Written evidence submitted by the Isthmian
Football League, known as the Ryman Football League
WHO ARE
WE?
The Isthmian Football League—founded 1905 for
amateur players only: professionals were not allowed to play in
the League until 1974 when The Football Association removed the
amateur status. In this submission referred to as "the League".
In 1905 the League had six Clubs—in 2011 the
League has 66 clubs.
In 1973 the League was the first league in England
with a major sponsorship—Rothmans of Pall Mall.
Also in 1973 the League was the first in the country
to adopt three points for a win and to adopt Goal Difference as
opposed to Goal Average for deciding places in a division where
clubs have equal points—both of which have become universally
accepted.
In 1989 the League was the first league outside the
Football League to become a limited company.
The League is positioned at levels 7 and 8 of the
national structure—see Appendix 1.
The League is positioned at Steps 3 and 4 of the
National League System—see Appendix 2.
Our clubs are allocated by The Football Association
on a geographical basis and currently cover an area from Lowestoft
in the East and across through Harlow, Harrow, round to Fleet
in Hampshire, south to Bognor Regis and along the coast to Hastings
and taking in the whole of Kent and Essex back up to Suffolk—see
Appendix 3.
Our highest placed Clubs are promoted to the Football
Conference regional divisions (subject to compliance with ground
requirements) and our lowest placed Clubs are relegated to the
appropriate Senior Feeder League on a geographical basis and are
replaced by clubs from those leagues.
We are a limited company with nine directors of whom
two are independent and seven are on the Boards or Management
Committees of our member clubs. We also have the benefit of Lord
Rosser as a Vice President of the League and he attends all Board
Meetings.
We have a full time Administrator. The present incumbent
has been in the post for six years and has decided to retire.
He will be succeeded in June by our first female League Secretary,
Ms Kellie Discipline, who has an impressive CV in football administration.
We also have a part-time administrator and pay honoraria to the
Chairman and Company Secretary.
We have over 3,500 players registered with the League
of whom only 195 are contract players. Most of our Clubs do not
have the financial resources to have players on contract and,
with it, the commitment to continue to pay them as well as a replacement
player if they suffer a long term injury. The downside of this
is that a player not on a contract can be signed by another club
without a transfer fee being paid.
Many players from our Clubs move on to Clubs in the
Premier League or the Football League. A recent prominent move
was Chris Smalling who was signed by Fulham from Maidstone in
2009 and has since been transferred for a significant sum to Manchester
United.
Our income in 2009 was £269,111 of which the
principal contributions were £87,029 from sponsorship, £38,000
from an FA grant and £58,300 from Clubs by way of subscription.
We spent £247,986 of which £73,148 was given by way
of benefits to Clubs (eg paying for floodlight inspections, pitch
maintenance, public liability insurance and the provision of free
footballs) with £43,543 being paid by way of cash awards
to Clubs and £46,219 on administrative salaries.
QUESTIONS TO
BE CONSIDERED
BY THE
COMMITTEE
Should football clubs in the UK be treated differently
from other organisations?
We say that football clubs are currently treated
differently from other commercial organisations and we believe
that they should continue to be so treated.
Currently there is little adverse effect on a limited
company outside football which suffers an insolvency event; however,
within the football industry it is a very serious matter for a
Club which can result in points being deducted and, in certain
cases, relegation.
Under present provisions, football creditors are
protected and have to be paid in full if clubs want to retain
the position they presently hold in the structure. We do not believe
that this is correct and believe that all creditors should be
treated the same whether they are former employees or local traders
who have provided goods and services for the club.
It is acknowledged that HMR&C lost its preferred
creditor status when the Enterprise Act 2006 came into force and
we believe that the preferred status of football creditors should
now be removed.
Our clubs are community clubs; in many cases they
are a substantial focal point in the community. The vast majority
of our clubs are non-profit making organisations; they are dependent
on local volunteers for the administration of the club, for the
staging of matches (stewards, programme sellers etc) and the running
of sides below the first team. Incredibly our 66 member clubs
provide 746 sides which include junior teams, women's teams, veterans
and disability sides. See Appendix 4.
We are concerned there is not a consistent approach
by local authorities to our clubs. Dartford FC were members of
our league at the time when they received substantial local authority
support and funding to enable them to re-establish themselves
as a focal point in the community through the building of a new
stadium. This assistance enabled the Club to progress from our
Division 1 South to our Premier Division and Dartford FC are now
playing in the Football Conference South. However, there are numerous
other instances where local authorities will not give any support
at all even to the extent of refusing to give business rate relief
to clubs.
The overwhelming majority of our clubs are not fully
amateur and indeed could not survive at the levels we operate
unless some payments were made to managers and players. The levels
are such that a Premier Division side would pay on average wages
in the region of £3,000 per week to its whole team and managers
whereas a team in the regional divisions would pay, on average,
less than a fifth of this. These figures are for the 40 weeks
of the average football season rather than for all 52 weeks of
the year. A number of clubs pay just expenses to players travelling
to matches and a few clubs pay nothing at all and can truly be
said to be amateur clubs.
It can be seen therefore that it is right with the
diverse nature of clubs that they be treated differently from
other commercial organisations.
Are football governance rules in England and Wales,
and the governing bodies which set and apply them, fit for purpose?
Of our current 66 clubs, 38 are limited companies
and 28 are members clubs or other structures such as members clubs,
community interest clubs and community amateur sports companies.
Football Governance Rules are confusing; the overall
body is The Football Association but every club in England must
affiliate to its local county association and without that it
cannot play football in this Country. Some clubs are full or associate
members of the Football Association in addition to being members
of their local county association. Membership of the Football
Association is not seen to be relevant in this regard because
the Governance Rules apply through the leagues irrespective of
whether the individual clubs are full members of The Football
Association.
We believe that there should be clear and unambiguous
lines of reporting and we do not comprehend, particularly with
current technology why there needs to be more than one governing
body and why a club should therefore have to pay more than one
affiliation fee.
This then leads on to the question as to whether
the governing bodies are fit for purpose. County Football Associations
are limited companies themselves but are, in effect, regional
offices of The Football Association and we believe that the roles
and responsibilities of those County Associations should come
under the umbrella of The Football Association. In business parlance,
and in terms of governance, the parent body would be the holding
company and the County Associations would be wholly owned subsidiaries.
This enables the question as to representation on Football Association
Boards and Committees to be reviewed. We believe that there should
be greater emphasis on leagues being represented with a number
of independent appointees to give balance. Most clubs belong to
several leagues (depending on the number of sides they run) as
well as more than one Association and some clubs even affiliate
to more than one county association. We believe that a club should
be responsible to one overall governing body, namely The Football
Association, and the league in which it plays. That way the governing
body can set out the overall structure and the league, working
in harness with the governing body can, if required, apply the
Governance rules.
Is there too much debt in the professional game?
In playing season 2009-10 we were unfortunate to
have two clubs which suffered insolvency events. In the case of
Folkestone Invicta FC they went into a Company Voluntary Arrangement
and as result of that were deducted ten points. The club was still
good enough to win enough points to qualify for the play offs
in our regional division and by winning the play offs were promoted
to our Premier Division; Harlow Town FC were in a similar situation
and as a result of their CVA were deducted ten points and were
placed in a relegation position as a result of this deduction.
However, as a result of other clubs throughout the Country going
into liquidation the club were reprieved from relegation and remain
members of our regional division.
In the current playing season we started with problems
with Croydon Athletic FC which required very careful management
and with great help from the League the club were able to continue
in the Premier Division having gained promotion last season; the
final example we can give is that this playing season we have
Leyton FC who have suffered many financial problems as well as
facing a Court case over the future of their ground and have been
unable to pay monies due to the League. As a result they were
expelled from the League, following a vote by the other 65 Clubs,
at a general meeting held in February 2011.
It could be said that one club in difficulty is one
club too many; we certainly see far too many clubs in financial
difficulties.
We believe that there is too much debt in the game
in general not just the full time professional game. We believe
that what is needed are financial initiatives such as are currently
being exercised by the Football League (in part) and the Football
Conference. We believe that there are two ways of approaching
this, one is to have a salary cap on Clubs and the other is to
have restrictions on budgets. We tend to favour restrictions on
budgets but this, in itself, creates a problem for a League such
as ours because of the cost of the structure required to administer
the enforcement of the requirements.
In recent years the Football Regulatory Authority
has been established and has a degree of autonomy and independence
within the game and has recently shown that it can enforce financial
regulations by the deduction of ten points from St Albans City
FC. We believe that this is a positive but what we believe is
that the procedures must be transparent and must apply to all
so that it is not a case of being "unlucky" to be caught
out. It should apply across the whole game, at the higher levels
as well as the lower levels. It does appear that there are different
rules depending on whether a club is a limited company or not;
for instance the Fit and Proper Persons Test only applies to directors
in limited companies and as we have said earlier we have 28 clubs
which are not limited companies and therefore there is no fit
and proper persons test applied to those clubs. This, in our submission,
is wrong and the fit and proper persons test should immediately
be extended to all clubs down to Step 4.
What are the pros and cons of the supporter trust
shareholding model
We welcome the involvement of all community groups
in our clubs which as we have already said are community clubs.
We do not believe that any one such group should
have either a power of veto or a majority vote over other interests
on the Board or Committee.
Where there is not a full compliance with the supporter
trust shareholding model then the other community interests should
be consultative since it would have a counter-productive effect
on encouraging people to invest in clubs if they could be outvoted
by those not investing their own monies.
Is government intervention justified and, if so,
what form should it take?
The Burns Report was a Government initiative and
has not been fully implemented. We believe that the remainder
of that report should be looked at and the parts which have not
been applied should be further considered. In particular we support
the introduction of independent non-executive directors. We believe
that Government intervention should be limited to getting the
structure right and then leaving the industry to run itself.
In previous years Government funding was available
for improvements in grounds but that has been withdrawn and the
only funding now comes from the Premier League. Whilst the money
is welcome, the fact that it is coming from the Premier league
only strengthens the influence of that body to the exclusion of
what we say should be the governing body, The Football Association.
If Government wants to intervene then it should be prepared to
go back to the time when it committed funds for ground improvements
and for that money to be distributed through FA channels or FA
approved channels.
Are there lessons to be learned from football
governance models across the UK and abroad, and from governance
models in other sports?
It is difficult for us to give any considered response
to this question as we only have experience of the existing Football
Association model and can really only react to that.
We believe from our level of the game that the problem
is that we fall in between the Professional Game Board and the
National Game Board because we are neither fulltime professionals
nor basic grass roots football. As such we believe that there
should be a much clearer and more specific place created for levels
5 to 8 or even levels 5 to 9 so that "grass roots" can
truly be the grass roots levels of the game and we can then deal
with matters which are truly applicable to our respective levels
of the game.
This league wishes to stress and emphasise to the
Committee the point that there is a third level, that is not The
Premier League nor The Football League nor "grass roots"
football played in the parks and that any report on football and
football governance should recognise and reflect that fact.
APPENDIX 1
THE NATIONAL STRUCTURE
| Level 1 | The Premier Football League
|
| Level 2 | The Football League
Championship
|
| Level 3 | The Football League
League One
|
| Level 4 | The Football League
League Two
|
| Level 5 | The Football Conference
National Division
|
| Level 6 | The Football Conference
North & South Divisions
|
| Level 7 | The Premier Divisions of the Isthmian, Northern Premier and Southern Football Leagues
|
| Level 8 | The 6 Regional Divisions of the Isthmian, Northern Premier and Southern Football Leagues
|
| Level 9 | The top divisions of the 14 feeder leagues
|
APPENDIX 2
THE NATIONAL LEAGURE SYSTEM
| Step 1 | The Football Conference
National Division
|
| Step 2 | The Football Conference
North & South Divisions
|
| Step 3 | The Premier Divisions of the Isthmian, Northern Premier and Southern Football Leagues
|
| Step 4 | The 6 Regional Divisions of the Isthmian, Northern Premier and Southern Football Leagues
|
| Step 5 | The top divisions of the 14 feeder leagues
|
| Step 6 | The second divisions of Step 5 leagues and other leagues—17 in total
|
| Step 7 | 42 divisions of various leagues
|
APPENDIX 3
MEMBER CLUBS OF THE ISTHMIAN FOOTBALL LEAGUE AUGUST 2010
PREMIER DIVISION
AFC Hornchurch
Aveley
Billericay Town
Bury Town
Canvey Island
Carshalton Athletic
Concord Rangers
Cary Wanderers
Croydon Athletic
Folkestone Invicta
Harrow Borough
Hastings United
Hendon
Horsham
Kingstonian
Lowestoft Town
Division One North
AFC Sudbury
Brentwood Town
Cheshunt
East Thurrock United
Enfield Town
Grays Athletic
Great Wakering Rovers
Harlow Town
Heybridge Swifts
Ilford
Leyton
Maldon & Tiptree
Needham Market
Potters Bar Town
Redbridge
Romford
Thamesmead Town
Tilbury
Waltham Abbey
Waltham Forest
Ware
Wingate & Finchley
DIVISION ONE
SOUTH
Bognor Regis Town
Burgess Hill Town
Chatham Town
Chipstead
Corinthian-Casuals
Dulwich Hamlet
Eastbourne Town
Faversham Town
Fleet Town
Godalming Town
Horsham YMCA
Leatherhead
Merstham
Metropolitan police
Ramsgate
Sittingbourne
Walton & Hersham
Walton Casuals
Whitehawk
Whitstable Town
Whyteleafe
Worthing
APPENDIX 4
THE BREAKDOWN OF 746 SIDES FROM 66 CLUBS
| Analysis of Club Teams—October 2010
| Total | Senior
Mens
11
| Youth
Under 18/19 | Other
Junior Football
| Womens | Veterans
| Disability |
| Totals | 746 |
115 | 100 | 454
| 47 | 18 | 12
|
| | |
| | | |
| |
| AFC Hornchurch | 5 | 2
| 1 | 2 | |
| |
| AFC Sudbury | 18 | 3
| | 14 | 1 |
| |
| Aveley | 16 | 2
| 1 | 11 | 2 |
| |
| Billericay Town | 7 | 2
| 1 | 2 | 2 |
| |
| Bognor Regis Town | 10 | 1
| | 8 | |
1 | |
| Brentwood Town | 4 | 2
| 1 | 1 | |
| |
| Burgess Hill Town | 3 | 1
| 1 | | 1 |
| |
| Bury Town | 23 | 1
| 3 | 14 | 1 |
1 | 3 |
| Canvey Island | 19 | 2
| 17 | | |
| |
| Carshalton Atheltic | 16 |
2 | 2 | 10 | 2
| | |
| Chatham Town | 11 | 2
| 2 | 7 | |
| |
| Cheshunt | 13 | 3
| 1 | 9 | |
| |
| Chipstead | 15 | 3
| 1 | 11 | |
| |
| Concord Rangers | 6 | 1
| 1 | 3 | |
1 | |
| Corinthian-Casuals | 14 |
2 | | 11 |
| 1 | |
| Cray Wanderers | 13 | 2
| 1 | 10 | |
| |
| Croydon Athletic | 14 | 1
| 2 | 10 | 1 |
| |
| Dulwich Hamlet | 4 | 1
| 2 | | |
| 1 |
| East Thurrock United | 17 |
1 | 1 | 13 | 2
| | |
| Eastbourne Town | 37 | 3
| 2 | 30 | 1 |
1 | |
| Enfield Town | 19 | 2
| | 6 | 11 |
| |
| Faversham Town | 4 | 2
| 1 | | |
1 | |
| Fleet Town | 3 | 2
| 1 | | |
| |
| Folkestone Invicta | 13 |
2 | 1 | 9 |
| | 1 |
| Godalming Town | 3 | 1
| 1 | | 1 |
| |
| Grays Athletic | 11 | 1
| 2 | 7 | |
1 | |
| Great Wakering Rovers | 5 |
2 | | |
| 3 | |
| Harlow Town | 1 | 1
| | | |
| |
| Harrow Borough | 3 | 2
| 1 | | |
| |
| Hastings United | 15 | 1
| 2 | 12 | |
| |
| Hendon | 4 | 1
| 2 | 1 | |
| |
| Heybridge Swifts | 4 | 2
| 2 | | |
| |
| Horsham | 6 | 1
| 1 | 4 | |
| |
| Horsham YMCA | 2 | 1
| 1 | | |
| |
| Ilford | 6 | 1
| 1 | 4 | |
| |
| Kingstonian | 24 | 1
| 2 | 14 | 6 |
1 | |
| Leatherhead | 25 | 3
| 2 | 20 | |
| |
| Leyton | 7 | 1
| 1 | 4 | 1 |
| |
| Lowestoft Town | 5 | 2
| 1 | 2 | |
| |
| Maidstone United | 31 | 3
| 2 | 15 | 4 |
1 | 6 |
| Maldon Town | 17 | 1
| 1 | 15 | |
| |
| Margate | 21 | 2
| 1 | 18 | |
| |
| Merstham | 20 | 5
| 1 | 12 | 2 |
| |
| Metropolitan Police | 5 |
2 | 1 | | 1
| 1 | |
| Needham Market | 3 | 2
| 1 | | |
| |
| Potters Bar Town | 7 | 2
| 1 | 1 | 1 |
1 | 1 |
| Ramsgate | 15 | 2
| 2 | 10 | 1 |
| |
| Redbridge | 5 | 2
| | 3 | |
| |
| Romford | 4 | 2
| 1 | 1 | |
| |
| Sittingbourne | 4 | 1
| 2 | 1 | |
| |
| Sutton United | 3 | 2
| 1 | | |
| |
| Thamesmead Town | 11 | 2
| 1 | 6 | 1 |
1 | 0 |
| Tilbury | 7 | 1
| 2 | 4 | |
| |
| Tonbridge Angels | 13 | 2
| 2 | 9 | |
| |
| Tooting & Mitcham United | 32
| 2 | 3 | 24 |
3 | | |
| Waltham Abbey | 12 | 2
| 1 | 8 | |
1 | |
| Waltham Forest | 1 | 1
| | | |
| |
| Walton & Hersham | 4 |
2 | 1 | 1 |
| | |
| Walton Casuals | 17 | 1
| | 15 | |
1 | |
| Ware | 4 | 1 |
2 | 1 | |
| |
| Wealdstone | 23 | 2
| 3 | 17 | 1 |
| |
| Whitstable Town | 15 | 2
| 1 | 12 | |
| |
| Whytehawk | 24 | 2
| 3 | 18 | 1 |
| |
| Whyteleafe | 12 | 1
| 1 | 9 | |
1 | |
| Wingate & Finchley | 9 |
1 | 3 | 5 |
| | |
| Worthing | 2 | 1
| 1 | | |
| |
February 2011
| 
