Besiktas Futbol Yatirimlari Sanayi Ve Ticaret A.S v. Union of European Football Associations (UEFA)

At a glance

Parties

Beşiktaş Futbol Yatırımları Sanayi ve Ticaret A.Ş. (Turkey) v. Union of European Football Associations (UEFA)

Case no.

CAS 2025/A/11769

Forum and rules

Court of Arbitration for Sport, appeals arbitration under Article R47 et seq. of the CAS Code; UEFA Statutes and regulations, subsidiarily Swiss law

Treaty

None. The regulatory instrument is the UEFA Club Licensing and Financial Sustainability Regulations – Edition 2024 (CLFS)

Tribunal

Mr Hervé Le Lay (President), Prof. Ulrich Haas, Mr Patrick Grandjean

Sector

Football; club financial regulation

Outcome

Appeal dismissed and the UEFA CFCB Appeals Chamber decision of 8 July 2025 confirmed (award of 31 March 2026).

Amount

Fine under appeal: EUR 900 000, about 17% of a squad cost excess of EUR 5 246 000. The published award omits the operative paragraphs on costs.

The dispute

Beşiktaş, a Turkish professional football club that played in the 2024/2025 UEFA Europa League, reported a squad cost ratio of 84.9% for 2024. The CLFS cap was 80%, so the excess was about EUR 5.2 million. The UEFA Club Financial Control Body (CFCB) First Chamber fined the Club EUR 900 000, and the CFCB Appeals Chamber dismissed the Club's appeal on 8 July 2025. Before CAS, the Club did not contest the breach or the calculation. It argued that several factors should have led to no sanction or to a fine at the 10% floor: the depreciation of the Turkish Lira and high inflation (as force majeure or major and unforeseen economic change under Annex M of the CLFS), three changes of president and board in 14 months, its status as a first-time offender, its cooperation, and its remedial business plan. It also argued that the fine was disproportionate and unequal because other clubs had received settlement agreements. UEFA answered that none of these were mitigating factors, that the Club had produced no evidence, and that the CLFS allows no settlements for cost-control breaches.

Key holdings

1. Currency depreciation and inflation are not force majeure under Article M.1(f) or a major and unforeseen economic change under Article M.1(g). The Club produced no financial statements, player contracts or expert evidence of a causal link to the breach. The Lira had been depreciating since 2014, and 2024 saw its lowest depreciation in five years (12.80%). No other Turkish club in UEFA competition breached the rule, which shows the effect was not irresistible. ¶¶ 71–82
2. The Panel doubted that Article M.1(c), on currency conversion of aggregate football earnings, applies to the squad cost rule. In any event, the Club's own unsupported figures (Exhibit 6) still showed a breach of about 0.59%, roughly EUR 623 000. ¶¶ 66–70
3. Changes in a club's board and presidency are internal matters within the club's control. Media and supporter pressure does not change this. Such changes are neither force majeure nor an extraordinary national economic event. ¶¶ 85–86
4. First-time-offender status is not an additional mitigating factor, because the Annex L.4 grid already uses it to set the 10%–25% range. As the 80% cap applied for the first time in 2024, every club in breach was a first-time offender. Cooperation is a duty under Article 78.01(a) CLFS, so fulfilling it does not mitigate. ¶¶ 88–91
5. A long-term business plan can mitigate under Article M.1(d), but it must be shown by a balance sheet, a profit and loss account and a cash flow statement. No business plan was produced before the CFCB Appeals Chamber or before CAS, and press statements by the new president cannot meet that burden. ¶¶ 93–95
6. The fine is proportionate. CAS reviews de novo but shows restraint on the level of a properly justified sanction, and about 17% of the excess lies in the middle of the 10%–25% range. The CAS precedents cited by the Club, including CAS 2018/A/5808, concerned different rules and circumstances. ¶¶ 98–103
7. There was no unequal treatment. The CLFS allows settlement agreements for stability-requirement breaches (Article 97.03) but not for the squad cost rule. The other clubs that breached the squad cost rule for 2024 (Chelsea FC, Aston Villa FC, Panathinaikos FC) received the same unconditional, proportionally calculated fine. The settlements the Club cited were stricter, as they also restricted player registration. ¶¶ 104–108

Procedural history

1. 13 March 2025The Club submits final squad cost information showing a 2024 squad cost ratio of 84.9%.
2. 20 March 2025UEFA opens proceedings before the CFCB First Chamber and appoints a reporting member.
3. 22 April 2025The CFCB Reporting member recommends a financial disciplinary measure of EUR 900 000.
4. 28 May 2025The CFCB First Chamber imposes the EUR 900 000 fine. The reasoned decision is notified on 6 June 2025.
5. 8 July 2025After a hearing, the CFCB Appeals Chamber dismisses the Club's appeal. The decision is notified on 5 September 2025.
6. 12 September 2025The Club files its Statement of Appeal with CAS.
7. 15 January 2026Panel constituted with Hervé Le Lay as President, after Massimo Coccia declined to serve.
8. 26 February 2026Hearing held by videoconference.
9. 31 March 2026Award: appeal dismissed and the Appeals Chamber decision confirmed.

Tribunal, counsel and experts

Decided by

• Hervé Le Lay President, Panel — appointed by the institution (appointed by the CAS Appeals Division President on 6 January 2026 after Massimo Coccia declined to serve)
• Ulrich Haas Co-arbitrator, Panel — appointed by the claimant
• Patrick Grandjean Co-arbitrator, Panel — appointed by the respondent

For the claimant

Anil Dincer

For the respondent

Antonio Rigozzi · Patrick Pithon

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Keywords

• squad cost rule
• UEFA Club Licensing and Financial Sustainability Regulations
• CLFS
• Club Financial Control Body
• financial sustainability
• force majeure
• Turkish Lira depreciation
• inflation
• major and unforeseen change in the economic environment
• mitigating factors
• first-time offender
• business plan
• proportionality of sanctions
• equal treatment
• settlement agreement
• burden of proof
• Beşiktaş
• football

Summary generated with AI from the published documents — refer to the award for the authoritative text.