The head of anti-discrimination body Kick It Out says that initial proposals by English football’s independent regulator “put equality, diversity and inclusion on the subs bench”.

The watchdog for the top five tiers of the men’s game is devising a new code of governance, with clubs having to show what they are doing to tackle under-representation of minorities in order to be granted a licence.

In correspondence sent to the independent football regulator (IFR) as part of a consultation process – and seen by BBC Sport – Kick It Out claims that the proposed measures are “inadequate”.

“[It] doesn’t go far enough in addressing the stubborn challenges that the game currently sees,” said Kick It Out chief executive Samuel Okafor.

“We’ve been really clear with the regulator in terms of the gap that currently exists. And the gap is significant.

“We’re really concerned that what we’ve seen in the first proposal, in essence, puts EDI [equality, diversity and inclusion] on the subs bench, [and] maintains the status quo.

“It’s really important that the regulator uses the powers that it has to drive the change that we all want to see.”

Among a series of recommendations, Kick It Out says it wants annual publication of clubs’ workforce diversity data, and every club to have board-level accountability for EDI.

Last month, police confirmed they were investigating after four Premier League players experienced online racial abuse over the course of one weekend, and Okafor said the spate of incidents showed why change was required.

“It should send a message to the regulators [over] the importance of why EDI really matters, why they need to prioritise it, why they need to take it seriously,” he said.

In response, an IFR spokesperson said that it will shortly be launching a second consultation on its licensing policy, “and so it is premature to assert deficiencies in our approach to EDI”.