I've been following football governance cases for years, and the recent CAS ruling in Crystal Palace Football Club v. UEFA, Nottingham Forest FC & Olympique Lyonnais (CAS 2025/A/11604) feels like a pivotal moment.
It's not just about whether Crystal Palace (CPFC) gets demoted from the UEFA Europa League (UEL) to the UEFA Europa Conference League (UECL).
At its core, this dispute highlights the tensions in today's game: sprawling investment groups snapping up clubs across borders, all while regulators like UEFA try to safeguard the sport's competitive integrity.
CPFC challenged UEFA's call that it violated multi-club ownership (MCO) rules due to shared links with Olympique Lyonnais (OL), arguing the decision was overly rigid. UEFA, backed by Nottingham Forest (as a potential beneficiary of any reshuffle) and OL itself, held firm. The CAS Panel ultimately sided with UEFA. Still, the reasoning offers plenty of food for thought on how these rules are evolving.
Let's rewind a bit. The case stems from CPFC and OL both qualifying for European competitions in the 2025/26 season, only for UEFA's Club Financial Control Body (CFCB) to flag an MCO issue. Under Article 5.01 of the UEFA Club Competitions Regulations (UCC Regulations), which govern the UCL, UEL, and UECL, no entity can control or exert "decisive influence" over more than one club in the same tournament. The rule aims to prevent conflicts, like one owner subtly favoring one club over another in transfers or tactics.
UEFA had tweaked the timeline for compliance ahead of this season. In October 2024, they issued a circular moving the assessment date forward to March 1, 2025 (from June the previous year), giving themselves more breathing room to investigate complex ownership webs. Clubs had to submit MCO declarations by mid-March, detailing their structures and any overlapping influences. CPFC's filing painted a picture of a tangled setup: Palace Holdco UK Limited as the ultimate controller, with Palace Manageco LLP (a Delaware entity) as beneficiary. The board included Stephen Parish (executive chairman and minority rep), John Textor (majority shareholder rep), David Blitzer, and Josh Harris. Textor, crucially, held a 65.4% stake in Eagle Football Holdings, which owned 93.95% of OL's parent group, plus stakes in other clubs like Botafogo and Molenbeek. Blitzer had his own portfolio through entities like GFH, spanning Brondby, Estoril, and Augsburg. Harris Blitzer Sports & Entertainment (HBSE) and Eagle Football Holdings Bidco were flagged as having potential control or influence over CPFC and others.
OL's declaration echoed similar ties via Eagle. Nottingham Forest, as the next-in-line English club for a European spot, joined as a respondent, likely to protect their interests if CPFC's appeal succeeded.
Article 5.01 isn't groundbreaking on its face. It's been around in some form for ages. But UEFA's enforcement has toughened up. The provision sets out prohibitions on shared management, operations, or any form of control/ decisive influence. The Panel zeroed in on subsections (b) and (c), particularly the "decisive influence" prong in (c), which captures situations where an entity "is able to exercise by any means a decisive influence in the decision-making of the club."
What really sharpened the rule's edge was UEFA's May 2024 circular from the CFCB First Chamber. It laid out indicators for decisive influence across four buckets: shareholding (e.g., 30% plus of shares/ votes, or 10% plus if you're the largest holder), financial support (like loans or guarantees hitting 30% thresholds), governance (board seats, veto rights, or key appointment powers), and player transfers (three or more deals in a season, or scouting contracts that tilt decisions). CPFC argued this circular effectively rewrote the regulations without proper approval, but the Panel brushed that aside. They saw it as a practical guide, not a binding amendment, something to promote "predictability" in a rule meant to nip integrity risks in the bud before matches kick off.
In my view, this makes sense from a regulatory standpoint. Football calendars are locked in early. You can't have clubs litigating ownership mid-season without chaos. The Panel emphasized that the circular was built on CFCB precedents since 2021, adapting to "new forms of cooperation and influence." It's a broad interpretation, sure, but one that prioritizes substance over form.
CPFC's main pitch was that UEFA hadn't shown any real coordination or harm, just structural overlaps that didn't translate to on-the-pitch issues. They leaned on the idea that "decisive influence" requires proof of actual exercise, not mere capability. The Panel wasn't convinced. Drawing on the rule's wording, "being able to exercise by any means," they held that the test is about capacity, not conduct. Why? Because the goal is preventive: to eliminate even the risk of undue sway.
The facts stacked against Palace. As of March 1, 2025, Eagle Football Holdings' fingerprints were everywhere: major stakes in OL and significant shares/ votes in CPFC's holding structure. Textor's dual roles (director at Palace, chairman/ CEO at OL) triggered governance indicators outright. Even without concrete evidence of meddling, these links crossed multiple thresholds. The Panel noted that if indicators like these are hit, decisive influence is presumed, shifting the burden to the club to rebut it. CPFC couldn't.
CPFC invoked the 2017 Red Bull case (Salzburg and Leipzig), where UEFA allowed both clubs in despite shared branding, arguing it showed flexibility. But the Panel distinguished it sharply: that decision hinged on an older, narrower rule focused on formal "control" via legal ties. Today's Article 5.01(c) casts a wider net, explicitly targeting informal influence that could arise structurally. It's a sign of the times. Ownership models have globalized, and UEFA's scrutiny has followed suit. We're moving from reacting to scandals to preempting them, policing "risk" rather than just "results."
Another angle CPFC pushed: even if there was a breach, UEFA should have let them fix it post-deadline, perhaps via a blind trust or share sale, as allowed in the 2024/25 transition year. The May circular had offered a one-off grace for clubs caught off-guard, but the Panel confirmed it was exceptional and didn't apply here. For 2025/26, the March 1 cutoff was ironclad, no discretionary mulligans. Allowing late cures, they reasoned, would incentivize clubs to drag their feet, disrupting tournament planning. Timing, in the end, sealed Palace's fate: OL got the UEL nod, CPFC the UECL demotion.
This award isn't just a win for UEFA. It's a blueprint for tighter MCO enforcement. Clubs in multi-entity groups (think City Football Group or the growing American investor stables) now face forensic scrutiny of their ecosystems, not just isolated operations. Transparency in structures, from boardrooms to balance sheets, is non-negotiable.
For emerging markets like India, where football investment is picking up steam (ISL expansions and foreign tie-ups), there are clear takeaways. First, build regulatory savvy into your strategy. Understand MCO rules before chasing continental spots in AFC tournaments. Second, prioritize clean ownership charts. Cross-border portfolios can boost resources but invite headaches. Third, player markets and competitions will increasingly reflect these global networks, so adaptability is key. Pair this with Financial Fair Play precedents, and it's essential reading for any Indian club eyeing Asia or beyond.
As a lawyer who's pored over similar disputes, this case underscores how football's business side is outpacing its traditions. The Panel's message is clear: if owners innovate with complex structures, regulators will counter with sharper tools and expect compliance on their timeline. CPFC might feel hard done by, but the ruling protects the game's credibility. In an era of billionaire-backed empires, that's no small feat. If you're advising clubs, stress proactive audits. The alternative is learning the hard way, like Palace did.
About the author: Ujwal Trivedi is a Partner of Manilal Kher Ambalal & Co. He is also a Licensed FIFA agent.
Disclaimer: The opinions expressed in this article are those of the authors. The opinions presented do not necessarily reflect the views of Bar & Bench.
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