Multi-Club Ownership (MCO) - Regulatory developments and practical guidance – Ahead of the Game: Sports Horizon Scanning 2026

Investment in sport has surged in recent years, and football has seen a notable rise in MCO structures across Europe, now involving over 200 UEFA clubs and nearly 400 worldwide, with numbers set to grow. 

While MCO structures may be appealing to clubs and investors as they allow for economies of scale, centralised costs, operational synergies, and player development opportunities for clubs within a MCO structure, they raise important regulatory considerations. 

What’s happened in 2025? 

The summer of 2025 highlighted the risks of non-compliance, as several clubs were denied access to European competitions for breaching UEFA’s MCO rules. In November 2025, the Court of Arbitration for Sport (CAS) published decisions in three significant cases involving breaches of the MCO Rules. We set out below the key points from these awards, which provide critical guidance on UEFA's enforcement approach, before outlining practical steps clubs should take to navigate the MCO landscape in 2026 and beyond.

Key developments and predictions for 2026

CAS Awards: The 2025 MCO trilogy

CAS 2025/A/11604: Crystal Palace FC (CPFC), Nottingham Forest FC (NFFC), and Olympique Lyonnais (OL)

This was the most high-profile of the three CAS awards. Bird & Bird acted for NFFC in this matter.

The procedural history was as follows:

• On 17 May 2025, CPFC automatically qualified for the 2025/26 Europa League by winning The FA Cup. As a result, NFFC fell to be entered into the 2025/26 Conference League (but for CPFC winning The FA Cup, it would have qualified for the Europa League by virtue of its league position).
• On 24 May 2025, OL also qualified for the Europa League. This created a potential MCO issue, as John Textor was the ultimate controlling party of OL whilst also holding a significant ownership interest in CPFC. Both clubs had declared in their respective MCO declarations to UEFA that Mr Textor (via Eagle Football Holdings) had control or decisive influence over them (and other clubs).
• On 11 July 2025, UEFA’s Club Financial Control Body (CFCB) concluded that CPFC and OL did not comply with the MCO Rules as of 1 March 2025 (the relevant assessment date). Consequently, CPFC was admitted to the 2025/26 Conference League, NFFC was admitted to the 2025/26 Europa League, and OL remained in the 2025/26 Europa League.
• On 21 July 2025, CPFC appealed the CFCB’s decision to the CAS.
• On 11 August 2025, following an expedited procedure, the CAS dismissed CPFC’s appeal. The CAS Panel’s decision can be found here. 

The key points from this CAS award that are of broader relevance to football clubs and investors are as follows:

• Actual vs. potential involvement: When enforcing the MCO Rules, UEFA does not need to establish that an individual had “actual” involvement in the management, administration, and/or sporting performance of a club. It is sufficient that the relevant individual can exercise such involvement. The Panel held that requiring UEFA to prove “actual” involvement would be extremely difficult to implement in practice.
• Perception of conflicts vs. actual conflicts: Part of the underlying rationale of the MCO Rules is to prevent the perception of conflicts of interest, not just actual conflicts of interest. The Panel noted that “as it was stressed in the ENIC Award [CAS 98/200], the importance of the public perception as to the existence of a conflict of interest potentially affecting the authenticity of results, which is protected by the MCO prohibition. Such public perception is indeed engaged by the simple involvement of a person in a club, irrespective of the level of such involvement.”
• Decisive influence: The concept of “decisive influence” is not defined in the MCO Rules, but it was addressed in a UEFA Circular issued in May 2024, which set out four indicators providing guidance as to what might constitute “decisive influence” (namely, through shareholders’ or members’ rights, financial support, governance, and player transfers).
• Curing a breach: There was (as contended for by CPFC) no discretionary practice by the CFCB permitting clubs to “cure” any breach of the MCO Rules after the 1 March deadline. CPFC’s competition law complaints in that regard (and against the MCO Rules generally) were dismissed.

CAS 2025/A/11495 Drogheda United FC (Drogheda) and CAS 2025/A/11566 FK DAC 1904 (FK DAC)

The CAS has also published decisions involving Drogheda and FK DAC. The key points to note from those two cases are as follows: 

• Change of assessment date: UEFA changed its assessment date from 3 June to 1 March. In Drogheda, the Panel found that this change was properly communicated by UEFA and that clubs knew, or ought to have known, about the change. The Panel in FK DAC reached the same conclusion and ruled that the change was compatible with Swiss and EU law and was implemented in accordance with the procedures established in the UEFA Statutes. As such, the change was not “arbitrary, discriminatory, or grossly disproportionate."
• Scope of involvement is very wide: The Panel in FK DAC reached the same position as the Panel in CPFC regarding the meaning of "be involved," noting that the words immediately following in the relevant MCO Rule (i.e., “either directly or indirectly, in any capacity whatsoever”) are clear. The Panel held that “there is no need to interpret this clear wording. The draftsperson has deliberately made involvement extremely broad—indirect and in any capacity.”
• Blind trusts: FK DAC argued that UEFA had permitted certain clubs to transfer shares into blind trusts after 1 March 2025, provided they had notified UEFA prior to the deadline, and contended that this rendered the 1 March 2025 deadline arbitrary. However, this argument was rejected, primarily because FK DAC failed to produce evidence substantiating this allegation. Moreover, the Panel confirmed that UEFA had not “approved” any blind trust agreements: “The mere fact that certain clubs may have implemented blind trust arrangements, regardless of their form, does not alter the reality that the CFCB has not assessed or approved any such arrangements.” CPFC advanced the same argument, which was also rejected on the same basis.

What’s the impact on sports organisations? 

The CAS awards discussed above provide important practical guidance for clubs and investors navigating MCO structures moving forward. We predict that some clubs will continue to fall foul of UEFA’s MCO Rules each year (given the history of such cases, increasing prevalence of such structures, and the perhaps unexpected qualification for the same UEFA competitions by two clubs in the same structure).However, key takeaways for clubs in MCO structures who might qualify for UEFA competitions and wish to avoid difficulty include the following:

1 March is a hard deadline

Notwithstanding prior speculation that UEFA may relax the MCO Rules, in December 2025 UEFA issued a further Circular confirming that 1 March was the strict deadline for compliance. UEFA has insisted that there would be no extension to circumvent the regulations after this date. Accordingly, clubs should not rely on late remedial action to cure breaches or avoid exclusion from UEFA competitions. Late share sales will not retroactively remedy a breach. Clubs – particularly those already in MCO structures – need to take steps to ensure that appropriate restructuring measures can be implemented before 1 March 2026 if there is even a small risk that two clubs in the same MCO structure could end up in the same UEFA competition next season. The CAS cases above demonstrate that ignorance of the MCO Rules (or UEFA Circulars) provide no excuse for non-compliance.

Blind trusts are not a guaranteed solution

In a UEFA Circular dated 14 May 2024, UEFA informed clubs that they would be permitted to use blind trusts (a legal structure under which all decision-making of a club rests solely under the control of a third party/trustee who is bound by fiduciary duty to act in the best interests of the club) after the 2024/25 season’s assessment date (3 June 2024), on a temporary basis and under certain conditions. However, the UEFA Circular made clear that this was being permitted “on an exceptional basis for the 2024/25 UEFA competitions” and 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”. As noted above, both FK DAC and CPFC sought to rely on UEFA’s supposed prior approval of blind trusts, but both CAS Panels concluded that UEFA had not approved any blind trusts for the 2025/26 season. The Panel in CPFC noted that this “was a temporary solution put in place by UEFA for the 2024/25 season only and does not constitute a consistent practice of the CFCB.”

Accordingly, clubs, owners, and investors should exercise caution when utilising blind trusts to address potential compliance issues with the MCO Rules. There is no guarantee they would be approved by UEFA going forward, particularly due to the questions about the effectiveness of blind trusts as a means of addressing conflicts of interest (given the ways in which the safeguards can potentially be circumvented). 

Furthermore, it is important to note that the structures referred to as 'blind trusts' in the football context would not necessarily share the characteristics of a classic blind trust arrangement. In a traditional blind trust, an individual (for example, a politician) places assets into a trust on terms that permit the trustees to buy and sell trust assets at their discretion without informing the beneficiary. This ensures that the politician holding public office need not declare an interest in certain assets because he or she does not know at any given time what assets are held by the trust. However, if a shareholder of two football clubs were to place the shares of one club into what is termed a 'blind trust' but under which the trustees lack the power to dispose of those shares, all relevant parties (including the beneficial owner and club personnel) would remain aware at all times that the shareholder is the ultimate owner of the relevant club. Such arrangements may therefore fail to address the underlying concerns regarding conflicts of interest and public perception that the MCO Rules are designed to prevent.

Consistent enforcement is paramount

While excluding clubs from UEFA competitions for failing to comply with the MCO Rules by the March assessment date (months before the season's conclusion) may appear harsh to some, numerous clubs invest considerable effort to ensure compliance by the deadline and UEFA needs a reasonable period during which to assess compliance prior to its competitions commencing to ensure the integrity of its competitions. It would be inequitable for UEFA not to enforce breaches consistently across all clubs. The CAS rejected arguments alleging excessive formalism in UEFA's approach. Clubs in breach of the MCO Rules can and should expect to face significant consequences.

Be mindful of indicators in the UEFA Circular

The threshold for breach of the MCO Rules may be lower than clubs anticipate. Clubs and investors should be mindful of the indicators set out in the May 2024 UEFA Circular (and how they were applied by the Panel in CPFC) and consider how those indicators might apply to their MCO structure. These indicators will serve as a starting point for any assessment of decisive influence.

2025 brought a landmark summer in UEFA's enforcement of its MCO Rules. The three CAS awards discussed above confirm that UEFA and the CAS will rigorously apply the MCO Rules and that technical compliance by the assessment deadline is non-negotiable. As MCO structures continue to proliferate across European football, so too does the risk of non-compliance. Clubs and investors should therefore adopt a proactive approach, ensuring full compliance well in advance of regulatory deadlines. 

Whilst these CAS awards pertain to UEFA’s MCO rules in football, it is worth noting that MCO structures and regulations exist in other sports, such as rugby union and Formula 1. The principles established in the decisions – particularly regarding the broad interpretation of ‘involvement’, the importance of perceived conflicts as opposed to actual conflicts, and the necessity of strict deadline compliance – is instructive for participants in other sports with similar rules. However, the efficacy of the rules remains subject to the regulator’s appetite and resources for review, intervention, and monitoring of MCO structures where financial investment in the sport may be a more pressing priority. 

To read the full report for Ahead of the Game: Sports Horizon Scanning 2026, click here.