6 blocked · 3 partial |
| High-priority open items | 8 |
| Open material findings | 10 |
| Corrective actions open | 10 (closure rate 0%) |
3. Gateway blocker analysis and critical exposures
Six gateway blockers prevent any recommendation to proceed. The most urgent are A01 (Board approval), G05 (resource assessment) and G08 (annual declaration evidence), all targetable inside 30 days. D01 and D07 (financial plan and independently reviewed stress tests) require external finance support and a 60-day window. F01 (recognised fan representation) cannot start until the Supporter Liaison Officer role is filled.
05-01 · D01 · Gateway Blocker
No financial plan covering the MLC 1 submission period exists; the club has a one-year operating budget only, with no three-year forecast or sensitivity analysis.
Exposure: MLC 1 cannot be submitted; licence condition B exposure is critical and the regulator will require a remediated plan before any provisional licence is considered. — Owner: Director of Finance, target 30 Nov 2026.
05-02 · D07 · Gateway Blocker
Cash-flow projections do not include a downside scenario for relegation or reduced broadcast income, and there is no documented liquidity buffer policy.
Exposure: Financial sustainability test under MLC 1 will fail; regulator may impose enhanced monitoring conditions or refuse a provisional licence. — Owner: Director of Finance, target 30 Nov 2026.
05-03 · F01 · Gateway Blocker
No structured fan consultation mechanism exists; the club last conducted a supporter survey in 2022 and has no constituted Fan Advisory Board.
Exposure: MLC 3 fan consultation requirement entirely unmet; reputational risk and likely regulator directive to consult before licensing. — Owner: Supporter Liaison Officer (vacant), target 15 Dec 2026.
05-04 · G08 · Gateway Blocker
Annual declaration for the previous period was submitted late and is missing two required directors' declarations; the owners & directors test has not been completed for the majority shareholder.
Exposure: MLC 4 non-compliance; statutory notification risk and potential regulator sanction. — Owner: Club Secretary, target 10 Nov 2026.
05-05 · G05 · Gateway Blocker
Change-of-control notifications for two ownership transactions in the prior year were not filed within the statutory window.
Exposure: MLC 4 notification failure; regulator enforcement action possible. — Owner: Club Secretary, target 10 Nov 2026.
05-06 · A01 · Gateway Blocker
The Board has not formally approved the ISR-GEM Licence Readiness Diagnostic.
Exposure: The diagnostic cannot proceed without a clear Board mandate and formal authority. — Owner: Chief Executive, target 24 Oct 2026.
4. Key findings across MLC areas
| Area | Yes | Partial | No | Open gateways | Position |
|---|---|---|---|---|---|
| Board governance & oversight | 3 | 2 | 2 | 1 / 2 | Not ready |
| Board composition & effectiveness | 2 | 1 | 3 | 1 / 2 | Not ready |
| MLC 1 — Financial plan readiness | 2 | 1 | 3 | 2 / 3 | Not ready |
| MLC 2 — Corporate governance statement | 3 | 1 | 2 | 1 / 2 | Not ready |
| MLC 3 — Fan consultation | 1 | 1 | 2 | 2 / 3 | Not ready |
| MLC 4 — Annual declaration & notifications | 1 | 0 | 4 | 3 / 3 | Not ready |
| Evidence management & assurance | 1 | 1 | 4 | 1 / 2 | Not ready |
5. Prioritised 30/60/90-day improvement plan
30-day
- 07-01 (High): Formal Board approval for the ISR-GEM Licence Readiness Diagnostic recorded in the minutes. — Chief Executive, due 24 Oct 2026, In progress.
- 07-02 (High): Complete the evidence review supporting the intended annual declaration. — Club Secretary, due 10 Nov 2026, Not started.
- 07-03 (High): Complete and approve the assessment of resources needed for current and planned activities. — Club Secretary, due 10 Nov 2026, Not started.
60-day
- 07-04 (High): Board-approved three-year financial plan (P&L, balance sheet, cash flow) covering the MLC 1 submission period. — Director of Finance, due 30 Nov 2026, Not started.
- 07-05 (High): Cash-flow downside scenario library and independently reviewed stress tests approved by the Board. — Director of Finance, due 30 Nov 2026, Not started.
- 07-06 (High): Ratified Fan Advisory Board terms of reference and first formal consultation meeting held. — Supporter Liaison Officer (to recruit), due 15 Dec 2026, Open.
- 07-07 (High): Cloud evidence repository established with named owners, retention rules, version control and expiry alerts. — Head of Compliance (to recruit), due 30 Nov 2026, Not started.
- 07-08 (High): Audit Committee reconstituted and meeting quarterly; board minutes to evidence documented challenge. — Chair of Trustees, due 15 Dec 2026, Open.
90-day
- 07-09 (Medium): Complete MLC 2 corporate governance statement with apply-and-explain position against all five Club Code principles. — Club Secretary, due 31 Dec 2026, Not started.
- 07-10 (Medium): Independent board effectiveness review completed and two independent non-executive directors recruited. — Chair of Trustees, due 31 Jan 2027, Open.
6. Sign-off
Board Chair
—
Signature and date
Executive Sponsor
Karen Voss, Chair of Trustees
Signature and date