MULTI-CLUB OWNERSHIP IN FRENCH FOOTBALL

Multi-club ownership (MCO) is becoming an increasingly prominent feature of the global football landscape, and France is no exception.

Although Article L.122-7 of the French Sports Code (the Code) prohibits domestic club control by a single entity within the same sporting discipline, no such restriction exists regarding foreign clubs.

As a result, French clubs are progressively being acquired by investment groups that already own clubs abroad, raising key questions about competition integrity, club identity, and regulatory oversight.

This brief overview explores the rise of MCO in France, from both a sporting competition and a legal and economic perspective, highlighting how national and European regulators are responding to this evolving phenomenon.

Article L.122-7 of the Code offers the clearest insight into France’s firm stance on MCO. It reflects a strict regulatory model, clearly confined to national territory. Whilst French law does not prohibit cross-border ownership, that is, holding stakes in one club in France and another abroad, it firmly restricts any overlap in ownership within the same sporting discipline on French soil.

The Article prohibits any individual or legal entity from exercising exclusive or joint control over more than one professional sports company operating in the same discipline. It also bars the simultaneous holding of management positions across such entities or any combination of managerial duties in one club with ownership or influence over another. These rules aim to preserve the independence of each club and ensure the integrity of national competitions.

Non-compliance is treated seriously and may result in fines of up to €45,000 (around Sw. Frs. 42,265). The legislator’s intention is very clear: to maintain competitive balance and prevent any consolidation of influence that could undermine the fairness of sporting outcomes. This approach reinforces the autonomy of clubs and supports a credible competition structure.

An exception to this prohibition allows a single individual to control two separate entities within the same sport, but only when one manages men’s teams and the other women’s. This exception underscores France’s commitment to both protecting competition integrity and encouraging investment in, for example, women’s football.

However, the French MCO rules apply strictly to clubs located in France. They do not extend to ownership structures that span across borders, which means that French clubs can legally become part of broader international networks. This legal nuance has paved the way for the integration of French clubs into international MCO networks.

This national framework is further supported by several regulatory bodies that oversee the financial health, legal compliance, and competitive fairness of professional football clubs operating within the French system.
In France, the financial regulation of professional football clubs is entrusted to the Direction Nationale du Contrôle de Gestion (DNCG), an independent body operating under the authority of the French Football Federation (FFF) and the Professional Football League (LFP). The DNCG ensures financial transparency, sustainability, and compliance across Ligue 1, Ligue 2, and the National divisions.

Its core responsibilities include the review of club budgets, audits of financial statements, and evaluation of investment structures and ownership changes. In the MCO context, the DNCG acts as a regulatory safeguard, verifying whether a proposed acquisition complies with domestic financial standards and supports the club’s long-term viability.

This control mechanism was notably exercised in 2023 when the American consortium BlueCo, already owners of Chelsea FC in the UK, announced its acquisition of Racing Club de Strasbourg Alsace. As required by French law, the project was submitted to the DNCG for prior review. Its approval was a critical step in confirming the deal’s compliance with national regulations.

Alongside the DNCG, the French Competition Authority (Autorité de la concurrence) intervenes when club acquisitions reach the thresholds defined by national merger control law. This was the case in Decision No. 19-DCC-160 of 21 August 2019, which concerned the acquisition of OGC Nice by the INEOS Group, already owners of FC Lausanne-Sport in Switzerland. It was the first time that the Authority had reviewed a transaction involving a professional football club, an issue not yet addressed by the European Commission at that point.

The Authority analysis focused on defining the relevant markets in which clubs operate. Special attention was given to the professional player transfer market, which had not previously been clearly delineated in French competition law. It was considered at least European, possibly global in scale, with clubs competing for players based on net salary, reputation, contract duration, league competitiveness, and international exposure.

The Authority also examined the sports marketing and sponsorship market, which it viewed as increasingly international. Ultimately, the transaction was cleared without conditions, as the merged entity held a very limited market share in both segments.

Together, Article L.122-7 of the Code, the DNCG financial oversight, and the Competition Authority merger control constitute a robust national framework that ensures football clubs operate with autonomy and financial integrity within domestic competitions.

However, as MCO increasingly involves international networks, these national mechanisms face limits. Cross-border ownership arrangements introduce challenges that require broader coordination at the European and global levels.

At the European level, UEFA enforces a strict framework to protect the integrity of its interclub competitions. Rather than banning multi-club ownership, it regulates it through carefully defined eligibility rules. Article 5 of the UEFA Champions League Regulations prohibits any natural or legal person from exercising direct or indirect control, influence, or involvement over more than one club participating in the same UEFA competition.

The aim of UEFA is not to ban MCO outright, but to avoid conflicts of interest and uphold the unpredictability of results, a core value of sporting fairness. If multiple clubs under common ownership qualify for UEFA competitions, only one may be admitted. Priority is determined according to a predefined order: the most prestigious competition, the club’s domestic ranking, and, finally, the association’s position in the UEFA access list.

In certain cases, a club excluded on this basis may still participate in another UEFA competition, as long as all integrity criteria continue to be met. This illustrates the UEFA balanced approach; not a blanket prohibition, but a form of conditional regulation that reinforces the credibility and fairness of European football.

Building on this framework, UEFA institutional oversight, notably through its Club Financial Control Body (CFCB), plays a central role in ensuring compliance with licensing and financial sustainability criteria. Acting as both a monitoring and enforcement body, at the European level, the CFCB supports a coherent regulatory approach across UEFA competitions. In parallel, the Court of Arbitration for Sport remains the main forum for resolving disputes in this domain, including those related to eligibility and club licensing.

At the global level, FIFA plays a complementary role through its Regulations on the Status and Transfer of Players. These rules prohibit third-party influence in transfer dealings and promote club autonomy, principles that have gained increasing importance in a landscape shaped by transnational investment in football. Although FIFA does not directly regulate MCO, its emphasis on independence and contractual freedom supports broader governance objectives.

In addition to these sport-specific frameworks, MCO must also be examined under European Union competition law. Professional sport is treated as an economic activity and is, therefore, subject to the rules governing mergers, market restrictions, and collusive behaviour, including Article 101 of the Treaty on the Functioning of the European Union (the Treaty). Whilst the Court of Justice of the European Union has not yet ruled on this specific issue, past cases offer some relevant insight.

One such case is ENIC v. UEFA, where ENIC, a company with financial stakes in several European football clubs, challenged the UEFA rule limiting the participation of clubs under common ownership in its competitions. The European Commission (Case COMP/37 806: ENIC/ UEFA) found that, although the rule could, in theory, restrict investment, it pursued a legitimate objective, namely, ensuring the integrity of UEFA competitions. On this basis, the Commission concluded that the rule complied with EU competition law. ENIC did not appeal the decision, and the UEFA rule remains in force.

This precedent illustrates that restrictions on multi-club ownership may be acceptable under EU law when they aim to protect the fundamental values of sporting fairness. These include maintaining uncertainty of results and public trust in the integrity of competition, principles that are further supported by the recognition of the social and educational role of sport in Article 165 of the Treaty. Future legal developments in this area will likely have to strike a careful balance between investor freedom and the broader interests of sport.

As professional football generates record revenues across Europe and ownership structures grow more complex, strong coordination among national regulators, UEFA, FIFA, and European institutions is essential. The rise of MCO presents both opportunities and challenges. Ensuring that governance frameworks evolve in step with this trend is critical to preserving the sport’s core values and maintaining trust amongst its stakeholders, supporters, and the wider public.

As MCO expands and evolves, balancing financial opportunity and sporting integrity remains central to the regulatory debate. Striking the right balance, therefore, between the two will be essential to safeguarding the core values of football, both on and off the field of play.

As will be appreciated, the subject of MCO in football in France and, indeed, beyond is a complex issue requiring expert professional advice and assistance and further information may be obtained from the Head of our French Desk, Dr Estelle Ivanova, by emailing her at ‘ivanova@valloni.ch’.