Wrexham manager Phil Parkinson says match officials have been "too eager" in issuing yellow cards following new directives issued over time wasting.
Parkinson will be without striker Paul Mullin and midfielder James McClean for Saturday's League Two visit of Gillingham due to suspension.
Both have accumulated five yellow cards each this season including cautions for offences deemed as time wasting.
"It's a big discussion point at the moment," Parkinson said.
"I think there's work to be done for the powers that be.
"We prided ourselves on not getting too many bookings last year and we were top of the fair play league across the divisions apart from the Premiership.
"But it's so easy to get booked, it really is. The refs are giving out (too many) yellow cards.
"I went through a lot of the yellows with the head of the referees, Mike Jones, and he agreed with me that a lot of them shouldn't have been given.
"So I think the refs have been too eager at times and there has been an inconsistency, that's not just at this level, it's the Premiership level as well."
Directives were introduced by the English Football League (EFL) at the start of the current season with the aim of increasing the amount of time the ball is in play.
"A lot of bookings I discussed were the ones for delaying the restarts and that was a directive to get the ball in play more - anyone delaying the restart would get a yellow," Parkinson told BBC Sport Wales - but they've just gone too far.
"The Mullin booking, when he ran to take a throw-in against Sutton was ridiculous. He ran to pick the ball up to take the throw - George Evans had just passed the ball off the pitch and it was never a booking.
"But once refs get it in their mind that they've been told to clamp down, certainly in the first third of the season, they go overboard and I think that's what you're seeing and it's not just us.
"Of course within those bookings there are ones that can be avoided, but equally there are ones which, if you look at James Mclean against Sutton - where he's got fouled and in the action of him getting fouled James clears the ball and he books him for time wasting - never in a million years
"It's something we've got to deal with. Every manager has got frustrations with officials at the moment."