CAS CONFIRMS UEFA BAN ON MULTI-CLUB OWNERSHIP IN DROGHEDA UNITED FC CASE
On 17 June 2025, the Court of Arbitration for Sport (CAS) dismissed the appeal brought by Drogheda United FC, an Irish football club, challenging the UEFA decision to exclude the Club from the 2025/26 UEFA Conference League. The decision was based on Article 5.01 of the UEFA Conference League Regulations, which prohibit the participation of multiple clubs under common ownership (MCO) or influence in the same UEFA competition.
Drogheda United FC and Silkeborg IF, a Danish Club, which also qualified for the tournament, are both owned by Trivela Group, a U.S.-based investment company.
On 5 June 2025, the UEFA Club Financial Control Body concluded that, as of the applicable assessment date – 1 March 2025 – the two clubs failed to meet the independence requirements set out in the Competition Regulations.
Under Article 5.01 of the Regulations, each club must demonstrate that it complied with the following criteria as of 1 March 2025 and continues to do so throughout the competition. This Article provides that:
“No club participating in a UEFA club competition may, either directly or indirectly:
– hold or deal in the securities or shares of any other club participating in a UEFA club competition;
– be a member of any other club participating in a UEFA club competition;
– be involved in any capacity whatsoever in the management, administration and/or sporting performance of any other club participating in a UEFA club competition; or
– have any power whatsoever in the management, administration and/or sporting performance of any other club participating in a UEFA club competition.”
The Article further prohibits any natural or legal person from exercising control or influence over more than one participating club, including through:
– a majority of shareholders’ voting rights;
– the right to appoint or remove board members;
– shareholder agreements; or
– any other means of decisive influence.
The majority of the three-member CAS Panel held that the amendment to the assessment date (moved from 3 June to 1 March 2025) had been properly communicated by UEFA. The Panel further found that Drogheda United FC knew, or ought to have known, of this deadline. It also rejected allegations of unequal treatment, finding no breach of the UEFA regulatory duties.
This CAS Award confirms the enduring relevance of the UEFA integrity-based restrictions on multi-club ownership, aligning with the landmark ENIC decision (CAS 98/200) and the European Commission decision in ENIC/UEFA (COMP/37806). These precedents upheld the legitimacy of such rules, aimed at preventing conflicts of interest and ensuring public trust in the authenticity of the results of sporting competitions.
However, the legal landscape surrounding sports governance and competition law has become increasingly complex. In recent judgments, such as European Super League (C-333/21) and Diarra (C-650/22), the Court of Justice of the European Union reaffirmed that restrictions imposed by sporting bodies must be justified by legitimate objectives and assessed against strict criteria of proportionality, transparency, and non-discrimination.
Against this backdrop, the Drogheda United FC CAS Award illustrates how integrity-based ownership rules can still be upheld, provided that they are applied in a clear, consistent, and predictable manner.
Whether such a strict interpretation will endure or give way to a more flexible approach, in the light of shifting investment models and legal standards, remains uncertain. Time will alone tell!
We advise on MCO cases and further information is available from Dr Estelle Ivanova by emailing her at ivanova@valloni.ch .