UEFA’s Multi-Club Ownership Rule Before CAS: The 1 March Deadline and the Drogheda United Decision (Part 1)

The end of the 2024/25 football season brought challenges for several football clubs forming part of what are known as multi-club ownership (MCO) structures. An MCO structure is one where the corporate entity of one football club forms part of a group of other football clubs whose corporate entities are collectively owned by a common person and/or other corporate entity.

Among European clubs, the notable clubs affected were Crystal Palace FC (CPFC), Drogheda United FC (DUFC) and FK DAC 190 AS (DAC), each of which was (at the relevant time) part of an MCO structure.

The challenges for those clubs arose in circumstances where each had qualified for a UEFA club competition (e.g., the UEFA Conference League (the Conference League) or the UEFA Europa League (UEL)) but at the same time one other club within that club’s MCO structures also qualified for the same competition. 

The relevant provision of each of UEFA’s club competition regulations for the 2025/26 season (referred to herein collectively as the “UCC Regulations”)^[1] is Article 5 and is known as the “MCO Rule”.

The Court of Arbitration for Sport (CAS) recently published three decisions concerning appeals by DUFC, DAC and CPFC against decisions by UEFA's Club Financial Control Body First Chamber (CFCB) refusing their admission to UEFA club competitions for the 2025/26 season. In each case, the CAS upheld the CFCB's decision, strictly applying the MCO Rule and rejecting arguments based on procedural fairness, legitimate expectations and Swiss law principles.

Article Structure

This two-part article provides a comprehensive analysis of these landmark CAS decisions and their implications for clubs in MCO structures:

Part 1 (this article) examines:

• The MCO Rule and its consequences
• How UEFA communicated amendments to the MCO Rule for the 2025/26 season
• The CAS 2025/A/11495 Drogheda United FC v. UEFA^[2] award, the first CAS decision addressing the 1 March 2025 deadline

Part 2 (which can be found here) will examine:

• The CAS 2025/A/11566 FK DAC 1904, A.S. v. UEFA^[3] award addressing Swiss law challenges and familial ties
• The CAS 2025/A/11604 Crystal Palace Football Club v. UEFA, Nottingham Forest Football Club & Olympique Lyonnais^[4] award involving complex ownership structures and decisive influence
• Practical guidance for clubs and their advisors
• UEFA's confirmation of the 1 March deadline for the 2026/27 season

The decisions are addressed chronologically according to the date of the operative part of each CAS Panel’s decision, demonstrating the strict and consistent approach adopted by both UEFA and CAS Panels in applying the MCO Rule.

Article Outline

• The MCO Regulations in Question
  • Consequences of Non-Compliance
• UEFA’s communication on the UCC Regulations
  • The May 2024 Circular: Defining ‘Decisive Influence’
  • The October 2024 Circular: Introducing the 1 March Deadline
  • The European Clubs Association’s Communications
  • The December 2024 Letter: Direct Club Notification
• CAS 2025/A/11495 Drogheda United FC v. UEFA
  • Background
  • Appeal to the CAS
    • Issue 1: Awareness of the 1 March Deadline
    • Issue 2: The December 2024 Letter and Equal Treatment
    • Issue 3: Validity of UEFA's Amendment Process
  • Outcome and Belated Compliance Attempts