ISR-GEM — Evidence Before Opinion

Worked example

Harborough City FC — a well-prepared club ready to proceed

A fictional club with strong governance foundations moves through the full ISR-GEM process and receives an unconditional Proceed to Full Diagnostic recommendation. Every view below is exactly what your Board would see — no sign-in required.

Fictional example. Harborough City Football Club is an invented club. All names, dates, scores and findings are illustrative and do not represent any real organisation.

Club profile & assessment setup

Club / licence holder
Harborough City Football Club
Assessment reference
BRD-PAQ-2026-HCB-001
Assessment date
12 September 2026
Decision date
29 September 2026
Prepared by
ISR-GEM Advisory (Lead Reviewer)
Governance lead
Priya Ramanathan, General Counsel & Company Secretary
Executive sponsor
Gerald Fitzpatrick, Chief Executive
Independent reviewer
S. Aldridge FCA, ISR-GEM Independent Reviewer
Review mode
Independent Advisory Review
Document version
1.0

Executive dashboard

Diagnostic entry decision & readiness scores

Diagnostic entry decision — recommendation

Proceed to full diagnostic

Zero open gateway blockers across all 19 gateway tests. The club has a ratified three-year financial plan, a constituted Fan Advisory Board, a complete annual declaration, and a controlled evidence repository with named owners. Two minor conditions — covenant stress-testing and fan feedback refresh — should be closed during the 30-day window but do not block the full diagnostic.

Open gateway blockers

0

of 19 gateway tests

Gateway partials

2

minor gaps, not blocking

High-priority open items

0

all findings low/medium

Assessment completion

92%

of questions answered

Section breakdown — all nine ISR-GEM sections

SectionTitleYesPartialNoOpen gatewaysProgressPosition
AIFR licensing baseline8000 / 3
100%
Ready
BBoard governance & oversight7100 / 2
90%
Ready
CBoard composition & effectiveness7000 / 2
95%
Ready
DMLC 1 — Financial plan readiness6100 / 3
85%
Ready with conditions
EMLC 2 — Corporate governance statement6000 / 2
92%
Ready
FMLC 3 — Fan consultation5100 / 3
82%
Ready with conditions
GMLC 4 — Annual declaration & notifications5000 / 3
95%
Ready
HEvidence management & assurance6000 / 2
88%
Ready
IContinuous improvement & culture6000 / 1
100%
Ready

Diagnostic evidence readiness

MLC 1–4 evidence position

Evidence-level readiness for each minimum licence condition, drawn from the full diagnostic. Critical gates flag controls that must be demonstrable before licensing.

MLC 1 — Financial plan

85%

0 open gate(s) · 0 blocked

Ready with conditions

MLC 2 — Corporate governance

92%

0 open gate(s) · 0 blocked

Ready

MLC 3 — Fan consultation

82%

0 open gate(s) · 0 blocked

Ready with conditions

MLC 4 — Annual declaration

95%

0 open gate(s) · 0 blocked

Ready

Findings register

Material weaknesses & governance gaps

No gateway blockers. All findings are low or medium priority and none prevent the full diagnostic.

05-01Material WeaknessD04 Medium priority

Three-statement financial model exists but the downside scenario for a 20% broadcast-income reduction has not been stress-tested against the covenant ratio.

Low residual risk; MLC 1 plan is sound but covenant resilience should be evidenced before full diagnostic fieldwork.

Owner: Director of Finance · Target: 20 Oct 2026 · Status: In progress

05-02Governance GapF02 Low priority

Fan Advisory Board meets quarterly but the published feedback loop to supporters was last updated six months ago.

Minor MLC 3 gap; the consultation mechanism is constituted and active but reporting transparency should be refreshed.

Owner: Supporter Liaison Officer · Target: 15 Nov 2026 · Status: Open

05-03Governance GapB06 Low priority

Board effectiveness review is conducted biennially; the Club Code recommends an annual cycle.

Low; a documented rationale is on file but aligning to annual would strengthen the MLC 2 narrative.

Owner: Chair of the Board · Target: 31 Jan 2027 · Status: Proposed

05-04Governance GapH03 Low priority

Evidence repository has named owners and retention rules for 96% of items; four historical contracts pre-2024 lack a designated owner.

Negligible; legacy items should be assigned or archived to complete the index.

Owner: Head of Compliance · Target: 10 Nov 2026 · Status: In progress

Improvement opportunities

Value-add initiatives scored on value vs effort

IOAreaOpportunityExpected benefitValueEffortScoreOwnerStatus
06-01Financial resilienceFormalise a covenant-monitoring dashboard with automated breach alerts linked to the downside scenario library.Demonstrates proactive financial governance and strengthens the MLC 1 narrative.5/52/52.50Director of FinanceAccepted
06-02Fan engagementMove to a real-time fan feedback portal with quarterly published response summaries.Differentiates the club on MLC 3 and deepens supporter trust.4/52/52.00Supporter Liaison OfficerProposed
06-03Board governanceMove from biennial to annual board effectiveness reviews aligned to the Club Code.Removes the only MLC 2 observation and future-proofs the governance statement.3/52/51.50Chair of the BoardProposed
06-04Evidence assuranceAutomate evidence-expiry alerts and add a quarterly compliance dashboard for the Audit Committee.Reduces manual effort and provides continuous assurance between diagnostic cycles.4/53/51.33Head of ComplianceAccepted

Corrective-action plan

Prioritised 30 / 60 / 90-day actions

30-day horizon

  • 07-01Medium

    Stress-test the 20% broadcast-reduction downside scenario against the covenant ratio and document the Board's response.

    Director of Finance · due 20 Oct 2026 · In progress

60-day horizon

  • 07-02Low

    Publish an updated fan feedback loop summary and refresh the Fan Advisory Board reporting calendar.

    Supporter Liaison Officer · due 15 Nov 2026 · Open

  • 07-03Low

    Assign or archive the four pre-2024 legacy contracts in the evidence repository.

    Head of Compliance · due 10 Nov 2026 · In progress

90-day horizon

  • 07-04Low

    Approve the transition to annual board effectiveness reviews and update the governance calendar.

    Chair of the Board · due 31 Jan 2027 · Proposed

  • 07-05Medium

    Deploy automated evidence-expiry alerts and a quarterly Audit Committee compliance dashboard.

    Head of Compliance · due 28 Feb 2027 · Not started

Two-page board briefing note

Print-ready Board report

The document your Board receives — purpose, executive summary, gateway analysis, key findings and the 30/60/90-day plan, with a sign-off block.

ISR-GEM Licence Readiness Pre-Audit

Executive Briefing Note

EBN-BRD-PAQ-001 · Independent Advisory Review · v1.0

RAG: Green
Club / licence holder
Harborough City Football Club
Assessment reference
BRD-PAQ-2026-HCB-001
Assessment date
12 September 2026
Executive sponsor
Gerald Fitzpatrick, Chief Executive
Governance lead
Priya Ramanathan, General Counsel & Company Secretary
Independent reviewer
S. Aldridge FCA, ISR-GEM Independent Reviewer
Prepared by
ISR-GEM Advisory (Lead Reviewer)
Decision date
29 September 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 30/60/90-day improvement plan to close two minor conditions before the full diagnostic commences.

Formal board recommendation

Proceed to full diagnostic

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 strong IFR licensing baseline, a ratified three-year financial plan, a constituted Fan Advisory Board, a complete annual declaration and a controlled evidence repository. Zero gateway blockers are open. Two minor conditions — covenant stress-testing of the downside scenario and a refresh of the fan feedback loop — should be closed during the 30-day window but do not block the full diagnostic.

Assessment completion92% (of questions answered)
Gateway tests21 total · 0 blocked · 2 partial
High-priority open items0
Open material findings4 (all low or medium)
Corrective actions open5 (closure rate 40%)

3. Gateway analysis

No gateway blockers are open. The club passes all 19 gateway tests, with two partials (D04 covenant resilience and F02 fan feedback reporting) that are non-blocking. The full diagnostic can proceed immediately.

  • 05-01 · D04 · Material Weakness

    Three-statement financial model exists but the downside scenario for a 20% broadcast-income reduction has not been stress-tested against the covenant ratio.

    Impact: Low residual risk; MLC 1 plan is sound but covenant resilience should be evidenced before full diagnostic fieldwork. — Owner: Director of Finance, target 20 Oct 2026.

  • 05-02 · F02 · Governance Gap

    Fan Advisory Board meets quarterly but the published feedback loop to supporters was last updated six months ago.

    Impact: Minor MLC 3 gap; the consultation mechanism is constituted and active but reporting transparency should be refreshed. — Owner: Supporter Liaison Officer, target 15 Nov 2026.

  • 05-03 · B06 · Governance Gap

    Board effectiveness review is conducted biennially; the Club Code recommends an annual cycle.

    Impact: Low; a documented rationale is on file but aligning to annual would strengthen the MLC 2 narrative. — Owner: Chair of the Board, target 31 Jan 2027.

  • 05-04 · H03 · Governance Gap

    Evidence repository has named owners and retention rules for 96% of items; four historical contracts pre-2024 lack a designated owner.

    Impact: Negligible; legacy items should be assigned or archived to complete the index. — Owner: Head of Compliance, target 10 Nov 2026.

4. Key findings across MLC areas

AreaYesPartialNoOpen gatewaysPosition
Board governance & oversight7100 / 2Ready
Board composition & effectiveness7000 / 2Ready
MLC 1 — Financial plan readiness6100 / 3Ready with conditions
MLC 2 — Corporate governance statement6000 / 2Ready
MLC 3 — Fan consultation5100 / 3Ready with conditions
MLC 4 — Annual declaration & notifications5000 / 3Ready
Evidence management & assurance6000 / 2Ready

5. Prioritised 30/60/90-day improvement plan

30-day

  • 07-01 (Medium): Stress-test the 20% broadcast-reduction downside scenario against the covenant ratio and document the Board's response. — Director of Finance, due 20 Oct 2026, In progress.

60-day

  • 07-02 (Low): Publish an updated fan feedback loop summary and refresh the Fan Advisory Board reporting calendar. — Supporter Liaison Officer, due 15 Nov 2026, Open.
  • 07-03 (Low): Assign or archive the four pre-2024 legacy contracts in the evidence repository. — Head of Compliance, due 10 Nov 2026, In progress.

90-day

  • 07-04 (Low): Approve the transition to annual board effectiveness reviews and update the governance calendar. — Chair of the Board, due 31 Jan 2027, Proposed.
  • 07-05 (Medium): Deploy automated evidence-expiry alerts and a quarterly Audit Committee compliance dashboard. — Head of Compliance, due 28 Feb 2027, Not started.

6. Sign-off

Board Chair

—

Signature and date

Executive Sponsor

Gerald Fitzpatrick, Chief Executive

Signature and date

Operational readiness aid only. This briefing note does not replace the club's individual licence, current IFR requirements, prescribed templates or portal directions. Controlled document EBN-BRD-PAQ-001 · Reference BRD-PAQ-2026-HCB-001.

Monitoring & closure

Baseline vs current — action verification

Baseline gateway blockers

0

As at 12 Sep 2026

Current gateway blockers

0

No blockers throughout

Action closure rate

40%

2 of 5 actions closed

Closure verification review

ReviewActionEvidence reviewedCompletion verifiedEffectiveness confirmedResidual riskReviewerDate
09-0107-01Downside scenario stress-test model v1.2 and Board memo documenting covenant headroom of 1.8x under 20% reduction.LowIndependent Reviewer26 Sep 2026
09-0207-03Evidence repository index showing all four legacy contracts assigned to the General Counsel with retention rules applied.LowHead of Compliance24 Sep 2026

The journey Harborough City followed

From first screening to the full diagnostic

1

Licence Readiness Pre-Audit

Guided governance review and gateway tests confirm strong foundations with zero blockers.

2

Licence Readiness Diagnostic

Cleared to proceed; evidence-based assessment of governance controls across MLC 1–4.

3

Board Report & Improvement Plan

Minor findings only; two low-priority conditions closed before the full diagnostic.

4

Implementation & Annual Assurance

Ongoing support and annual assurance once the core diagnostic has established demand.

See this with your club's data

Book a confidential walkthrough and we will take your Board through the live diagnostic on your club — or start the Pre-Audit today.