Following my two earlier articles on UEFA multi-club ownership (MCO) regulations, this topic has seen further developments, both in terms of the regulatory framework itself and in recent decisions issued by UEFA and the Court of Arbitration for Sport (CAS).
To briefly recap, for the 2024/25 season, proceedings were opened in cases concerning several clubs (Girona FC (Spain) and Manchester City FC (England); Manchester United FC (England) and OGC Nice (France)) due to potential multi-club ownership conflicts.
In those cases, the clubs/investors implemented significant structural changes (blind trusts, removal of board representation, and separation of operations) which were accepted by the UEFA Club Financial Control Body (CFCB), and the clubs were permitted to participate in UEFA competitions.
Since then, UEFA has slightly revised the MCO regulations (for the 2025/26 season):
- as per the revised wording of Article 5.01, the assessment date was moved to 1 March preceding the competition. In other words, clubs/investors should ensure their structures are finalized well in advance of the new assessment date if there is a possibility that multiple clubs in their network could end up in the same UEFA competition.
- the revised Article 5.05 introduces greater flexibility – if two clubs qualify for different UEFA competitions (e.g., one in the Champions League, the other in the Europa or Conference Leagues) then the risk is lower — but the integrity requirements still apply.
For the ongoing 2025/26 season, the UEFA CFCB First Chamber initiated two noteworthy proceedings, one regarding Győri ETO FC (Hungary)/FC DAC 1904 Dunajská Streda (Slovakia), and the second regarding Crystal Palace FC (England)/Olympique Lyonnais (France).
In the DAC/Győri case, the CFCB found a breach of Article 5.01 of the MCO Regulations and as a result accepted Győri ETO’s admission to the 2025/26 UEFA Conference League but FC DAC was denied entry to the same competition.
In a nutshell, DAC and Györi were found to have overlapping governance through EEA Holding B.V., a financial holding company. The most notable concern involved one individual who simultaneously served as Managing Director of Györi and as CEO of DAC. UEFA concluded that such overlap allowed for potential influence across both clubs. As both clubs finished fourth in their respective domestic leagues last season, the rule that the club from the country with the lower UEFA coefficient is excluded, applied. DAC was therefore removed as Slovakia has a lower coefficient than Hungary.
DAC appealed to the CAS and argued that UEFA had improperly advanced the assessment date from 3 June 2025 to 1 March 2025 without adequate justification and that the ownership structure posed no real risk of influence or control.
The CAS Panel unanimously upheld UEFA’s position. Not only did it confirm that UEFA’s change in the assessment date was within its regulatory discretion but, more significantly, it determined that DAC had violated MCO rules by enabling a situation where one person could exert decisive influence over two clubs competing in the same UEFA competition. This CAS decision further clarifies that the MCO regulations do not require evidence of actual influence—only the potential for it. This principle lies at the heart of the CAS decision and is critical to ensure fair competition.
In the second case, involving Crystal Palace FC and Olympique Lyonnais, both clubs qualified for the Europa League, however the same investor (Mr John Textor, via his company Eagle Football Group), had significant ownership stakes in both clubs (a majority in Lyon and more than 40% in Crystal Palace).
In July 2025, the CFCB concluded that as of 1 March 2025, the multi-club-ownership regulations had been breached by the two clubs because the same individual had a significant stake and influence in both clubs, and that the required restructuring or removal of the conflict had not been completed by the deadline (1 March).
As Lyon finished higher in the relevant season in their domestic league than Palace did in the Premier League, the admission of Crystal Palace to the 2025-26 Europa League was denied; instead the latter was admitted to the 2025-26 UEFA Conference League.
Both cases demonstrate that UEFA is prepared to enforce its MCO rules strictly and exclude clubs from UEFA competitions if they do not comply with them. Ownership and control structures must be fully compliant as of the assessment date (1 March) and remain so throughout the season. Investors are therefore required to ensure that any proposed MCO model is properly structured to comply with the MCO Rules.
It is sure that UEFA will keep an eye on this issue. In a recent interview with Politico, Mr Ceferin, the UEFA President, stated that MCO is something that UEFA will have to deal with and that the correct balance needs to be found. As Mr Ceferin mentioned “to forbid it completely means that you will push the investors out of football. To allow two clubs to be owned by the same owner and play the same competition is a no-go for us because of the credibility of the competition. The moment we lose credibility of competition, we lose everything.”.
