European Multi-Club Regulations in Professional Women’s Football

UEFA Regulations

• An identical regulation applies in women’s football as the men’s game.
• Article 5 of the UEFA Regulations prohibits two or more teams who are owned/controlled by the same entity from competing in the same European competition (i.e. Women’s Champions League or Europa Cup).
• Should two or more clubs fail to meet this criteria, only one of them may be admitted into the relevant competition.
• That club is the one who ranks highest in its respective domestic competition. If that is equal, it comes down to which national association (e.g. FA for WSL clubs) is ranked higher in the “access list” by UEFA[1], with the “higher” team retaining their spot.

Potential solutions

• The owner/controller could divest in one of the clubs but this may not be desirable and obviously undermines broader group structure strategies designed to operate across multiple clubs.
• Shareholding could also be structured in such a way so that the relevant threshold for “control” is not reached, e.g. by acquiring a stake but of only “non-voting” shares (as was utilised by Tony Bloom in his investment into Heart of Midlothian).
• In the men’s game, the rules have been navigated and workarounds have been considered and approved by the UEFA Club Financial Control Body (CFCB), the body appointed by UEFA to oversee UEFA’s Club Licensing and Financial Sustainability Regulations. Recent examples include City Football Group and INEOS who implemented ‘blind trusts’ in respect of Girona FC and OGC Nice, respectively, for the 24/25 season, and again INEOS in respect of Lausanne-Sport for the 25/26 season.
• The blind trust is a legal mechanism by which the relevant shareholder transfers its entire legal and voting rights in one club to an independent trustee for a defined period, while retaining only the beneficial interest.
• Note that blind trust structures severely hamper ability of the beneficial owner/controller to be involved in decision-making/governance (including operational and sporting) and provide financial support.

Points to note about blind trusts

• Blind trust structures severely hamper the ability of the beneficial owner/controller to be involved in decision-making/governance (including operational and sporting) and provide financial support, unless approved by UEFA. This may be particularly problematic in the women’s game if the women’s club is dependent on ongoing financial support from the beneficial owner/controller.
• Blind trusts currently need to be in place by 1 March in the year ahead of the upcoming football season (i.e. 1 March 2026 in advance of the 26/27 football season), i.e. before European competition qualification has been confirmed. The onus is on the relevant club to declare any issues and put structures in place pre-emptively. UEFA have taken a strict approach in enforcing this deadline, as seen by the treatment of Crystal Palace FC and their demotion to the UEFA Conference League for the 25/26 season.
• The blind trusts will need to be in place for a significant period i.e. March 2026 to July 2027 in respect of the 26/27 season. The UEFA CFCB can also apply conditions post-season e.g. transfer restrictions.

Considerations for MCO women’s clubs

Clubs and their owners who are part of MCO structures in the women’s game may wish to start thinking about some or all of the following to be on the front foot ahead of any potential clash:

• Is there a risk of Article 5 being engaged, i.e. multiple clubs part of the same MCO structure qualifying for the same competition?
• If so, what workarounds can/should be implemented?
• When do such steps need to be taken by?
• Keep under review the regulatory landscape for any relevant changes e.g. a potential change to the 1 March deadline.

If you require further information and/or would like to discuss in more detail, please contact our Head of Women’s Football Harriet Leach (harriet.leach@onsidelaw.co.uk) or Lily Elliott (lily.elliot@onsidelaw.co.uk), a Senior Associate in our Disputes and Regulatory team.