Wednesday 2nd November 2022

AST submits evidence to Government review of Women's Football

The Government recently announced a review into the Future of Women's Football. This can be read here.

The AST submitted evidence to this review. Our Board member Zak Wagman, who regularly attends matches at Meadow Park led this work supported by AST member Yoko Gravestock, also a regular attendee at women's matches.

The text of the submission we made is here.

2.1 Homegrown Talent, Club Pathways and Professional Environment*

With the growing strength of the Barclay’s Women’s Super League, more overseas players are adding quality and excitement to England’s domestic game. Offering an elite-level professional environment is crucial to the continued development of these athletes.

· What is the correct balance to ensure the next generation of English women and girls thrive?

· What can be done to strengthen the talent pool across the game and ensure it reflects the cultural diversity of our society?

· What more could be done at a grassroots level and within schools and the education system to ensure girls get a greater level of access to football?

· Player's physical and mental welfare should be a priority. How can access and quality of medical care be improved?

Women's football in England has the potential to, and should be supported to, mirror men's football in this regard: a truly national game that every young person wants to and has access to play, with an elite league at the top of a deep pyramid system that attracts the best talent from all around the world.

There must be investment at a grassroots level so that all girls have the same opportunity to play football in school as every boy does, but also so that every county FA supports amateur or weekend leagues, in the same way that this exists for the men’s game. There are significant issues around access to pitches for women of all ages, and the government and county FAs should develop a process to support the setting up of leagues for women across the country to ensure that everyone in this country has equal access to facilities and equipment.

2.2 Increasing Matchday Attendance*

The UEFA Women’s EUROs delivered record-breaking crowds unlike any women’s football tournament before. We want this interest and excitement to translate into greater matchday attendances across the women’s pyramid.

· How can we grow the fanbase and increase matchday attendance? How can the spectator experience be improved and made accessible to all, while maintaining fan safety as a priority?

There should be a more accessible and equitable structure for access to ticketing at elite level.

This should begin by having segregated or separated areas for home and away fans, to make attending women’s games more of a social element, enabling supporters’ groups to prosper. This would also help with improving the atmosphere at matches which, in turn, makes the games more of a spectacle, for those at the stadium, those watching on TV, and indeed the players. Further to this, as happens in the men’s game, ‘away tickets’ should be available to buy. Currently, an Arsenal fan who would want to attend every away WSL game in a season, would need to register for membership of each of the eleven other clubs in order to purchase tickets. This is unproductive and counter-intuitive to boosting attendance at games. If the away team can sell tickets to its supporters, in a designated away block/section, through its regular ticket sale processes, this would make it much simpler for fans to follow their teams. Some clubs have begun this process, but this must be uniform, rapid and accessible.

Match dates should be reviewed, to ensure that a team’s male and female teams do not play at the same time or, where possible, the same day, as this forces fans to make a choice that they do not want to, or should not need to, and locks out of the game many who would otherwise attend.

This review should extend to kick-off times, as some of the present WSL slots, such as 18:45 on a Sunday evening are not in line with the goal of growing attendance at the game. Given that we know that a significant proportion of attendees are families/children, and these fans are the future of the game, this kick off time significantly restricts those that might otherwise attend from going to matches.

Finally, women’s football should ensure to not go down the route of being beholden to the TV companies and their whims. Currently, men’s football fans have to wait until the 11th hour to know the confirmed and finalised kick off times due to changes for TV appearances. This makes following a football team at home and away excessively and prohibitively costly. There should be a minimum of six weeks’ notice for a change, and ideally longer if the game wants more people to be able to attend.

2.3 Commercial Growth and Broadcasting*

23.3 million peak viewers tuned in across broadcast and streaming services to watch the England v Germany EUROs Final in July. As interest in the game skyrockets, it is crucial we get the balance right between promoting visibility and making Women’s Football financially viable.

· How can we grow the commercial interest in the game, whilst making Women’s football accessible to all? (You might want to think about broadcasting and streaming services, what the optimal broadcasting slots for Women's Football might look like, prize money, use of Men’s stadia, current competition formats etc.)

In order to ensure maximum commercial and broadcast attention, it is important to ensure that women’s football is played at fan-friendly times – so not clashing with men’s football where possible, and in regular slots where fans can get used to expecting to see a women’s game. This is why, for example, continuing the WSL during the 2022 men’s World Cup is such a good idea that will add value. It is, therefore, worth always ensuring that the women’s domestic season plays during men’s international breaks, for example.

Women’s football should be put to tender for broadcast contracts in a way similar to the Premier League, to extract as much value as possible from as many markets as possible, as this money is fed back into improving the game. These tenders should stipulate a requirement on the broadcaster to promote the wider interests of the game and the sales process should seek to ensure some women’s football remains available on free to air television.

Competitions should prioritise sporting merit at all costs. As such, there is a compelling case to increase the number of relegation/promotion spots for the WSL to two, so as to create a genuine battle against relegation/for promotion, as currently this is extremely limited. This will also give more second tier clubs the opportunity to advance to the next level, as often there is one team in the Championship that stands out, and the division becomes a non-contest.

Prize money should be fairly split. Whilst everybody recognises that the women’s game does not have the same earning potential as the men’s game currently, it is important that the prize money is aligned with the increasing commercial attention and, crucially, at all stages, is enough to warrant the team entering the competition in the first place.


2.4 Financial Health*

Women’s football is the fastest growing sport in the UK. To sustain this growth, we need to consider what financial structures and mechanisms can be put in place to ensure the long-term financial viability of Women’s Football across the pyramid.

· Please share your thoughts on how financial sustainability might be achieved. (You might want to consider issues such as salary inflation, support from Men’s clubs etc.)

This is the key area where women’s football can learn from the men’s game so as to ensure that it does not fall down the same path.

The women’s football pyramid must be properly supported by those at the top, as its health is essential to the sustainability and growth of the national game. This should be prioritised through a central allocation toward the women’s game from the FA, Premier League and Football League. Prize money in national competitions, such as the FA Cup, and a significant chunk of the WSL’s broadcast revenue being distributed throughout the lower leagues, is essential to ensure that the pyramid grows and prospers.

As currently stands, all investment by football clubs into their women’s teams should be exempt from Financial Fair Play (FFP) regulations. This incentives investment in the sport, and ensures that clubs are not penalised for good intentions. However, consideration should be given to putting in place maximum amounts that can be spent on the women’s team (in transfers and salaries) to ensure that competitive balance is maintained.

The biggest barrier to financial health and sustainability in football is unscrupulous owners. That is why it is important that all of the recommendations of the Crouch review are fully implemented. In particular, the Owners’ and Directors’ Test needs to be amended to require that all clubs should have two truly independent Non-Executive Directions (NEDs) who meet the standards set out in the 2018 UK Corporate Governance Code; and owners and directors should have to endorse, and be regularly assessed on their compliance with a football custodianship duty which would include effective engagement with supporters.

The current ‘fit and proper’ test is neither fit nor proper, and this is the biggest threat to financial sustainability across the men’s and women’s game.  We would also hope that the addition of two INEDS would see more diversity, including female representation, on Club Boards.

It is important that this system enables all independent women’s teams (i.e. those not partnered with a men’s team at any level) to both survive and flourish. However, the benefits of these partnerships should not be underestimated with regard to access to medical and commercial expertise; equipment and facilities; and wider exposure.

2.5 Facilities*

The number of girls playing football is growing year on year, and the professionalisation and visibility of the Lionesses and domestic leagues is inspiring our next generation to get involved at all levels of the game.

· How can facilities and stadia be maximised to encourage the participation and access of women and girls, and enhance the elite performance environment at a professional level?

· What facilities and infrastructure are needed to increase participation levels in schools, clubs and the wider community?

The AST supports the calls made by the Lionesses that every girl should be given the opportunity to play football at school. There also needs to be a great focus by the Government and the DCMS to offering at least an hour a day of sports activity inside and outside of the school day to all young people.

2.6 Club Structures and Governance*

· Clubs are the beating heart of Women’s Football across the country. Making sure clubs are diverse, financially stable and well-managed is key to the long-term sustainability of the game.

· Are the current governance structures in the Women's game fit for purpose? (You may want to consider issues such as accountability, equality, diversity and inclusion)

Like in the men’s game, proper governance in football should comprise effective representation for fans.

Supporters should be empowered to become shareholders in their clubs, an outcome which would immediately improve governance arrangements by making owners answerable to supporters. Football clubs are too important to be owned by one person, and all clubs should include supporters being represented and involved in the ownership structure as shareholders. Supporters should be given the opportunity to buy at least ten per cent of the equity in their club. By empowering supporters to become shareholders they would be granted both a custodian role and the protections that company law provides. An independent body could determine the fair market price and oversee arrangements for the purchase and sale of shares. All shares would need to hold the same voting rights as those held by the majority owners.

Supporters should be given a greater say in how clubs are run through a ‘golden share’ on major decisions that affect the future of the club or threaten its heritage. Certain protected rights, such as the club’s colours or name, the competitions a club enters and the location of the club’s stadium would be classed as reserved matters and administered through a single special share to which specific rights are attached – a ‘golden share’. This arrangement would be best delivered through changes being made to the articles of association of football clubs. This could be introduced through a change to the WSL rulebook, a new licensing arrangement for clubs, or a change to company law (which already recognises the concept of a golden share).

Arrangements need to be put in place for meaningful and direct engagement between supporters and the owners, directors and executives of their clubs. This engagement must be conducted with openness, honesty and transparency. To help achieve this objective, each club should have an elected supporters’ representative on its board and a formally constituted Supporter Advisory Board with an open agenda and remit. Whatever the ownership structure of a club, we believe that its governance will be enhanced if supporters have a greater understanding of decisions being made and the opportunity to meet with Board members and senior executives to have an input into the key strategic decision-making. The simple objectives of improving information flows and introducing structures in which supporters can be represented does not require any new legislation, but can be introduced by measures within the rule books of the football authorities or through a new licensing regime. Arsenal currently has the Arsenal Advisory Board, and there is reference to the women’s team in its remit but this does not allow for issues to be addressed in detail. AST has already made the case at meetings of this Advisory Board that there should also be a separate, specific Advisory Board for Arsenal Women, or a sub-committee of the Advisory Board specifically focusing on Arsenal Women, to ensure proper and focused representation of supporter interest in the women’s team.

Equality and diversity in all decision making is important and we believe that the Boards of football clubs should demonstrate these principles in their membership and actions.

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