Football Governance - Culture, Media and Sport Committee Contents

Written evidence submitted by The Football Conference



—  The Football Conference was formed in 1979 with 22 Clubs in one National Division (later extended to 24 Clubs).

—  Attained automatic promotion place to Football League (subject to meeting Ground Grading criteria) in 1987.

—  Attained second automatic promotion place to Football League (subject to criteria) from Play-Off system in 2003.

—  Played instrumental role with the FA in the re-structure of the National League System in 2004.

—  Extended Competition to 68 Clubs in three Divisions by the formation of Conference North & Conference South for start of 2004-05 season.

—  2005-06 season—introduced an "Approved Playing Budget" system to monitor member Clubs' expenditure on players' wages against Club turnover.

—  2007-08 After successive sponsorships, concluding with 12 continuous years with Nationwide Building Society, engaged new Title sponsor in Blue Square for three years.

—  2007-08 Engaged new Broadcast Partner (Setanta) for five years. (Broadcaster went into Administration at end of 2008-09 season.)

—  2008-09 season—developed and extended Approved Playing Budget system into a Financial Reporting Initiative to monitor and control debt, particularly Crown debt.

—  2010-11 Renewed Title sponsorship with Blue Square Bet for three further years.

—  2010-11 Engaged with new Broadcast Partner (Premier Sports Television) for three years.

—  2010-11 Support received from The Premier League (PL) and The Professional Footballers' Association (PFA) to organise and manage a Club Community Development Fund. At present 34 member Clubs are involved in scheme encompassing health education; literacy and disabled groups.


—  National Competition.

—  National media exposure—Press, Radio and Television.

—  Excellent working relationship with the Football Association, The Premier League, and The Football League.

—  Observer status on the Professional Game Board.

—  Promotion/Relegation link with Football League.

—  Promotion/Relegation with three Feeder Leagues in National League System.

—  68 Clubs—well established and progressive Clubs representing large areas, towns or cities, in most cases as important a part of local and community life as larger clubs in the Premier League and the Football League.

—  Successful Clubs providing a highly competent level of football in three Divisions of the Football Conference; the FA Cup, eg Crawley Town, and the FA Trophy.

—  Best Players of member Clubs are selected for the England "C" team in European Championship matches.

—  Over 60 England "C" players from the Football Conference have progressed to Football League Clubs.

—  Wrexham FC has frequently had players selected to represent Wales at all levels, including Full Internationals.

—  A Promotion/Relegation agreement between the FC and the Football League has worked well since its establishment 23 years ago.

—  The FC has a successful record of promoting its Clubs to the Football League in a stable condition meriting further promotion, eg Doncaster, Rushden & Diamonds, Wycombe Wanderers and Yeovil Town.

—  The FC had a successful record of returning Clubs relegated from the Football League to their former status, in a "rehabilitated" condition, eg Exeter City, Oxford United and Torquay United.

—  Clubs' development of young talent, eg Stuart Pearce (Wealdstone to Coventry City & England); Graham Roberts (Yeovil Town to Tottenham Hotspur & England); Andrew Townsend (Weymouth to Southampton & Republic of Ireland).

—  Clubs' ability to rebuild playing careers, eg Michael Kightley (Southend to Grays Athletic to Wolverhampton Wanderers); Andy Drury (Luton Town to Ipswich Town).

—  Provides grounding for Managers, eg Nigel Clough (Burton Albion to Derby County), Mark Yates (Kidderminster Harriers to Cheltenham Town), Neil Warnock (Scarborough to Notts. County), Steve Cotterill (Cheltenham Town to Stoke City).

—  Excellent relationships, and financial support with/from the Premier League, the Football League, the Professional Footballers' Association and the League Managers' Association.

—  Professional centralised administration in middle of operating area with small dedicated Staff.

—  Board of Directors & Officers comprising a mix of professional personnel with current and/or past Club & Competition experience together with independent personnel which provides good governance.

—  Representation on the FA Council—two delegates.

—  Established Financial Reporting Initiative to assist Clubs to "live within their means". This Initiative has been very successful at reducing HMRC debt.

—  Nationally known sponsor which is part of internationally known company.

—  Ability to attract Broadcast Partner (Radio & Television).

—  Club Community Development Fund (see above)—funded by PL and PFA.

—  Community Clubs "buddying" with Premier League clubs eg Altrincham with Manchester United & Manchester City.

—  Overseer of strong Football Conference Youth Alliance (68 Clubs) developing education and football.


—  National Competition gives rise to travel difficulties.

—  The Football Conference feels "betwixt & between" the Professional Game and the National Game. With its amalgam of predominantly full-time professional Club in its Premier Division and it predominantly part-time professional Clubs in its North & South Divisions it is the "meat in the sandwich" between the Professional Game and the National Game.

—  Failing Clubs in current economic climate.

—  Part-time/hobby time administration of most Clubs creates communication difficulties and reduces training opportunities that would raise ability to work effectively and efficiently.

—  Clubs without potential or ambition to progress.

—  Clubs losing young players after investing in development, to professional clubs, without receiving compensation.

—  Notwithstanding financial grant aid from the Football Foundation (FF) and the Football Stadium Improvement Fund (FSIF), grant levels have decreased. Funding required to raise ground standards to meet legislative demands, and the requirements for promotion, particularly to the Football League, is difficult for Clubs to find.

—  There is a lack of support for facilities, eg 3G artificial surface pitches, in the FC community of its 68 member Clubs, where these Clubs are well positioned to deliver these projects.

—  Lack of direction from the FA leads over use of artificial surfaces in competition matches leads to confusion, eg selective use in the FA Trophy and FA Cup (not beyond First Round) but use is permitted in European competitions.

—  Funding for Youth Development schemes organised by Football League clubs relegated to the Football Conference cease after two years.

—  In common with all levels of football in Britain there is a lack of ethnic and gender diversity in the administration of the game.


—  Opportunity to call upon governing body and senior football competitions and organizations for help and advice.

—  National competition gives greater scope to sponsors & partners for wider exposure.

—  The FA Cup and the FA Trophy. Clubs welcome the opportunity to play in these competitions and the Football Conference consistently provides both Finalists in the FA Trophy.

—  Premier Division Play-Off Final at Wembley Stadium. The 2009-10 Final attracted 42,669 spectators.

—  Opportunity to extend promotion/relegation agreement with the Football League from the current two Clubs promoted & two Clubs relegated to four each way, in line with arrangement between Divisions within the Football League.

—  Players have the opportunity to represent their country.

—  Opportunity for former Premier League and Football League players to prolong and/or resurrect their careers.

—  The Club Community scheme provides players with the opportunity to identify different career paths.

—  Through the Club, Club sponsors have opportunity to engage with local businesses.


—  Re-structuring in Leagues above taking top Clubs from Football Conference.

—  Current economic climate.

—  Declining interest, eg falling gates.

—  Mass media coverage of most senior Clubs and Leagues.

—  Television coverage and scheduling of senior Competitions.

—  End of season movement of Clubs affects stability and consistency of competition.

—  Rising cost of travel impinges on visiting supporters' ability to travel, thereby reducing attendances.

—  Withdrawal of personal funding provided by ambitious Owners/Directors.

1.  Should football clubs in the UK be treated differently from other commercial organisations?


Football Clubs must be compliant with UK Company Law and meet all their commercial and legal responsibilities.

It is acknowledged football clubs trade, and are often funded, differently to normal commercial organisations. Unlike conventional companies football clubs engage more deeply within their local communities and carry with them the history of the area they represent and long standing allegiances and hopes of their local (and often large) supporter base. Clubs compete against one another in competitions; despite variances in their structure, eg constitution of club, amount of resources available, and size of support. They must, however, meet all liabilities and responsibilities as expected of any other trading company.

Like Companies with responsibilities to shareholders, football clubs have responsibilities to meet with their supporters, communities and fellow participants. The difficulties of cash flow forecasting are understood, where "revenue gathering" home matches can be postponed by inclement weather and opponents having Cup commitments, but these variances are well known within the industry and must be budgeted for. To suggest treating clubs differently from other commercial organisations creates the possibility of treating those trading (and paying their bills) differently from those that are not meeting their creditors in full and in a timely manner. This disparity will affect the competitive integrity of the competition. The FC has adopted financial systems which implement effectively the Competitions belief Clubs should be responsible for all their debts, in full.

2.  Are football governance rules in England and Wales, and the governing bodies which set and apply then, fit for purpose?

The answer to this question is possibly relative to a Competition's position within the game's structure.

Historically, the FA has successfully governed football through a culture of Committees reporting to a Full Council comprising representatives from across the whole football spectrum, but predominantly from County Football Associations. But the game has moved on. Its evolution over the past 20 years has been rapid, particularly since the formation of the Premier League. Competitions, Clubs and participants have become more professional. They have become lean organisations, requiring quick incisive decisions. Levels of bureaucracy, with time consuming decision making processes, slow the fast moving industry football has become.

The progression of the Premier League into an organisation commanding global appeal raising millions of pounds, enables it to fund many aspects of the game and communities. The funding of several community based schemes, as well as many of footballs stakeholders including Competitions (and therefore, indirectly, clubs) puts the Premier League in a position of immense strength, and largely autonomous from the Football Association. The effect has enabled the Football League to reach up with its own development of the Championship, League One and League Two. These organisations comprise the Professional Game Board. Although the Football Conference has observer status on the Board, it heads the remainder of the football structure, under the control of the Football Association's National Game Board.

The Football Conference understands this position and welcomes the involvement from the FA. The Competition worked closely with the FA to restructure the National League System in 2004. But the Competition now has 19 of its 24 Premier Division Clubs with a full-time playing staff. Its Premier Division is required to comply with many regulations, including FIFA dictates, with which no other Competition in the National League System (NLS) needs to comply. The Football Conference has reached the stage where it, too, needs to reach up. It requires a degree of autonomy from the NLS, within its Rules and procedures, to fulfil its responsibilities and objectives.

The Football Conference feels it is "the meat in the sandwich", between the Professional Game and the National Game. The Burns Report addressed the organisation of the game and it was left to the FA to implement the recommendations. The FC would like to see the Report fully implemented.

The FC is content when matters of governance arise, that may concern it, they are dealt with fairly, but procedures could be made leaner to increase the efficiency and effectiveness of decisions.

3.  Is there too much debt in the National Game?

There is nothing wrong with debt, eg borrowing money, providing resources are in place (or are expected to be in place) to repay it. Put another way, "there is nothing wrong in paying your bills". For this reason the FC does not accept "football creditors" should receive preferential treatment. Football clubs have as great a duty to ensure their suppliers, HMRC, and other creditors are treated as fairly as narrowly-defined football creditors.

Whilst the national debt has increased the FC has recognised its responsibilities to ensure a financial "level playing field" exists for all its members. Any Club not meeting is financial responsibilities gains a pecuniary advantage over its competitors by having funds available for other purposes, eg for better players, thereby gaining a competitive advantage.

The FC has installed a quarterly reporting system whereby expenditure on players' wages can be compared with turnover. Furthermore, in conjunction with HMRC the FC monitors the payment of Crown debt. The aims of the FC initiatives in this respect intend to prepare Clubs for the rigours and risks of the game: encourage Clubs to live within their means and become financially sustainable entities; and to ensure, should promotion be achieved, they are prepared for the increase in costs a higher level of the game will inevitably bring.

There are many examples of Clubs going into Administration and incurring a deduction of points. In the case of the FC, Clubs have been relegated from the Competition for failing to comply with the League's financial procedures. If Clubs fail to observe the above measures, which are intended to prevent financial failure—which affects the integrity of the Competition—it may be time to consider more vigorously, cost management systems in relation to turnover, eg expenditure on the playing squad.

Whilst there have been financial calamities and chaos in some quarters, football clubs are notably robust. They have a good survival record. With the help of support from their communities they continue to play the game, even at an appropriate level, should circumstances and legislation dictate they cannot sustain the level they were once at.

The FC proposes to continue it endeavours to create sustainable Clubs and supports the regulatory changes emanating from the "top" of the Game.

4.  What are the pros & cons of the Supporter Trust share holding model?

We are all Supporters, in some way shape or form. Supporters' Clubs have always been around, raising income to support their Clubs in a tangible way.

Supporters' Trusts (ST) often start from adversity, eg as a protest or as a result of a Club's failure. There are examples of ST being emotional and passionate but without the necessary financial input, responsibility, skills and experience. On the other hand a ST's run Club is controlled by one of the key communities it serves, ie the fans. The Club cannot be sold or mortgaged without the agreement of the fans. And where a Club has land of its own, asset strippers cannot benefit. Fans have a closer involvement in how the Club is run, and with key decisions, meaning greater "buy in" and ownership. Oversight by fans is more likely to prevent financial over-commitment in search of success and the stronger links to the Clubs brings greater benefits to the community. Every Club is, however, unique. Their constitutions are different: one size does not fit all. Any proper business model can achieve success, if run correctly. The FC does not advocate any model in preference to another.

Many Clubs endeavour to live beyond their means: mortgaging their future in search of success; reluctant to play at the level their resources more reasonably suit. Promotion and relegation are the life blood of the modern game, in which Clubs require considerable sums to survive, let alone progress.

Football is a disease, incurable in many cases. Supporters are proud of their Clubs; their allegiance stays with them for life; they want to "belong" to their Club. But they also want success. Supporters and Supporters organisations want to be part of a successful Club and have been known to raise funds for the purchase of a player. They are less well known to raise funds for that player's wages and are less likely to want to share in the losses their Club makes. Several professional Clubs now have a member of the Supporters' Club or Trust on its main Board, making a valuable contribution.

The game, however, is unique in terms of business models and there are many ownership styles. There will always be exceptional Supporters' Trust shareholding models arisen from failure or an offshoot of legal intervention, eg Exeter City and AFC Wimbledon. No two models are necessarily the same. Whilst Supporters' Direct was set up following the Task Force recommendations, Government has since ceased its financial support.

Supporters are the lifeblood of football and the FC supports and encourages their involvement in whatever way best fits the circumstances of each Club. Supporters Trusts are one important option available to supporters who wish to become more involved. The FC welcomes this.

5.  Is Government intervention justified and, if so, what form should it take?

Intervention, no. Participation, guidance, advice and tangible help, as a result of joint discussions amongst agreement involvement of all major stakeholders, most certainly yes.

The above should be on the understanding the FA and the major competitions accept the findings of such a Commission and agree implementation. Representation from the Professional Game, the present National Game, and Education, as well as selected individuals must be included.

6.  Are there lessons to be learned from football governance models across the UK and abroad, and from governance models in other sports?

Financing large increases in salary costs has dramatically affected football, and other sports, within the UK and Europe. Whilst in the USA salary/squad "capping" of these costs has been effective in the management of major sports. The UK has several foreign Club owners and many more players from overseas that have influenced the higher levels of football, whilst the lower levels are drawn into the spiralling cost culture, or simply follow bad examples.

Football, it seems, is reluctant to look seriously at examples in other sports which may, if properly tested, positively influence the game, eg sin bins in hockey & rugby, 10 yard advancement of free kicks for dissent, technology. Maybe there is not a lot wrong with the game, certainly nothing that cannot be put right. But football must not be insular in seeking solutions for its perceived problems, or simply keeping apace with development and/or the demands of the spectator. Football should look outward to keep the game interesting, safe and comfortable for all its stakeholders. Perhaps the vehicle expressed in the answer to question 5 will provide the mode, but there has to be the will to provide the way.

February 2011

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© Parliamentary copyright 2011
Prepared 29 July 2011