FOOTBALL MULTI-CLUB OWNERSHIP: CAS APPEAL CASE
On 14 July 2025, the Court of Arbitration for Sport (CAS) dismissed the appeal lodged by Slovakian club FK DAC 1904 A.S. against UEFA, as reported in the official CAS media release of the same date. The appeal concerned the DAC exclusion from the UEFA Conference League 2025/2026 due to alleged breaches of the UEFA multi-club ownership rules.
The dispute revolved around Article 5.01 of the UEFA Club Competition Regulations, designed to preserve the integrity of UEFA competitions, by preventing any form of control or influence over more than one participating football club. Under this provision, no individual or legal entity may be involved, directly or indirectly, in the management, administration, or sporting performance of more than one club, nor may they exercise decisive influence over multiple clubs’ decision-making.
On 26 June 2025, the UEFA Club Financial Control Body found that DAC and Hungarian club Györi ETO FC were both linked to EEA Holding B.V., and that three members of the same family were involved, either directly or indirectly, in the “shareholding/membership of both Clubs” and “in the governance of both Clubs.”
DAC challenged both the change in the assessment date, from 3 June to 1 March 2025, and the UEFA conclusion that there was a breach of the multi-club ownership rules.
The CAS Panel unanimously found that the change of date was consistent with the procedures set out in the UEFA Statutes and that DAC had breached Articles 5.01(b) and 5.01(c)(iv) of the Regulations. And, in particular, that the same individual was the Managing (and sole) Director of ETO FC, whilst also serving as CEO, Vice-President and board member of DAC, a situation that enabled decisive influence over both clubs’ decision-making. The appeal was, therefore, dismissed.
This outcome reflects a strict interpretation of the UEFA competitions integrity rules and confirms the organisation’s broad scrutiny of overlapping governance in multi-club ownership scenarios.
This case marks a firm reaffirmation of the UEFA determination to safeguard the integrity of its club competitions. By validating the forward shift in the assessment date and recognising that overlapping executive functions can amount to decisive influence, the decision illustrates how UEFA applies its multi-club ownership rules in practice. Football clubs and their investors must ensure that their governance structures are fully compliant, particularly in cases involving investment groups or family-controlled entities.
The case also illustrates how the UEFA integrity-based regulatory approach touches upon issues that are equally relevant under European Union (EU) competition law, such as control, independence, and conflicts of interest.
In practice, multi-club ownership raises complex legal questions at the intersection of regulatory autonomy and internal market rules, particularly where shared governance may distort competitive balance or compromise the strategic independence of participating football clubs.
Recent EU case law, including European Super League (C-333/21), Diarra (C-650/22), and Meca-Medina (C-519/04 P), confirms that whilst sports governing bodies enjoy a certain degree of autonomy, this autonomy must be exercised in a manner that is proportionate and consistent with EU law, including the competition rules.
The DAC ruling follows a series of prior assessments in the EU regarding multi-club ownership, going back, notably, to the ENIC/UEFA case (COMP/37.806), in which the European Commission accepted the legitimacy of the UEFA integrity rules under the then Article 81 (1) of the EC Treaty, now Article 101 of The Treaty on the Functioning of the European Union, provided that they are applied in a proportionate and transparent manner.
We advise on this complex field of EU sports law and further information is available from Dr Estelle Ivanova by emailing her at ivanova@valloni.ch.