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CAS 2025/A/11604 — Crystal Palace Football Club v. Union des Associations Européennes de Football (UEFA), Nottingham Forest Football Club & Olympique Lyonnais

"Crystal Palace" · CAS upheld UEFA's decision admitting Olympique Lyonnais to the 2025/26 UEFA Europa League and relegating Crystal Palace to the UEFA Conference League due to multi-club ownership breach.

What happened in Crystal Palace

Crystal Palace FC (CPFC) won the 2024/25 FA Cup, qualifying for the 2025/26 UEFA Europa League (UEL). Olympique Lyonnais (OL) qualified for the same competition via a cascade mechanism after PSG won both Ligue 1 and the Coupe de France. Both clubs shared a common link through John Textor, who was simultaneously Chairman/CEO of OL and a director and major indirect shareholder of CPFC through Eagle Football Holdings Bidco Limited. UEFA's CFCB First Chamber found both clubs in breach of the Multi-Club Ownership (MCO) Rule under Articles 5.01(b) and 5.01(c) of the 2025/26 UEL Regulations as at the 1 March 2025 assessment date. Applying Article 5.02, the First Chamber admitted OL (ranked 6th in Ligue 1) over CPFC (ranked 12th in the Premier League) to the UEL, relegating CPFC to the UEFA Conference League. CPFC appealed to CAS, arguing: (1) no breach occurred; (2) OL did not qualify on sporting merit so CPFC should have priority under Article 5.02(a); and (3) a post-deadline cure (Textor's share sale completed 24 July 2025) should be recognised. The CAS Panel dismissed all three grounds, confirming the Appealed Decision. The case is significant for establishing that the 1 March assessment date is strictly applied, that formal directorship constitutes 'involvement' under Article 5.01(b), and that post-deadline cures do not remedy MCO breaches.

Procedural history of CAS 2025/A/11604

On 26 May 2025, the CFCB First Chamber opened proceedings against CPFC and OL under Article 12.01 of the UEFA CFCB Procedural Rules. A hearing was held on 3 June 2025 in Nyon. On 11 July 2025, the First Chamber issued the operative part of its decision, admitting OL to the 2025/26 UEL and rejecting CPFC's admission to the UEL, instead admitting CPFC to the 2025/26 UEFA Conference League. The grounds were notified on 14 July 2025. The First Chamber found breaches of Articles 5.01(b) and 5.01(c) of the UEL Regulations as at 1 March 2025, and applied Article 5.02(b) to prefer OL (6th in Ligue 1) over CPFC (12th in Premier League). CPFC filed its Statement of Appeal with CAS on 21 July 2025, within the 10-day deadline under Article 62(3) of the UEFA Statutes. An expedited procedure was established, with the Appeal Brief filed 25 July 2025, Answers filed 5 August 2025, and a hearing held 8 August 2025 in Lausanne. The operative part of the award was to be rendered by 11 August 2025.

Key holdings in CAS 2025/A/11604

• As at 1 March 2025, CPFC was in breach of Article 5.01(b) of the UEL Regulations because Mr Textor simultaneously held formal director and partner positions at both OL and CPFC, constituting 'involvement' in the management and administration of more than one club regardless of whether those rights were actually exercised.
• As at 1 March 2025, CPFC was in breach of Article 5.01(c)(iv) of the UEL Regulations because Eagle Football Holdings Bidco Limited held 44.09% of economic rights and 39.87% of voting rights in CPFC, injected GBP 123 million representing 49% of Palace Holdco's share premium reserve, and Mr Textor held governance positions, each independently triggering the decisive influence indicators in the May 2024 Circular.
• The 1 March 2025 assessment date is strictly applied and a post-deadline cure — including the sale of Eagle Football Holdings Bidco Limited's shares in Palace Holdco completed on 24 July 2025 — does not remedy a breach of Article 5.01 of the UEL Regulations.
• Under Article 5.02(b) of the UEL Regulations, where two MCO-linked clubs both qualify on sporting merit for the same UEFA club competition, the club ranked highest in its domestic championship is admitted; OL (6th in Ligue 1) was therefore preferred over CPFC (12th in the Premier League).
• OL qualified for the 2025/26 UEL on sporting merit within the meaning of Article 5.02(a) of the UEL Regulations, as its qualification through the Article 3.03 cascade mechanism following PSG's dual qualification does not deprive it of the character of a sporting-merit-based qualification.

How the CAS panel reasoned

The Panel applied Swiss law principles of statutory interpretation — literal, systematic, teleological and historical — to Article 5.01 of the UEL Regulations. On Article 5.01(b), the Panel rejected CPFC's argument that 'involvement' requires actual, day-to-day participation, finding that holding a formal directorship or partnership position inherently constitutes involvement 'in any capacity whatsoever', consistent with the provision's broad language and its purpose of protecting both actual and perceived competition integrity. The Panel declined to follow CPFC's reliance on the Red Bull Case (AC-01/2017), which concerned Article 5.01(c), not Article 5.01(b). On Article 5.01(c)(iv), the Panel found that the May 2024 Circular's indicators — shareholding above 30%, financial support exceeding 30% of share premium, and governance positions — were legitimately issued as interpretive guidance and were each independently triggered on the facts. The Panel rejected CPFC's argument that the indicators could not be determinative, noting that only the UEFA ExCo can amend regulations but that the CFCB may clarify their application. On the post-deadline cure, the Panel found no established UEFA discretionary practice permitting cures after 1 March 2025, distinguishing the exceptional 2024/25 blind trust arrangements explicitly limited to that season. The ECA email of 25 October 2024 was not treated as evidence of a binding UEFA commitment. On Article 5.02, the Panel found both clubs qualified on sporting merit for the UEL, making Article 5.02(a) inapplicable and Article 5.02(b) determinative in OL's favour.

Why Crystal Palace matters in CAS jurisprudence

This award is the first CAS decision to apply the new 1 March assessment date for UEFA's MCO Rule and confirms its strict, non-discretionary character for the 2025/26 season. It establishes that formal directorship alone satisfies the 'involvement' threshold under Article 5.01(b), that the May 2024 Circular's decisive-influence indicators are legitimate interpretive tools, and that post-deadline share sales cannot cure MCO breaches. The award also clarifies that Article 3.03 cascade qualifications constitute sporting-merit qualifications for Article 5.02 purposes.

Cases cited in this award

CAS 98/200 (ENIC Award) CAS 2025/A/11495 CAS 2008/A/1705 CAS 2015/A/4153 CAS 2023/A/9501 C-333/21 European Superleague Company (ESL Case)

Frequently asked questions about Crystal Palace

Why was Crystal Palace relegated to the Conference League instead of playing in the Europa League they qualified for by winning the FA Cup?

Crystal Palace qualified for the 2025/26 UEL by winning the FA Cup on 17 May 2025, but the CFCB First Chamber found that as at the 1 March 2025 assessment date, CPFC and Olympique Lyonnais were both in breach of the MCO Rule under Articles 5.01(b) and 5.01(c) of the UEL Regulations due to John Textor's simultaneous roles at both clubs and Eagle Football Holdings Bidco Limited's shareholding. Under Article 5.02(b), OL (6th in Ligue 1) was preferred over CPFC (12th in the Premier League), and CPFC was admitted to the UECL under Article 5.04. CAS upheld this decision.

Did Crystal Palace's sale of John Textor's shares cure the MCO breach and allow them into the Europa League?

No. Eagle Football Holdings Bidco Limited and Mr Textor completed the sale of their shares in Palace Holdco to Mr Robert Wood Johnson IV on 24 July 2025, and Mr Textor was removed from all CPFC group positions from 17-18 June 2025. However, the CAS Panel found that the 1 March 2025 assessment date is strictly applied and that no established UEFA discretionary practice permitted post-deadline cures for the 2025/26 season. The May 2024 Circular's blind trust flexibility was explicitly limited to the 2024/25 season on an exceptional basis.

How did Olympique Lyonnais qualify for the Europa League on 'sporting merit' if they only finished 6th in Ligue 1?

OL finished 6th in Ligue 1 in 2024/25, which initially qualified them for the UECL. However, PSG won both Ligue 1 (securing UCL qualification) and the Coupe de France (securing a UEL place), triggering the Article 3.03 cascade mechanism. This shifted Lille into PSG's UEL cup-winner slot and elevated OL into the UEL. The CAS Panel held that qualification through Article 3.03 still constitutes qualification on sporting merit for the purposes of Article 5.02(a) of the UEL Regulations, making Article 5.02(b) — domestic league ranking — the applicable tiebreaker.

What was the significance of the 1 March 2025 MCO assessment date and why did it matter for Crystal Palace?

UEFA's Executive Committee moved the MCO compliance assessment date forward from 3 June to 1 March for all 2025/26 club competitions, as announced in the October 2024 Circular, to allow sufficient time for CFCB investigations and appeals before competitions begin. As at 1 March 2025, Mr Textor held director and partner positions at both CPFC and OL, and Eagle Football Holdings Bidco Limited held 44.09% of economic rights in CPFC — triggering multiple decisive-influence indicators. CPFC argued the deadline was disproportionate and that UEFA had discretion to extend it, but the CAS Panel rejected both arguments, confirming the date is strictly applied and that CPFC's non-compliance on that date was determinative.

Topics: Doping, ethics & governance at CAS

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