Case Update: CAS publishes decisions in UEFA multi-club ownership cases involving Crystal Palace, Drogheda United and FC DAC 1904

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The Court of Arbitration for Sport (CAS) recently published its full decisions in three significant cases involving breaches of UEFA’s multi-club ownership (MCO) rules. 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.

“No one may simultaneously be involved, either directly or indirectly, in any capacity whatsoever in the management, administration and/or sporting performance of more than one club participating in a UEFA club competition.” Article 5.01(b) MCO Rules

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, read our previous MCO overview.

“No individual or legal entity may have control or influence over more than one club participating in a UEFA club competition, such control or influence being defined in this context as: […] (iv) being able to exercise by any means a decisive influence in the decision-making of the club.” Article 5.01(c)

In May 2024, UEFA’s Club Financial Control Body (CFCB) issued a circular providing guidance on the meaning of “decisive influence” under Article 5.01(c) (May Circular).

On 7 October 2024, UEFA published a circular informing clubs of a change in the assessment date for the MCO Rules i.e. the deadline by which clubs must comply (October Circular). For the 2023/24 season, the assessment date was 3 June 2024, but for the 2024/25 season the date was brought forward to 1 March 2025.

Crystal Palace FC (CPFC) appeal

Background

CPFC qualified for the Europa League 2025/26 by winning the FA Cup on 17 May 2025. In parallel, CPFC finished 12^th in the Premier League in the 2024/2025 season.

Olympique Lyonnais (OL) finished sixth in Ligue 1 in the 2024/2025 season, thereby qualifying for the Conference League 2025/2026.

On 24 May 2025, Paris Saint-Germain (PSG) won the 2024/2025 Coupe de France. Given that PSG had already qualified for the 2025/2026 Champions League as the winner of Ligue 1, a place in the 2025/2026 Europa League was allocated to OL, being the next highest ranked team in Ligue 1 which had not qualified for the Europa League based on the final Ligue 1 table.

OL noted in its MCO declaration that, on 1 March 2025, Mr John Textor was OL’s ultimate controlling party and ultimate beneficiary, and the President of OL. OL also noted that Mr Textor had an ownership interest, voting rights or membership or other involvement or influence in the management, administration or sporting performance in other clubs, including CPFC.

CPFC also indicated in its MCO declaration that Eagle Football Holdings Bidco Ltd, owned by John Textor, had control or decisive influence over CPFC and other clubs.

On 11 July 2025, the CFCB decided that CPFC and OL did not comply with the MCO Rules as of the 1 March 2025 assessment date.

The MCO Rules provide that, in the case of a breach, the club which finished lower in its domestic league would be removed from the relevant UEFA competition. CPFC was therefore removed from the Europa League.

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, CPFC was admitted to the Conference League 2025/26.

CAS decision

On 21 July 2025, CPFC appealed to CAS, requesting that CAS annul the CFCB’s decision. On 11 August 2025, CAS dismissed the appeal following an expedited procedure. In its full decision published recently, the CAS panel held that CPFC was in breach of Articles 5.01(b) and (c) of the MCO Rules. In particular:

Prohibition on being “involved” (Article 5.01(b))

The CAS panel held that the prohibition in Article 5.01(b) of the MCO Rules has a “wide scope”. In this case, Mr Textor was “involved” in both CPFC and OL:

In relation to CPFC, “holding a position of director and principal partner in the companies which constitute the governing bodies of CPFC, with voting rights allowing Mr Textor to participate in decisions crucial for [CPFC] (such as the club’s strategy, financial planning, players’ transfers, appointment of the coach, etc.), is sufficient to constitute involvement.”

In relation to OL, “Mr Textor was the ultimate controlling party, the ultimate beneficiary, and the President of the club.”

Prohibition on “decisive influence” (Article 5.01(c)(iv))

The CAS panel held that the criteria set out in the May Circular were “sufficient to prove (at least prima facie) the existence of such “decisive influence””. The panel held that Mr Textor was able to exercise a decisive influence on the decision-making of CPFC and OL. The relevant factors were:

• Shareholders’ rights: Mr Textor held more than 30% of the shares in CPFC as at 1 March 2025 through Eagle Football Holdings Bidco Limited (Eagle Holdings) and Eagle Holdings owned 93.95% of OL.
• Financial support: Mr Textor and Eagle Holdings made investments into CPFC’s holding company.
• Governance: Mr Textor held executive positions in CPFC’s governing bodies and was President of OL.
• Player transfers: There were multiple transfers between CPFC and Molenbeek (a club which Mr Textor had a controlling interest in) between summer 2021 and the end of the 2023/24 season.

Competition law

CPFC argued that: UEFA had implemented a discretionary practice allowing clubs to “cure” non-compliance with the MCO Rules after the deadline; and had failed, contrary to EU competition law and the principles set out by the Court of Justice of the European Union in the European Superleague case, to publish any substantive criteria applicable to its discretion to extend the deadline.

The CAS panel held that there was no discretionary practice to extend the assessment date and therefore the competition law arguments were not applicable. Accordingly, the sale of the shares of Mr Textor and Eagle Football Holdings Bidco Limited in CPFC after 1 March 2025 did not constitute a “cure” to the breaches of the MCO Rules.

Even if there had been a discretionary practice, the panel held that the compatibility of the MCO Rules with EU competition law had already been extensively and accurately dealt with in a previous CAS case known as the ENIC Award (CAS 98/200), which the CAS panel in CPFC “fully endorsed”.

The ENIC case established that the adoption of the MCO Rules did not breach EU competition law (i.e. the MCO Rules did not restrict competition ‘by object’; there was no abuse of dominance in the adoption of the MCO Rules; and the MCO Rules are a proportionate means of achieving a legitimate objective).

Outcome

The CAS panel concluded that OL was correctly admitted to the Europa League and CPFC validly admitted to the Conference League, since OL was ranked higher in its respective domestic championship than CPFC.

Additional UEFA MCO appeals

Earlier this year, CAS dismissed appeals brought by Drogheda United FC (DUFC) and FC DAC 1904 Dunajská Streda (DAC) regarding their removal from the UEFA Conference League 2025/26 for breaches of the MCO Rules. For more background on these appeals, read our update on Drogheda here and our update on DAC here.

CAS have also published its full decisions in the DUFC and DAC cases. We summarise on the next page the key takeaways from all three cases.

Key takeaways

• Strict enforcement of MCO Rules: These recent MCO cases emphasise 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.
• UEFA’s communication of the change in assessment date was appropriate: In the DAC and DUFC cases, it was argued that the clubs had a “legitimate expectation” that compliance with the MCO Rules by the relevant assessment date would be applied more flexibly based on previous UEFA practice. This was rejected in both the DAC and DUFC decisions.

“It was clear at the time that the 2024/25 [MCO Rules], which provided for an assessment date of 3 June 2024, only applied for the previous season only. In particular, the May 2024 Circular clearly stated that UEFA would authorise clubs to set up a blind trust as a “temporary alternative […] on an exceptional basis for the 2024/25 UEFA competitions”. Furthermore, the May 2024 Circular expressly stated that “the CFCB First Chamber will not be bound by this alternative when assessing clubs’ compliance with the MCO rule for participation in UEFA competitions in subsequent seasons”. Consequently, no legitimate expectation arose.” Extract from the DUFC decision.

• Wide scope of the meaning of “involved” in a club: This point was emphasised in the CPFC case, where Mr Textor’s position as director and principal partner in companies which constituted the governing bodies of one club (CPFC) and position as President of another club (OL) was, together with other factors such as voting rights, sufficient to amount to “involvement” in multiple clubs. The DAC and DUFC cases did not turn nor rely so heavily on this issue.
• The starting point for assessing “decisive influence” are the indicators in the May Circular: The CAS panel in the CPFC case accepted that the May Circular did not ‘amend’ the MCO Rules but decided that the criteria set out in that May Circular would be sufficient to prove the existence of “decisive influence” (at least on a prima facie basis).
• Competition law: In all three cases, competition law arguments were also raised but summarily dismissed. In the DAC case, the Panel “was not convinced” that changing the deadline date was an abuse of a dominant position. Indeed, the Panel noted that the deadline was “precise (the date change was clear); it was transparent (all member associations and clubs were informed of the change via the October 2024 Circular…with clubs in the [European Club Association] receiving further information from that organisation); the objective remained the integrity of the UCC, however with more clubs in MCO structures more time was required to consider their positions; and the Panel saw no discrimination with this change, the basic rule applied to all clubs that had decided to work within a MCO structure.” The Panel also found no discrimination in the application of the MCO Rules.

Concluding thoughts

With just under three months until the current deadline for compliance with the MCO Rules (1 March 2026), investors should take note of the practical takeaways above and ensure that any proposed MCO model is structured to comply with the MCO Rules in advance of that date, with appropriate safeguards in place to enable potential restructuring.

Clubs, investors and other stakeholders should also continue to monitor any potential changes to the MCO Rules (in particular, the relevant assessment date) and calibrate their approach accordingly, in order to avoid a potential breach of the MCO Rules.