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The head of anti-discrimination body Kick It Out says that initial proposals by English football’s independent regulator “put equality, diversity and inclusion on the subs bench”.

The watchdog for the top five tiers of the men’s game is devising a new code of governance, with clubs having to show what they are doing to tackle under-representation of minorities in order to be granted a licence.

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In correspondence sent to the independent football regulator (IFR) as part of a consultation process – and seen by BBC Sport – Kick It Out claims that the proposed measures are “inadequate”.

“[It] doesn’t go far enough in addressing the stubborn challenges that the game currently sees,” said Kick It Out chief executive Samuel Okafor.

“We’ve been really clear with the regulator in terms of the gap that currently exists. And the gap is significant.

“We’re really concerned that what we’ve seen in the first proposal, in essence, puts EDI [equality, diversity and inclusion] on the subs bench, [and] maintains the status quo.

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“It’s really important that the regulator uses the powers that it has to drive the change that we all want to see.”

Among a series of recommendations, Kick It Out says it wants annual publication of clubs’ workforce diversity data, and every club to have board-level accountability for EDI.

Last month, police confirmed they were investigating after four Premier League players experienced online racial abuse over the course of one weekend, and Okafor said the spate of incidents showed why change was required.

“It should send a message to the regulators [over] the importance of why EDI really matters, why they need to prioritise it, why they need to take it seriously,” he said.

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In response, an IFR spokesperson said that it will shortly be launching a second consultation on its licensing policy, “and so it is premature to assert deficiencies in our approach to EDI”.

‘Inadequate given its duties’

Established to improve clubs’ financial sustainability, the IFR was the key recommendation of a fan-led review published in 2021.

The review also concluded that improving diversity was “a key aspect of driving better business decisions by football clubs”.

Kick It Out says this is “a golden opportunity to raise standards across the football pyramid and ensure clubs truly reflect the communities they serve”.

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But in its submission, it also claims it has received legal advice that “supports the view that the IFR’s current proposals for EDI are inadequate given its duties under the Football Governance Act 2025 and Public Sector Equality Duty”.

Okafor said the IFR’s initial proposals might be explained by “a lack of awareness of the significant challenges that exist”.

Key recommendations

Kick It Out told the IFR that “persistent under-representation across senior leadership and coaching roles is underlined” by workforce diversity data published for the first time last year.

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The submission states that data shows in the Premier League, 22% of roles in board and senior leadership teams are women, 3.2% are from ethnically diverse backgrounds, 0.9% have a disability and 0.3% are from the LGBTQ+ community.

“Senior coaching role figures are worse, and regarding overall workforces across the 92 Premier League and English Football League (EFL), only a handful of clubs match local census data across these four demographics,” said Kick It Out.

The organisation adds that since the publication of EDI data was made mandatory by the FA as a result of clubs failing to meet targets on the diversity of non-playing staff, there have been differences in the detail provided, and “very few clubs openly publicised the data”.

Kick It Out wants the information standardised across clubs, made more accessible, and for the IFR to publish an annual EDI benchmarking report.

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It also says that rather than every two years as proposed, annual publication “is critical for accountability, visibility and consistent progress”.

It added: “Football’s slow progress on EDI is strongly linked to weak governance structures and a lack of strategic oversight from club leadership.”

Kick It Out says the IFR should “embed EDI as a core regulatory objective, and establish an advisory board to evaluate club performance”.

The regulator’s response

An IFR spokesperson said: “Equality, diversity, and inclusion is a key element of the Football Governance Act, and the IFR will continue to listen and adapt its policies to affect the change required across football.

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“The IFR is currently developing EDI policy for the 116 regulated clubs it oversees and is engaging extensively with organisations such as Kick it Out to ensure best practice.

“We welcome Kick It Out’s views and will give full consideration to their legal advice.”

The IFR’s second consultation on licensing, which will be published later this month, is expected to include a recommendation that clubs have board-level accountability for EDI.

However, officials are said to be mindful of ministers’ desire for a proportionate and ‘light-touch’ approach, and at this stage, clubs are likely to be allowed to set their own targets and benchmarks on workforce data, and to issue reports every two years.

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