Crystal Palace Football Club v. Union of European Football Associations (UEFA), Nottingham Forest Football Club, Olympique Lyonnais
Case summary
At a glance
- Parties
- Crystal Palace Football Club (England) v. Union des Associations Européennes de Football (UEFA), Nottingham Forest Football Club (England) and Olympique Lyonnais (France)
- Case no.
- CAS 2025/A/11604
- Forum and rules
- Court of Arbitration for Sport, expedited appeals arbitration procedure under the CAS Code (2025 edition). The appeal was brought under Article 62 of the UEFA Statutes and Article 34.01 of the UEFA CFCB Procedural Rules.
- Tribunal
- Prof. Luigi Fumagalli (President), Mr Manfred Nan, Mr Olivier Carrard
- Sector
- Football; multi-club ownership; eligibility for UEFA club competitions
- Outcome
- Appeal dismissed. The UEFA CFCB First Chamber decision of 11 July 2025 is confirmed, so Olympique Lyonnais plays in the 2025/26 UEFA Europa League and Crystal Palace in the 2025/26 UEFA Conference League. Operative part issued 11 August 2025; reasoned award dated 31 October 2025.
The dispute
Crystal Palace qualified for the 2025/26 UEFA Europa League by winning the FA Cup. Olympique Lyonnais (OL) qualified for the same competition through the Ligue 1 access-list adjustments that followed PSG's league and cup double. John Textor, through Eagle Football Holdings Bidco Limited, controlled OL and also held 44.09% of the shares of Palace Holdco, the company controlling Crystal Palace; he was a director of Palace Holdco and one of four principal partners of Palace Manageco. The UEFA CFCB First Chamber found that both clubs breached the multi-club ownership (MCO) rule in Article 5.01(b) and (c) of the 2025/26 UEL Regulations as at the 1 March 2025 assessment date, admitted OL to the Europa League and moved Crystal Palace to the Conference League. Crystal Palace argued that Mr Textor had no actual involvement or decisive influence; that UEFA had a discretionary practice of accepting post-deadline cures, and the sale of the Eagle stake in June–July 2025 cured any breach; that EU competition law (Articles 101 and 102 TFEU) was infringed; and that it, not OL, should be preferred under Article 5.02(a) because OL had not qualified "on sporting merit" directly.
Key holdings
- Breach of Article 5.01(b). The wording is clear: "be involved" means the mere act of being part of something, and actual involvement is not required. Mr Textor's positions as director of Palace Holdco and principal partner of Palace Manageco, each carrying a 25% vote on decisions crucial to the club, were enough. He was therefore involved in both Crystal Palace and OL on 1 March 2025. ¶¶ 102–114
- Breach of Article 5.01(c)(iv). The ability to exercise decisive influence is enough; it need not actually be exercised. The May 2024 CFCB Circular does not amend the regulations, but its indicators are a valid interpretive tool and prove decisive influence at least prima facie. Eagle's stake of over 30% (B1 shares carried votes), the investment of about GBP 123,000,000 (49% of paid-in capital), Mr Textor's governance rights and the loan of seven players to Molenbeek each showed decisive influence over Crystal Palace. ¶¶ 117–139
- UEFA has no discretionary practice of allowing clubs to cure an MCO breach after the 1 March 2025 assessment date. The 2024/25 blind-trust arrangements were an exceptional, one-season measure. No proceedings were opened against Nottingham Forest. The ECA email of 25 October 2024 was not sent by or on behalf of UEFA. Remarks attributed to CFCB Chairman Sunil Gulati are not evidence of a UEFA practice. ¶¶ 143–153
- The sale of the Eagle Football Holdings Bidco shares in Palace Holdco in June 2025 came after 1 March 2025 and did not cure the breach. ¶¶ 155–158
- The EU competition law claim depended, as the appellant conceded, on the existence of a discretionary practice. Since none exists, the Panel did not decide it. The Panel endorsed the ENIC Award's reasoning on the compatibility of MCO rules with EU competition law. ¶¶ 160–161
- By majority, Article 5.02(a) draws no distinction between direct and indirect qualification on sporting merit, so OL qualified for the Europa League on an equal footing with Crystal Palace. Under Article 5.02(b) the club ranked higher domestically is preferred: OL finished 6th in Ligue 1 and Crystal Palace 12th in the Premier League. Crystal Palace was validly admitted to the Conference League under Article 5.04. ¶¶ 175–181
Procedural history
- 26 May 2025Crystal Palace and OL are notified of the opening of proceedings before the CFCB First Chamber.
- 3 June 2025Hearing before the CFCB First Chamber in Nyon.
- 11 July 2025Operative part of the CFCB First Chamber decision: OL is admitted to the 2025/26 Europa League and Crystal Palace to the Conference League. The grounds are notified on 14 July 2025.
- 21 July 2025Crystal Palace files its Statement of Appeal with CAS against UEFA, Nottingham Forest and OL.
- 25 July 2025Panel constituted. Crystal Palace files its Appeal Brief.
- 29 July 2025The Panel denies Crystal Palace's request for production of documents.
- 8 August 2025Hearing at CAS headquarters in Lausanne.
- 11 August 2025Operative part of the award issued: appeal dismissed.
- 31 October 2025Reasoned award issued.
Tribunal, counsel and experts
- Decided by
- Luigi Fumagalli President, Panel — appointed by the institution
- Manfred Nan Co-arbitrator, Panel — appointed by the claimant
- Olivier Carrard Co-arbitrator, Panel — appointed by the respondent
- For the claimant
- Louise Reilly · David Baker · Ian Mill · Dominic Howells · David Hinchcliffe · Shaney Stevens-Neale · Edgar Philippin
- For the respondent
- UEFA · Nottingham Forest Football Club (representative) · Antonio Rigozzi · Patrick Pithon · David Anderson · Benoît Keane · Andrew Hunter · Luka Krsljanin · Richard Bush · Tiran Gunawardena · Lukas Stocker
- Experts
- Sylvain Marchand (claimant)
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Keywords
- multi-club ownership
- MCO rule
- decisive influence
- Article 5.01 UEL Regulations
- UEFA Europa League
- UEFA Conference League
- John Textor
- Eagle Football Holdings
- Club Financial Control Body
- assessment date
- blind trust
- post-deadline cure
- sporting merit
- FA Cup
- Article 101 TFEU
- Article 102 TFEU
- ENIC Award
- interpretation of sports regulations
Summary generated with AI from the published documents — refer to the award for the authoritative text.
Award (CAS 2025/A/11604)
Procedure: Appeal
Sport: Football
Matter: Eligibility (except nationality)
Outcome: Dismissed
Panel: Luigi Fumagalli, Manfred Peter Nan, Olivier Carrard
Source: Court of Arbitration for Sport case database.