Some clubs are using a "loophole" in a regulation aimed at increasing the number of black managers in football, says Troy Townsend from anti-discrimination charity Kick It Out.
The English Football League (EFL) has a policy - informally known as the 'Rooney Rule' - that clubs must interview at least one black, Asian and minority ethnic (BAME) candidate for a managerial vacancy.
But that is not necessary if they do not have a shortlisting process and interview only one candidate.
"I'm not saying clubs are not following a process but they aren't nailed on to a process because there is a little bit of a loophole there," said Townsend.
"You aren't going to be held accountable. It's like dipping your toes in without going to swim."
After an 18-month pilot, the EFL introduced the policy "for all first-team vacancies" last summer - after clubs voted in favor - becoming the only league in Europe to do so.
It said at the time it hoped the policy would "help address the under-representation" and would be "mandatory when clubs consider multiple applicants for a role".
Townsend added: "If we are going to implement these types of changes then we have to be thorough in the process of what we are doing. Then we also have to release the data around it."
There are six BAME managers across the 91 clubs in the Premier League and EFL.
Townsend said that figure was "absolutely disgraceful considering the number of players there are in the game that has also transitioned into coaching and are qualified".
The 'Rooney Rule' regulation is named after the NFL diversity committee chairman Dan Rooney, who spearheaded a policy that clubs in American football should interview at least one BAME candidate for each head coach or senior football operation vacancy.
But Townsend said it has not always led to an "open recruitment process" in football.
"All we are asking for is one person in that process," he said. "But if they have already got designs on somebody they can appoint that person and they aren't actually breaking that mandatory code rule."
The Premier League has not adopted the 'Rooney rule' - and it was reported last week that it has no plans to do so.
Townsend said: "If you're not going to take it on the whole hog then you don't take it on, or you amend it so that actually 91 clubs are involved and we see the figures and facts come out.
"I have my reservations about it. I've always had them. If it's not covered by all then it can't be a good thing.
"People can level whatever criticism they want at me - the stats speak for themselves."
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