Football multi-club ownership (“Multi-Club Ownership” or “MCO“) is an increasingly present reality on the international stage. This business model involves a single individual or entity holding stakes in two or more football clubs, whether through direct shareholding or indirect control structures.
Indeed, the phenomenon is not unfamiliar in Portugal. Several clubs are currently part of MCO structures: for instance, SC Braga counts Qatar Sports Investments among its shareholders – the same entity that owns Paris Saint-Germain – while Rio Ave FC is controlled by Greek businessman Evangelos Marinakis, who simultaneously holds Olympiacos and Nottingham Forest FC.
This type of investment structure raises a number of issues, particularly with regard to transparency rules and the prevention of conflicts of interest that may compromise the integrity of sporting competitions.
In this regard, it is worth recalling the recent controversy surrounding the sale of two Rio Ave FC players to Olympiacos – striker Clayton and winger André Luiz – during the January 2026 transfer window. Both were the standout players of the Vila do Conde side in the first half of the season, with Evangelos Marinakis having reportedly admitted, according to several media outlets, that he turned down offers of approximately EUR 20 million for André Luiz and over EUR 10 million for Clayton, choosing instead to transfer them to Olympiacos for significantly less in order to strengthen the Greek club, which is owned by him.
A situation that took on further significance given that CF Estrela da Amadora held a 10% sell-on clause over a future transfer of André Luiz. The club announced, through an official statement[1], that it would refer the matter to the Court of Arbitration for Sport to investigate the transaction and ascertain whether the principles of economic fairness and the safeguarding of the interests of contractually involved third parties had been respected.
This case illustrates, in paradigmatic fashion, some of the potential risks inherent in multi-club structures – among them, the potential competitive weakening of hierarchically smaller clubs within the same MCO structure, the practice of intra-group transfers at below-market values, and the harm inflicted on third parties holding economic rights over the players involved.
Multi-Club Ownership also gained international prominence on the occasion of Crystal Palace FC’s registration in UEFA’s European competitions for the 2025/2026 season. The English club won the FA Cup in May 2025, qualifying for the UEFA Europa League, but its participation was refused because businessman John Textor simultaneously held an interest in Crystal Palace FC and majority control of Olympique Lyonnais, which had also qualified for the same competition. Under UEFA’s rules – namely, Article 5 of the UEFA competition regulations[2] – a natural or legal person may not hold control or exercise decisive influence over more than one club participating in the same European competition. The result: Crystal Palace FC was relegated to the UEFA Conference League, being prevented from competing in the tournament for which it had qualified on full sporting merit, which entailed not only the inability to participate in a more prestigious competition but also a negative financial impact arising from the different revenue levels between competitions.
In the wake of this case, UEFA announced its intention to partially loosen the regulatory framework. In October 2025, a “dual deadline” system was thus proposed: clubs would retain the obligation to flag potential MCO conflicts by 1 March, but would be granted an additional period, until the beginning of June, to effectively resolve any overlap issues between clubs within the same group. However, on 8 December 2025, UEFA issued a circular[3] confirming that, for the 2026/27 season, the 1 March deadline would remain as the binding assessment date.
In Portugal, the matter is regulated by Law No. 39/2023 of 4 August, which establishes the legal framework for sports companies, prohibiting any natural or legal person with a qualifying holding[4] in a sports company from simultaneously holding a qualifying holding in another sports company that participates in national competitions of the same sport (cf. Article 16(1)). Additionally, a sports company is also prohibited from holding a stake in the capital of another sports company (cf. Article 16(3)). Any breach of these rules, as well as of the associated transparency duties – which include the disclosure to the competent authorities of the entire chain of holders of interests – constitutes a very serious administrative offence (cf. Article 16(5)).
Whereas UEFA’s rules focus on the concept of “decisive influence[5]” – which encompasses not only the holding of majority interests but also situations of de facto control through shareholders’ agreements, veto rights over strategic decisions, or contractual arrangements capable of influencing the sporting or financial management of a club – Law No. 39/2023 adopts a stricter formal criterion: the 5% qualifying holding threshold.
It is therefore clear that the phenomenon of Multi-Club Ownership finds itself at a regulatory crossroads. On the one hand, its expansion appears irreversible – the volume of investment in football and the logic of asset diversification will, in all certainty, continue to drive the acquisition of interests in multiple clubs. On the other hand, the cases of Rio Ave FC and Crystal Palace FC demonstrate, each on its own scale, that the existing regulatory frameworks – at both European and national level – present weaknesses and grey areas that may compromise sporting integrity.
The question that arises is therefore inevitable: will the legislator be able to keep pace with a phenomenon that, by all indications, will remain unstoppable? With the formal evaluation of Law No. 39/2023 scheduled for September 2026 and UEFA considering adjustments to its own regulatory framework, the answer remains to be seen.
by Ricardo Cardoso e Tomás Moita, Practice Area – Sports, Fashion and Entertainment
[1] Official Statement, CF Estrela da Amadora, dated 19.02.2026, available at: OFFICIAL STATEMENT – Estrela da Amadora.
[2] 2025/26 Regulations of the UEFA Europa League, available at: https://documents.uefa.com/r/Regulations-of-the-UEFA-Europa-League-2025/26/Preamble-Online.
[3] UEFA Circular Letter No. 69/2025, available at: 20251208_circular_2025_69_en.pdf.
[4] Cf. Article 16(2) of Law No. 39/2023 of 4 August: Under the Portuguese Securities Code, approved by Decree-Law No. 486/99 of 13 November, a qualifying holding is a direct or indirect holding representing a percentage exceeding 5% of the share capital.
[5] CAS 2025/A/11604 – Crystal Palace Football Club v. UEFA, Nottingham Forest FC & Olympique Lyonnais, available at: 11604_Arbitral_Award__for_publ._.pdf: In this regard, the CAS clarified that “decisive influence” is assessed by the capacity to exercise it, and not by proof that it was actually exercised. In other words, it is a criterion of capacity, not of conduct.
