Crystal Palace FC v. UEFA, Nottingham Forest FC & Olympique Lyonnais

UEFA's multi-club ownership (MCO) rules prohibit the same person or entity from holding decisive influence over two clubs competing in the same UEFA competition in the same season. On UEFA's assessment date of 1 March 2025, John Textor — founder of Eagle Football Holdings — held a 43.9% stake in Crystal Palace and a 77% stake in Olympique Lyonnais. Both clubs had qualified for the following season's Europa League. Crystal Palace appealed UEFA's finding that this breached the MCO rules.

The central legal question was whether Textor's stakes, though below outright majority ownership at Palace, amounted to "decisive influence" within the meaning of UEFA's rules, and whether the rules allowed any flexibility for a club to restructure its ownership after the assessment date to cure a breach. Crystal Palace mounted a specific corporate-structure argument: it contended UEFA should have measured Textor's indirect interest through a particular holding company, Eagle Football Holdings Bidco Limited, which held only 28.84% — below the 30% ownership threshold set out in UEFA's own May 2024 Circular — and separately argued that, whatever the percentage, Textor had no actual involvement in Palace's day-to-day management or administration.

The Panel rejected both arguments. On the ownership question, it looked past the specific holding company Palace pointed to and found decisive influence existed over both clubs on the facts as a whole, including Textor's own dual governance roles — a director at Palace and simultaneously chairman and chief executive of Lyon. On the "no actual involvement" argument, the Panel articulated a governing principle with implications well beyond this case: decisive influence under UEFA's rules is assessed by the capacity to exercise it, not by proof that it was actually exercised. A shareholder does not escape the rule merely by staying hands-off in practice if the underlying stake and governance position give them the power to intervene. Separately, and consistent with the reasoning CAS had already set out in the Drogheda United case decided months earlier, the Panel held that UEFA's rules do not permit flexibility once the 1 March assessment date has passed — compliance is judged strictly on that date, not on the situation as it may later be corrected.

CAS dismissed Crystal Palace's appeal. Palace were demoted from the Europa League to the third-tier Conference League. Nottingham Forest's own path there was itself indirectly shaped by Palace's success: Forest's seventh-place Premier League finish would ordinarily have earned Europa League qualification outright, but Palace's FA Cup win had initially bumped Forest down to the Conference League instead; once Palace was excluded from the Europa League for the MCO breach, Forest was restored to the Europa League place its league position had originally earned. Lyon retained its position based on its higher domestic finish via Ligue 1. This case was decided alongside a closely related CAS award the same year, CAS 2025/A/11566 FK DAC 1904 v. UEFA, which addressed a Slovakian club's ownership structure under the same MCO framework and reached the same result. The ruling is now a leading authority on how strictly UEFA's ownership rules are actually enforced, with real, immediate sporting consequences rather than a purely administrative sanction.