ISR-GEM Licence Readiness Pre-Audit
Executive Briefing Note
EBN-BRD-PAQ-001 · Independent Advisory Review · v1.0
- Club / licence holder
- St. Jude's Football Club
- Assessment reference
- BRD-PAQ-2026-STJ-001
- Assessment date
- 21 September 2026
- Executive sponsor
- Marcus Reeve, Chief Executive
- Governance lead
- Alina Okonjo, Company Secretary
- Independent reviewer
- D. Harlow FCA, ISR-GEM Independent Reviewer
- Prepared by
- ISR-GEM Advisory (Lead Reviewer)
- Decision date
- 8 October 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 prioritised 30/60/90-day improvement plan.
Formal board recommendation
Proceed with conditions
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 sound IFR licensing baseline and board governance foundation. Three gateway blockers remain open across MLC 1 financial-plan readiness, MLC 3 fan consultation and MLC 4 annual declaration, together with material weaknesses in evidence assurance.
| Assessment completion | 69% (of questions answered) |
|---|---|
| Gateway tests | 21 total · 3 blocked · 8 partial |
| High-priority open items | 4 |
| Open material findings | 5 |
| Corrective actions open | 6 (closure rate 0%) |
3. Gateway blocker analysis and critical exposures
Gateway blockers D02 (integrated financial model), F03 (representative fan arrangements) and G08 (Annex C and owners & directors test records) prevent an unconditional recommendation to proceed. Each has a named accountable owner and a target completion date inside the 60-day window.
05-01 · D02 · Gateway Blocker
No integrated three-statement financial model (P&L, balance sheet, cash flow) exists for the MLC 1 financial plan submission period.
Exposure: MLC 1 submission cannot be evidenced; licence condition B exposure and probable regulator information request. — Owner: Director of Finance, target 31 Oct 2026.
05-02 · F03 · Gateway Blocker
Fan Advisory Board terms of reference are unratified and no representative fan arrangement has been formally constituted.
Exposure: MLC 3 fan-consultation requirement unmet; reputational and licence condition C exposure. — Owner: Supporter Liaison Officer, target 24 Oct 2026.
05-03 · G08 · Gateway Blocker
Annex C annual declaration process and owners & directors test records are incomplete for two newly appointed directors.
Exposure: MLC 4 annual declaration cannot be signed with confidence; statutory notification risk. — Owner: Company Secretary, target 7 Nov 2026.
05-04 · H06 · Material Weakness
Evidence repository lacks accountable named owners and retention rules for 31% of indexed items.
Exposure: Evidence assurance cannot be relied upon during full diagnostic fieldwork. — Owner: Head of Compliance, target 14 Nov 2026.
4. Key findings across MLC areas
| Area | Yes | Partial | No | Open gateways | Position |
|---|---|---|---|---|---|
| Board governance & oversight | 6 | 1 | 0 | 0 / 2 | Ready with conditions |
| Board composition & effectiveness | 5 | 1 | 1 | 0 / 2 | Ready with conditions |
| MLC 1 — Financial plan readiness | 4 | 1 | 1 | 1 / 3 | Not ready |
| MLC 2 — Corporate governance statement | 5 | 1 | 0 | 0 / 2 | Ready with conditions |
| MLC 3 — Fan consultation | 3 | 0 | 1 | 1 / 3 | Not ready |
| MLC 4 — Annual declaration & notifications | 4 | 0 | 1 | 1 / 3 | Not ready |
| Evidence management & assurance | 3 | 2 | 1 | 0 / 2 | Ready with conditions |
5. Prioritised 30/60/90-day improvement plan
30-day
- 07-01 (High): Board-approved integrated P&L, balance sheet and cash-flow model with defined perimeter. — Director of Finance, due 31 Oct 2026, In progress.
- 07-02 (High): Ratified Fan Advisory Board terms of reference and constituted representative fan arrangement. — Supporter Liaison Officer, due 24 Oct 2026, In progress.
60-day
- 07-03 (High): Completed Annex C declaration pack and owners & directors test records for all directors. — Company Secretary, due 7 Nov 2026, Not started.
- 07-04 (High): Evidence repository index with accountable owners, retention rules and version control. — Head of Compliance, due 14 Nov 2026, In progress.
- 07-05 (Medium): Complete MLC 2 corporate governance statement covering all five Club Code principles. — Company Secretary, due 28 Nov 2026, In progress.
90-day
- 07-06 (Medium): Board forward agenda and assurance map covering all IFR licence conditions A to D. — Chief Executive, due 19 Dec 2026, Not started.
6. Sign-off
Board Chair
—
Signature and date
Executive Sponsor
Marcus Reeve, Chief Executive
Signature and date