CAS dismisses appeal by Crystal Palace against UEFA decision regarding non-compliance with multi-club ownership rules

On 11 August 2025, the Court of Arbitration for Sport (CAS) dismissed an appeal brought by Premier League club Crystal Palace FC against UEFA concerning a decision to remove the club from the UEFA Europa League 2025/26, due to non-compliance with UEFA’s multi-club ownership (MCO) rules. The decision follows the recent dismissals of appeals before CAS brought by (i) Drogheda United FC and (ii) FC DAC 1904 Dunajská Streda (DAC) regarding their removal from next season’s Conference League. All three cases have important implications for clubs and investors considering MCO structures in European football.

Background

UEFA, the governing body of football in Europe, has regulations in place for each of the Champions League, Europa League and Conference League competitions. Article 5 of the regulations (the MCO Rules) prohibits two clubs under common ownership, management, control or influence from competing in the same UEFA club competition in a given season.

The MCO Rules are engaged when two or more related clubs qualify to compete in a UEFA club competition in the same season. In the event of such a breach, only one of those clubs will be admitted to the relevant UEFA competition. For further detail on the MCO Rules and recent cases, read our previous updates: detailed overview; update on Drogheda case; update on DAC.

In a circular issued in October 2024, UEFA advised clubs of a change in the assessment date relevant to the MCO Rules. For the 2024/25 season, the assessment date was 3 June 2024, but for the 2025/26 season, the date was brought forward to 1 March 2025.

Facts

Crystal Palace qualified for the Europa League 2025/26 by winning the FA Cup in May 2025. Olympique Lyonnais (OL) qualified for the same competition by finishing sixth in Ligue 1 at the end of the 2024/25 season.

On 11 July 2025, UEFA’s Club Financial Control Body (CFCB) decided that Crystal Palace and OL did not comply with the MCO Rules as of the 1 March 2025 assessment date.
The MCO Rules provide, in the case of a breach, that the club which finished lower in its domestic league would be removed from the relevant UEFA competition. Crystal Palace was therefore removed from the Europa League due to its 12th place finish in the Premier League last season.

Under the MCO Rules, a club that is prohibited from playing in the same competition as a related club may be admitted to a lower-tiered UEFA competition (in descending order: Europa League and Conference League). Hence, Crystal Palace was admitted to the Conference League 2025/26.

Appeal and Decision

Crystal Palace appealed to CAS, requesting that CAS annul the CFCB’s decision. However, on 11 August 2025, CAS dismissed Crystal Palace’s appeal following an expedited procedure. The CAS panel held that:

John Textor had shares in Crystal Palace and OL, and was a board member with decisive influence over both clubs at the time of UEFA’s assessment date.
Crystal Palace had not received unfair treatment in comparison with Nottingham Forest (which is now promoted to the Europa League) and OL.
The MCO Rules are clear and do not provide flexibility to clubs that are non-compliant on the assessment date.

The decision to remove Crystal Palace from the Europa League and admit it to the Conference League was therefore upheld.

Key Takeaways

This recent and high-profile case demonstrates that UEFA is prepared to enforce its MCO Rules strictly and exclude clubs from UEFA competitions if they do not comply – and that CAS is willing to uphold such decisions.

Investors should take note and ensure that any proposed MCO model is structured from the outset to comply with the MCO Rules, with appropriate safeguards in place to enable potential restructuring.

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