1. Introduction
In recent years, there has been a marked rise in the number of clubs with common ownership. Major shareholders are trying to create synergies by bringing several football clubs into one large corporate group. This is called the multi-club ownership (“MCO”) model. While the phenomenon is not new, its growth has accelerated and has forced UEFA to refine and tighten its regulatory framework. One key change is UEFA’s decision to bring forward the assessment date – the deadline by which clubs must comply with the rules against multi-club ownership – from June to March, marking a major shift in approach.
2. Background
The MCO model was already explored in the late 1990s by ENIC, the now majority shareholder of Tottenham Hotspur F.C. Since then, the multi-club strategy has grown in popularity, and the footballing landscape is now dominated by these big multi-club groups. One can immediately think of the Red Bull and City Group, who have been active for several years, but even now with the recent acquisitions by the Saudi Public Investment Fund, this topic has come to the fore again.
According to UEFA’s fourteenth edition of The European Club Footballing Landscape report, published in February 2023, more than 180 clubs worldwide were part of a multi-club structure and over 6,500 players were employed by teams connected to such groups, which amounts to almost a five-fold increase compared to 10 years ago [1].
3. Implications for the integrity of football competitions
Despite several advantages, this multi-club ownership also entails certain risks. Particularly with respect to safeguarding the integrity of football competitions. Besides the fact that almost all national federations or leagues have introduced a ban on having clubs under ownership within the same domestic league, UEFA has also introduced strict rules for its European competitions, being the UEFA Champions League, Europa League and Conference League.
In this regard, Article 5 of the Regulations of the UEFA Champions League attaches several conditions to the participation in relevant competitions by clubs belonging to the same group. First, participating clubs may not hold any participations, directly or indirectly, in other participating clubs, as well as have any influence or involvement in the management, administration or sporting performance of other participating clubs. However, this rarely occurs in practice. It is mainly point (c) of the first paragraph of article 5 that is relevant to current MCO practice in this case, which states that participating clubs should not be controlled by the same individual or legal entity. When it is the case, only one team can participate in the European competition in question.
For a long time, this provision was interpreted flexibly. The UEFA’s Club Financial Control Body (“CFCB”) set precedent by allowing both RB Leipzig and Red Bull Salzburg to participate in the 2017–2018 Champions League after structural changes were made to reduce Red Bull’s “decisive influence” [2]. In subsequent years, too, UEFA allowed affiliated clubs to compete, provided that adjustments were made to ensure a sufficient degree of independence.
Also the 2023-2024 season illustrates this flexible approach. Clubs such as Aston Villa and Vitória Guimarães, Brighton and Union Saint-Gilloise, and AC Milan and Toulouse [3] were all admitted to European competition despite potential conflicts of interest. UEFA accepted their participation on the condition that no transfers would take place between the related clubs during the relevant period, and that their governance structures were modified to eliminate overlapping influence.
UEFA’s willingness to accept remedial measures reached its peak in the summer of 2024. Faced with high-profile cases such as Manchester United and Nice, and Manchester City and Girona, UEFA allowed the clubs concerned to remain in European competition even though their ownership structures would normally have been considered non-compliant with the MCO rules.
This was achieved by transferring shares into so-called blind trusts, with independent trustees taking over all decision-making powers for the affected clubs. These exceptional arrangements were expressly described as a temporary measure, valid only for the 2024/25 competitions, and UEFA clarified that they would not serve as a precedent for future seasons.
In parallel, UEFA’s CFCB issued detailed guidance on the meaning of “decisive influence.” Indicators included holding 30% or more of shares, providing 30% or more of financial support, having governance rights or board positions, or even engaging in repeated player transfers between related clubs. This broadened the scope of the test and made clear that decisive influence would be assessed substantively rather than formally.
4. The cases of Crystal Palace and FC DAC 1904 mark a significant evolution
Recent rulings, concerning Crystal Palace and FC DAC 1904, illustrate an important shift away from the flexible approach of UEFA in previous years.
In this regard, a change in the regulations took place on 7 October 2024. Previously, the assessment of “effective control” was conducted in June, allowing clubs to adapt their structures once they knew whether they had qualified for European competitions. By this shift, however, this assessment date was brought forward to March, meaning that UEFA ensured that compliance had to exist months earlier, long before qualification was confirmed.
Crystal Palace had qualified for the Europa League by winning the FA Cup, while Olympique Lyonnais qualified through Ligue 1. Both were connected through John Textor, who held shares and board roles in each. On 11 July 2025, the UEFA’s CFCB ruled that the clubs were in breach of the MCO rules, applying the decisive influence test strictly as of the new assessment date of 1 March 2025.
Crystal Palace appealed the CFCB decision, but the CAS Award of 11 August 2025 dismissed the appeal, confirming that the new assessment date was valid and binding, and that no restructuring after that date could cure the breach.
Similarly, Slovakian side FC DAC 1904 and Hungarian club Győri ETO FC both qualified for the Conference League. Their shared ownership structure through EEA Holding and overlapping family governance roles brought them within the scope of the MCO rules. On 26 June 2025, the CFCB determined that DAC and Győri ETO did not comply with the MCO rules as of the 1 March assessment date. DAC appealed this decision, but the CAS Award of 14 July 2025 dismissed the appeal, stressing that the dual role of one individual in both clubs established decisive influence beyond doubt and that subsequent attempts to argue independence were irrelevant once the breach existed on 1 March 2025.
5. Conclusion
These cases confirm a fundamental change in UEFA’s approach. Where once UEFA allowed remedial measures – transfers to third parties, blind trusts, or conditional approvals – it now insists on full compliance at the moment of assessment. The shift of the assessment date from June to March is the crux of this new regime. When the assessment took place in June, clubs already knew whether they would participate in European competition and could adapt their structures accordingly. This made it possible to cure conflicts of interest reactively, often at the last minute. By moving the assessment to March, however, UEFA has made it impossible to rely on such reactive solutions. Clubs must now be compliant well in advance of knowing whether they will even qualify for Europe.
UEFA itself has explained [4] that this amendment was introduced not to reduce clubs’ flexibility, but because of the growing complexity of multi-club structures and the need to give the CFCB sufficient time to complete its investigations before the competitions begin. The stated aim is to ensure certainty and smooth organizations of the tournaments.
The practical consequence is undeniable: clubs can no longer wait until qualification is secured to restructure their ownership. CAS has confirmed that only the situation on the assessment date is relevant, and subsequent restructuring is irrelevant. The ability to “cure” conflicts once qualification became certain has therefore been eliminated.
This procedural change is the decisive factor behind the stricter enforcement now being witnessed. It transforms UEFA’s MCO regime from a system that tolerated reactive fixes into one that requires proactive, permanent compliance. The implications for investors are profound: multi-club ownership models must now be structured from the outset with robust safeguards, ensuring that no decisive influence can be exercised across multiple clubs. Temporary mechanisms, such as blind trusts, have been expressly confined to the exceptional 2024/25 season and are no longer acceptable going forward. The combined effect of the new assessment date and the strict stance taken by CAS signals a future in which UEFA’s MCO rules will be enforced rigidly, without room for manoeuvre.
[1] UEFA, “The European Club Footballing Landscape”, 10 February 2023.
[2] UEFA, “Salzburg and Leipzig admitted into UEFA Champions League”, 20 June 2017.
[3] UEFA, “The CFCB renders decisions on multi-club ownership cases for the 2023/24 UEFA club competitions”, 7 July 2023.
[4] UEFA’s circular No.54/2024.