UEFA’s Multi-Club Ownership Rule Before CAS: Decisive Influence in the DAC and Crystal Palace Cases (Part 2)

This is Part 2 of a two-part article examining the Court of Arbitration for Sport's (CAS) strict application of UEFA's Multi-Club Ownership Rule (MCO Rule) in three landmark 2025 decisions. The MCO Rule is found under Article 5 of each of UEFA’s club competition regulations for the 2025/26 season (referred to herein collectively as the “UCC Regulations”)^[1].

Part 1 examined the MCO Rule itself, UEFA's communication of amendments introducing a 1 March 2025 assessment deadline, and the first CAS decision in CAS 2025/A/11495 Drogheda United FC v. UEFA^[2]. That case established that the 1 March deadline was validly adopted, properly communicated, and strictly enforceable, with no flexibility for clubs to achieve compliance after the deadline had passed.

Part 2 examines the two subsequent CAS awards — CAS 2025/A/11566 FK DAC 1904, A.S. v. UEFA^[3] and CAS 2025/A/11604 Crystal Palace Football Club v. UEFA, Nottingham Forest Football Club & Olympique Lyonnais^[4] —which addressed more complex ownership structures and legal challenges. These cases involved:

• FK DAC 1904 AS (DAC): A Slovakian club whose case raised questions about familial relationships creating decisive influence, Dutch trust structures (STAKs), and Swiss law principles governing the validity of UEFA's regulatory amendments.
• Crystal Palace FC (CPFC): An English club in a complex ownership structure involving minority shareholdings, where the question was whether economic investment and board positions created "decisive influence" under Article 5.01(c) of the UCC Regulations.

In both cases, the CAS panels dismissed the clubs' appeals and confirmed the CFCB First Chamber's decisions, reinforcing the strict and uniform application of the MCO Rule. This article concludes with practical guidance for clubs and their advisors based on these three decisions, and examines UEFA's December 2025 confirmation that the 1 March deadline will continue for the 2026/27 season.

Article Outline

• CAS 2025/A/11566 FK DAC 1904, A.S. v. UEFA
  • Background
    • The CFCB Decision
  • Appeal to the CAS
    • Issue 1: Swiss Law and Validity of Amendment
    • Issue 2: Enforceability and Legitimate Expectations
    • Issue 3: Article 5.01(b) Breach - Shared Management
  • CAS 2025/A/11604 Crystal Palace Football Club v. UEFA, Nottingham Forest Football Club & Olympique Lyonnais
    • Background
      • The CFCB Decision
    • Appeal to the CAS
      • Issue 1: Article 5.01(c) Breach - Decisive Influence
      • Issue 2: No Discretion to Cure Non-Compliance After 1 March
    • Key Findings
    • Practical Guidance for Football Clubs
    • UEFA's Confirmation for 2026/27 Season