As of early 2026, approximately 380 clubs worldwide are integrated into MCO frameworks, with nearly 42% of clubs in Europe’s five largest leagues, the Premier League, La Liga, Serie A, Bundesliga, and Ligue 1, maintaining significant cross-investment or shared ownership ties.

This proliferation has challenged UEFA’s regulatory architecture, specifically regarding the preservation of competitive integrity and the prevention of conflicts of interest. 

While the “blind trust” has previously served as a temporary palliative for ownership conflicts, the governing body’s decisive shift toward a proactive, permanent compliance regime marks a distinct change in how investors must navigate the intersection of strategic expansion and regulatory adherence.

The regulatory environment is governed primarily by Article 5 of the Regulations of the UEFA Champions League, Europa League, and Conference League.

This article prohibits any individual or legal entity from exercising control or influence over more than one club participating in a UEFA competition. 

The landmark jurisprudence of 2025, underscored by the Court of Arbitration for Sport (CAS) in decisions involving Crystal Palace, Drogheda United, and FK DAC 1904, has established that the mere potential for influence, rather than proven actual involvement, is sufficient to trigger exclusion.

This substance over form methodology requires a comprehensive understanding of compliance workarounds beyond the blind trust, which UEFA has explicitly designated as an exceptional, temporary measure no longer guaranteed for future seasons.

Article 5 

The foundation of Article 5 is the protection of the public perception of authenticity in sporting results. The rule, originally enacted in 1998 following the ENIC group’s overlapping interests in AEK Athens and Slavia Prague, seeks to ensure that no single entity can dictate the performance, management, or administration of more than one club in a given tournament.

In the current landscape, this is achieved through a set of stringent prohibitions that apply to any club participating in a UEFA club competition.

According to the regulations, no club participating in a UEFA competition may, either directly or indirectly, hold or deal in the securities or shares of any other participating club, be a member of any other participating club, or be involved in any capacity whatsoever in the management, administration, and/or sporting performance of another participant. The scope of involvement is interpreted with extreme breadth, covering any capacity whatsoever, which effectively prohibits shared technical staff, common back-office hubs, and joint scouting networks.

The secondary tier of the prohibition addresses the individual or legal entity behind the club. No individual or legal entity may have control or influence over more than one participating club. UEFA defines this control or influence through a series of specific thresholds, including holding a majority of shareholders’ voting rights, having the right to appoint or remove a majority of the members of the administrative, management, or supervisory body, or being able to exercise by any means a decisive influence in the decision-making of the club.

If two or more clubs within an MCO structure qualify for the same competition and are found to be in breach of Article 5, the regulations provide a strict hierarchy to determine which club is admitted and which is excluded.

This all-or-nothing consequence, where the lower-ranked club is often demoted to a secondary competition or excluded entirely, has driven the search for sophisticated workarounds. 

The most common of these is the blind trust, where an owner transfers shares to an independent trustee. However, following the UEFA Circular of December 2025, blind trusts are no longer considered a permanent safe harbour, especially if the beneficial owner retains a significant economic interest.

Substance-over-form methodology

The most significant evolution in MCO regulation occurred in May 2024, when the UEFA Club Financial Control Body (CFCB) issued a circular providing detailed guidance on the meaning of decisive influence. Unlike traditional corporate law, which often focuses on a 50% ownership threshold, UEFA’s test is qualitative and holistic. The CFCB now scrutinises horizontal synergies, the very efficiencies that make MCO models attractive to investors, as evidence of non-compliance.

The May circular established four primary indicators of decisive influence, which have since been adopted by CAS as sufficient to prove a breach on at least a prima facie basis:

1. Shareholders’ and members’ rights: Holding 30% or more of the shares in both clubs, or holding at least 10% while being a leading shareholder, is a primary indicator of influence.
2. Financial support: Providing 30% or more of a club’s total revenue, or providing financial security through credit facilities or stadium financing, creates an economic dependency that functions as a lever of control.
3. Governance and executive positions: Holding positions such as CEO, Sporting Director, or CFO in more than one club, or having the right to appoint or remove board members.
4. Technical and transfer activity: Systemic player transfers (defined as three or more movements) or the sharing of scouting databases and technical staff.

This methodology shifts the burden of proof to the club, which must demonstrate that no single person or entity can exert influence over multiple participants. For owners, this necessitates a move toward permanent structural and operational decoupling.

Workaround 1: Equity dilution

The most robust alternative to a blind trust is the permanent reduction of shareholding below the 30% threshold, combined with the total relinquishment of management rights. This strategy aims to bring the investment into the category of a minority interest rather than control.

In 2023, the investment group V Sports, which owns 100% of Aston Villa, faced a conflict when the Portuguese side Vitória SC also qualified for the UEFA Europa Conference League. To achieve compliance, V Sports implemented a two-pronged structural change:

First, it reduced its stake in Vitória SC from 46% to 29% by transferring 17% of the club’s equity back to the club itself. Second, it removed all representation on the board of directors. This reduction below the 30% threshold was critical because it moved V Sports out of the presumptive control zone established by the CFCB.

The V Sports case demonstrates that 29.9% serves as a regulatory ceiling in European football. By relinquishing board seats, the investor proves that they no longer have the capacity to participate in crucial decisions such as strategy, financial planning, or the appointment of coaches.

A similar path was followed by Tony Bloom, the owner of Brighton & Hove Albion, regarding his investment in the Belgian club Royale Union Saint-Gilloise. When both clubs qualified for the 2023/24 Europa League, Bloom reduced his ownership share in USG to a minority stake.

Crucially, Bloom transferred the majority interest to Alex Muzio, a long-time business associate who had been the club’s president. While the two individuals were linked through prior business dealings, UEFA accepted the arrangement because Bloom ceased to have day-to-day involvement in USG’s operations and the governance structures were genuinely separated.

This highlights that who the shares are transferred to is as important as the quantity of shares transferred; the new majority owner must be an independent entity capable of making autonomous sporting decisions.

Workaround 2: Governance siloing and Red Bull

For owners who do not wish to divest their equity, the primary alternative is governance siloing, the creation of strict, legally-enforced firewalls between the executive bodies of the related clubs. This strategy relies on the principle that shareholding alone does not constitute decisive influence if the owner has contractually and legally relinquished all management rights.

RB Leipzig and RB Salzburg

The precedent for this workaround is the 2017 case of RB Leipzig and Red Bull Salzburg.

Initially, the CFCB Chief Investigator recommended that only Salzburg be admitted to the Champions League because Red Bull was deemed to exercise influence over both through common personnel and financial ties. However, the clubs undertook a disengagement process that permanently altered their governance.

The key structural changes included:

1. Statutory amendments: Salzburg amended its club statutes to remove Red Bull’s right to appoint or remove board members.
2. Executive resignations: Personnel with overlapping roles or perceived links to the parent company were forced to step down and focus on only one club.
3. Termination of cooperation agreements: A formal cooperation agreement between the two clubs was terminated, and sponsorship levels were reduced to fair market value to prove financial independence.

The Adjudicatory Chamber eventually found that Red Bull no longer held decisive influence because the capacity to participate in decision-making had been structurally eliminated. This Red Bull Model serves as a blueprint for MCOs: compliance can be achieved through the total removal of personnel overlap and the termination of inter-club operational ties, even if a common branding or sponsorship link remains.

Workaround 3: Operational and technical decoupling

The substance over form test means that even if an owner has separated the boards of directors, the existence of horizontal synergies can still trigger a breach. These synergies are often the primary driver of investment value in MCOs, yet they are the primary evidence of non-compliance for the CFCB.

To satisfy UEFA, clubs must prove the total absence of shared technical agreements. This requires:

• Database siloing: Clubs are strictly forbidden from sharing scouting databases or player performance software.
• Back-office separation: MCOs often use common hubs for HR, Legal, and Finance to reduce costs. Compliance requires these hubs to be decoupled, ensuring that no administrative staff have access to the sensitive data of more than one participating club.
• Personnel firewalls: Coaches and technical staff cannot have dual roles or consultancy agreements across the network.

In the case of Girona and Manchester City, the clubs reported that during their period of trust-based compliance, employees were prohibited from sending each other emails or communicating regarding sporting matters. While this level of rigidity may seem excessive, it is necessary to withstand a CFCB audit that looks for any indication of coordinated sporting strategy.

Workaround 4: Transfer market restrictions and moratoriums

A central concern of the MCO rules is that related clubs might coordinate transfers to artificially inflate revenues, reduce costs, or circumvent financial regulations. To mitigate this, UEFA increasingly mandates no-transfer pacts as a condition for the admission of related clubs.

September 2025 moratorium

For the 2024/25 season, clubs such as Manchester United/Nice and Manchester City/Girona were forced to enter into an absolute prohibition on player movements, permanent or loan, direct or indirect, until September 2025. This moratorium is exhaustive, covering:

1. Direct transfers: Any transfer of registration between the two clubs in the same competition tier.
2. Indirect transfers: Moving a player from a third satellite club within the same MCO group.
3. Pre-existing agreements: Generally, only transfers entered into before the opening of CFCB proceedings are exempted, though even these are scrutinised for potential conflicts.

The Savio case illustrates the impact of this workaround. The winger was on loan at Girona from fellow CFG club Troyes, but Manchester City’s move for the player had to be delayed because of the regulatory freeze. For an owner, this means that the feeder club or development pathway model is effectively paralysed for the duration of the clubs’ dual participation in European football.

Workaround 5: Financial independence and debt structuring

UEFA’s May 2024 guidance expanded the definition of decisive influence to include financial interdependence. Owners who provide a significant portion of a club’s liquidity, often via GP-level credit facilities or parent company loans are deemed to exercise influence even without voting control.

To achieve compliance, MCOs must ensure that each club has independent financing. This involves:

• Stand-alone credit lines: Ensuring that individual clubs have their own ring-fenced credit facilities that do not rely on cross-guarantees from other clubs in the portfolio.
• Revenue diversification: Ensuring that owner-linked entities do not provide more than 30% of the club’s total revenue.
• Fair market value assessments: In the Premier League and for UEFA competitions, any commercial deal with an associated party must be submitted for FMV assessment to ensure it is not an artificial or disguised capital injection.

Economic dependency is viewed as a lever of control. If a club is financially reliant on a parent entity for its day-to-day survival, that parent entity is deemed to have the capacity to influence sporting decisions. Owners must therefore prove that each clu is a self-sustaining entity or that its funding sources are diversified beyond the primary investor.

Timing

One of the most critical aspects of modern MCO compliance is not a structural workaround, but a procedural one: timing.In October 2024, UEFA moved the compliance assessment date from June to March 1st. This shift has profound implications for how owners must structure their portfolios.

The Court of Arbitration for Sport has upheld the March 1st deadline as a hard and non-negotiable snapshot. The CAS panels in the 2025 cases established three critical principles:

1. The “potential” standard: UEFA does not need to establish that an owner actually intervened in management; the mere capacity to do so as of March 1st is sufficient for a breach.
2. No post-deadline cures: Restructuring measures, share sales, or board resignations implemented after March 1st cannot retroactively cure a breach that existed on the assessment date.
3. Proactive compliance: Because league standings are not finalised until May, owners must act on the hypothetical risk of qualification. If there is even a small chance that two clubs in an MCO group could qualify for the same competition, the owner must complete the decoupling by the winter.

The failure to meet this deadline resulted in the demotion of Crystal Palace to the Conference League in 2025, despite the club having qualified for the Europa League on sporting merit. The planned sale of John Textor’s stake had not been finalised by March 1st, and CAS ruled that the subsequent progress was irrelevant to the assessment of the breach.

Intersection of national and international regulation

Owners must also navigate a dual-frontier where national-level regulations are increasingly harmonised with UEFA’s Article 5.

The UK’s introduction of the Independent Football Regulator adds a layer of statutory oversight. A primary condition of the IFR license is a “robust corporate governance structure” that protects the club from systemic risk within a wider ownership group. The IFR’s Owners, Directors, and Senior Executives (ODSE) test is more rigorous than previous versions, auditing the source of wealth and the viability of the group’s financial plan.

Portuguese law 39/2023

In Portugal, Law 39/2023 establishes a stricter formal criterion than UEFA’s qualitative decisive influence test. It prohibits any natural or legal person with a qualifying holding in one sports company from simultaneously holding a qualifying holding in another participating in national competitions of the same sport. This means that while UEFA might tolerate a 29.9% stake, national laws may have lower or more rigid thresholds that preclude MCO structures entirely within the domestic sphere.

Strategic implications

The analysis of the current regulatory environment indicates that the era of reactive ownership management is over. Owners who wish to maintain multiple clubs in European competition must move toward a model of passive portfolio investment rather than active MCO synergies.

Summary of alternatives to blind trusts

The transition of UEFA’s MCO regime from a system that tolerated reactive fixes to one requiring proactive, permanent compliance has profound implications for investors. The ability to cure conflicts once qualification is certain has been eliminated, forcing a radical re-calibration of how value is derived from the multi-club model.

2026/27 and beyond

As we look toward the 2026/27 season, UEFA has confirmed that the March 1st deadline will remain binding. The governing body is showing no flexibility, despite pleas from smaller clubs regarding the high cost of compliance with hypothetical scenarios. The common sense solution proposed by some, allowing post-deadline changes, has been flatly rejected by both UEFA and CAS, which prioritise certainty and smooth organisation over investor flexibility.

The maturation of the MCOs means that a club’s legal and financial architecture is now as important as its sporting results. For owners, the primary workaround to the blind trust is the total and permanent separation of their assets, ensuring that each club can prove it operates as an autonomous entity in the eyes of the law, the regulator, and the public. Failure to do so results in a regulatory offside trap, where sporting success is negated by administrative non-compliance.

Conclusion

The structural transformation of football ownership requires a concomitant transformation in regulatory strategy. For the owner of two clubs competing in the same UEFA competition, the analysis of Article 5 and its 2025 jurisprudence suggests several definitive conclusions.

First, the blind trust is a diminishing asset. While it provided a temporary bridge for the 2024/25 transition, it is increasingly viewed as an insufficient mechanism for addressing the potential for influence. Owners must move toward permanent structural divestment or governance firewalls.

Second, the March 1st deadline is the primary risk factor. Any restructuring intended to resolve an MCO conflict must be fully executed and legally binding by the end of the winter transfer window. The reactive approach, waiting for league positions to stabilise, is no longer a viable strategy.

Third, horizontal synergies are the primary evidence of breach. To maintain two clubs in the same European competition, an owner must dismantle shared scouting networks, common data platforms, and inter-club commercial agreements. The commercial value of the MCO must be decoupled from the sporting performance of the individual assets.

Finally, where desirable or possible, the 29.9% threshold combined with board resignation remains the most effective workaround. This dilution strategy preserves a significant economic interest while removing the regulatory triggers of Article 5. For the modern football investor, navigating this landscape requires a meticulous, proactive approach to corporate governance that prioritises the integrity of the competition above the operational efficiencies of the portfolio.

In the case of the Friedkins (and anyone else), it is clear that the blind trust is not a viable option. However, workarounds exist, and will be evidenced in the future, should both AS Roma and Everton qualify for the same European competition.