One Owner, Two Clubs, One Place: The Crystal Palace MCO Decision at CAS

On 11 August 2025, the Court of Arbitration for Sport, (CAS), dismissed the appeal of Crystal Palace FC, (Palace). Palace had pursued an appeal against UEFA, Nottingham Forest FC, (Forest), and Olympique Lyonnais, (Lyon). It centred on UEFA’s decision to demote Palace from the 2025/26 UEFA Europa League to the Conference League, while admitting Lyon to the Europa League despite the two clubs having linked ownership structures.

CAS, in upholding the decision rendered by the First Chamber of the UEFA Club Financial Control Body, found that Palace had breached the multi-club ownership rules contained in the 2025/26 UEFA Club Competitions Regulations, (the Regulations).^[1]

This article explores the reasons for CAS’ decision and the regulatory framework in which it was decided, before identifying two key questions for European professional football that arise from the decision.

• First, does CAS’ decision, and UEFA’s rules more generally about the allocation of places in its European competitions, prejudice more competitive national leagues?
  
  
• Second, how does European professional football protect its integrity in the face of ever-increasing commercialisation?

Contents

• UEFA & Qualification Routes for its European Football Competitions
• Palace & Lyon’s Routes to Qualifying for the Europa League
• Issue of Linked Ownership Structures, the CFCB & the MCO Regulatory Framework
• Palace & Lyon’s MCO Declarations for 2025/26 Season
• Instigation of Proceedings by & Hearing before UEFA’s CFCB
• CFCB’s Decision & its Consequence
• Palace’s Appeal to CAS
• CAS’ Decision
• Consequences of Decision & Questions it Poses