July and August 2025 Roundup
A roundup of football law news and decisions from July and August 2025:
FA fail in charge brought against Paqueta for alleged breach of anti-betting rules
As explained in Football Law’s May 2024 Roundup, Lucas Paqueta (“LP”) had been charged with breaches of the FA Rules, r. E5.1 and F3.
On 31 July 2025 it was announced that:
The four charges brought under FA Rules, r. E5.1 (that LP directly sought to influence the progress, conduct, or any other aspect of, or occurrence in four Premier League matches by intentionally seeking to receive a card from the referee for the improper purpose of affecting the betting market in order for one or more persons to profit from betting) had not been proven.
The two charges under FA Rules, r. F3 (failures to comply with his obligations to answer questions and provide information to The FA's investigation) had been proven.
The FA Regulatory Commission’s written reasons are available here, which at 314 pages long is understood to be the longest sports disciplinary decision ever given (for now).
A further hearing is due to take place to determine the sanction to be imposed on LP for his breaches of FA Rules, r. F3, albeit the Regulatory Commission indicated that ‘any sanction imposed [on LP] will be at the lower end of the scale’ (see paragraph 945).
Very well done to Alastair Campbel (Level), Nick De Marco KC (Blackstone Chambers) and Kendrah Potts (4 New Square) on achieving a brilliant outcome for LP. The case provides a leading example of successfully challenging and undermining the evidence relied upon by a sports governing body in support of a disciplinary charge, particularly in circumstances where only circumstantial evidence, rather than direct evidence, is relied upon. The effective use of cross-examination and expert evidence is present throughout the Regulatory Commission’s assessment of the evidence. Of note from the Regulatory Commission’s decision are the following (focusing on the FA Rule, r. E5.1 charge):
The FA relied upon non-independent expert evidence in analysing the FA’s betting data. The FA’s submission that this witness’ evidence could be treated as akin to an independent expert because they had ‘shown the impartiality that would have been expected of an independent expert’ was not accepted (see paragraphs 103-112). This was considered to be a flaw in the FA’s case (see paragraph 568). Comparatively, LP relied upon independent expert evidence in respect of the FA’s betting data analysis, whose evidence was accepted by the Regulatory Commission (see paragraph 177).
The bets placed and which were the focus of the charges under FA Rules, r. E5.1 were all placed in Brazil. However, the betting data relied upon by the FA only represented between c. 14% to 32% of the Brazilian betting market, and therefore reliance placed upon “suspicious betting patterns” derived from a small proportion of the entire Brazilian betting market carried less weight (see paragraphs 212 to 218).
The FA’s submissions to the Regulatory Commission differed from and disagreed with the position outlined in the FA’s non-independent expert’s evidence, the former stating that LP had passed on information (about receiving a card in an upcoming match) to one or more individuals that had the spread to others, whereas the latter indicated that the betting patterns were ‘hugely orchestrated’ (see paragraphs 221-239; see also paragraphs 257-259, 302 and 531). The Regulatory Commission noted that this resulted in an appearance that the ‘FA was not altogether certain what case it was presenting against [LP]’ (see paragraph 239).
The absence of high or maximum stakes being placed in the bets concerned demonstrated a lack of confidence or actual insider knowledge that one would expect in a spot-fixing operation (see paragraphs 278-279).
LP also relied upon independent expert evidence from an actuary, which concluded that performance statistics relied upon by the FA were inappropriate and did not prove any misconduct by LP, and that there were logical flaws in the way the statistics were calculated and presented (see paragraphs 616-637, 717-718, 759 and 792). The FA’s performance statistics expert was also considered to not be independent of the FA (see paragraphs 679 and 772) and suffered from confirmation bias arising from the match incidents being considered through an assumed level of suspicion because of the investigation into and charges against LP (see paragraphs 684-691 and 774-777).
Diarra claims for compensation
As explained in Football Law’s article ‘Diarra: Tout ou Rien?’ (written by Thomas Horton, Kat Pijetlovic and Chrisopher Flanagan), on 4 October 2024 the Court of Justice of the European Union (“CJEU”) decided that article 9.1 and parts of article 17 of FIFA’s Regulations on the Status and Transfer of Players (“RSTP”) are contrary to (subject to any justification) articles 45 and (subject to any permitted exemption) 101(1) of the Treaty on the Functioning of the European Union.
The CJEU’s decision arose from a claim brought by former French footballer Lassana Diarra (“LD”) against FIFA and Union Royale Belge des Sociétés de Football Association (“URBSFA”) seeking damages for loss of earnings surrounding LD’s termination of his playing contract with FC Lokomotiv Moscow in 2014 and LD’s subsequent inability to obtain employment with Belgian football club Royal Charleroi SC for a period thereafter due to the operation of the above-stated provisions of the RSTP.
On 18 August 2025, FIFPRO announced that LD is now also pursuing a claim for compensation before the Belgian courts for damages resulting from the operation of the above-stated provisions of the RSTP, which are said to be in addition to those pre-existing proceedings still before the Mons Court of Appeal (the court that made the request to the CJEU in the first instance):
‘These proceedings represent, together with those being held in the Mons Court of Appeal, the continuation of the case [LD] originally filed in 2015. The decision to pursue litigation followed unsuccessful attempts at amicable settlement, with FIFA declining to engage constructively to resolve the rightful demand by the player to be compensated for his career losses’.
A statement released by Dupont-Hissel, the law firm representing LD, identifies that LD’s compensation claim is valued at €65 million. In that same statement, Martin Hissel of Dupont-Hissel stated:
‘Following a ruling by the CJEU, in the absence of an amicable solution, the next logical step is to return to the national courts so that they can implement the CJEU ruling. This is therefore what we are doing now, on the basis of a very clear CJEU ruling that has settled all the key legal points. The Belgian courts should hand down their decisions in 12 to 15 months. It should be noted that, in accordance with EU law, the URBSFA and FIFA will be jointly and severally liable for the damages awarded to our client by the Belgian court.
It should also be noted that, based on the CJEU ruling, all players who had or still have to pursue their careers under the illegal FIFA rules (i.e. all professional players who played or are playing in an EU Member State or in the UK, since 2002) are entitled to compensation (i.e. not only players who, like [LD], suffered specific damage as a result of these FIFA rules, such players being able to obtain - in addition - compensation for this specific damage)’.
Mr Hissel’s comments also come following a press release from Justice for Players provided to Football Law on 5 August 2025 which stated:
‘The Justice for Players Founda(on (“JfP”) is launching a class action in the Netherlands against [FIFA] and several national football associations on behalf of professional football players, men and women, who have played for football clubs in member states of the European Union and the United Kingdom since 2002.
- JfP is fighting for the rights of professional football players and to secure compensation for players whose earnings were compromised as a result of FIFA’s restrictive rules on termination of contracts and transfers (the “FIFA Regulations").
- This legal action has been launched following [the CJEU] ruling in October 2024, which found that the FIFA Regulations are unlawful in the case against FIFA brought by [LD] and the international players' unions, FIFPRO Europe/FIFPRO World, the international players’ unions.
- JfP has instructed Netherlands-based law firm Finch Dispute Resolution, which specialises in class actions in the Netherlands to represent it in the class action.
- Dupont-Hissel, the law firm that represented [LD], is also advising JfP.
- This legal action is fully funded by Deminor, one of Europe’s leading providers of legal finance, so that players will not have to pay to join the legal action or assume the financial risk of this legal action’.
FIFPRO responded to JfP’s press release by stating that ‘the establishment of this foundation represents the anticipated practical response to the CJEU's Diarra judgment, effectively centralising advocacy for affected players' interests that have broad implications for the football industry’.
Crystal Palace FC excluded from UEFA’s Europa League and unsuccessful in appeal to the Court of Arbitration for Sport
As explained in Football Law’s May and June 2025 Roundup, Crystal Palace FC (“CPFC”) faced removal from UEFA’s Europa League (“UEL”) during the 2025/26 season due to (i) Eagle Football Holdings Bidco Limited (“Eagle”) owning 87.69% of Olympique Lyonnais (“OL”) and, reportedly, around 43% of CPFC (albeit it is understood this may be closer to 46%); (ii) both CPFC and OL qualifying for the UEL; and (iii) such multi-club ownership set-up being non-compliant with article 5.01 of the Regulations of the UEL.
As also explained in Football Law’s May and June 2025 Roundup, CPFC’s participation in the UEL initially depended upon whether OL could successfully appeal a decision of the Direction Nationale du Contrôle de Gestion (DNCG), the organisation responsible for overseeing and monitoring the financial performance of football clubs in France, which relegated OL to Ligue 2 due to its poor financial performance. If OL failed in that appeal against the DNCG’s decision, then, as announced by UEFA’s Club Financial Control Body (“CFCB”) on 30 June 2025, OL would be excluded from the UEL (and CPFC would be clear to participate in the UEL).
On 9 July 2025, it was announced that OL had succeeded in its appeal against the DNCG’s decision and that it had been restored to Ligue 1 (and therefore would not be excluded from the UEL).
Consequently, on 11 July 2025, the CFCB announced:
‘[…] the CFCB First Chamber pursued the assessment of the documentation submitted by [OL] and [CPFC] and concluded that the clubs breached, as at 1 March 2025, the multi-club ownership criteria foreseen in Art 5.01 of the UEFA Club Competition Regulations.
For this reason, and in accordance with the provisions set in Art. 5.02, 5.03 and 5.04 of the UEFA Club Competitions Regulations, the CFCB First Chamber decided:
- To accept [OL’s] admission to the 2025/26 UEFA Europa League; and
- To reject [CPFC’s] admission to the 2025/26 UEFA Europa League and to accept [CPFC’s] admission to the 2025/26 UEFA Conference League.
The present decision may be appealed against before the Court of Arbitration for Sport [(“CAS”)], in accordance with Articles 62 and 63 of the UEFA Statutes’ (“the 11 July 2025 Decision”).
Written reasons from the 11 July 2025 Decision are currently unavailable.
A further consequence of that decision was that Nottingham Forest FC replaced CPFC in the UEL.
It appears that the concerns around ownership of CPFC and Brøndby IF (as explained in Football Law’s May and June 2025 Roundup) did not cause any issues for CPFC’s admission to UEFA’s Conference League (“ECL”).
Nonetheless, CPFC appealed against the 11 July 2025 Decision to the CAS, as confirmed by the CAS’s media release dated 22 July 2025, which stated:
‘The appeal filed on 21 July 2025 seeks to annul the decision by the [CFCB] on 11 July 2025 which found [CPFC] and OL non-compliant with multi club ownership regulations and placed [CPFC] in the UEFA Conference League 2025/2026. Alongside the annulment, [CPFC] requests readmission to the [UEL] 2025/2026 with Nottingham Forest’s admission rejected. In the alternative, [CPFC] requests readmission to the [UEL] 2025/2026 with OL’s admission rejected’.
On 11 August 2025, a further media release from the CAS announced that CPFC’s appeal against the 11 July 2025 Decision had been dismissed, and which stated:
‘After considering the evidence, the Panel found that John Textor, founder of Eagle Football Holdings, had shares in CPFC and OL and was a Board member with decisive influence over both clubs at the time of UEFA’s assessment date. The Panel also dismissed the argument by CPFC that they received unfair treatment in comparison to Nottingham Forest and OL. The Panel considered that the UEFA Regulations are clear and do not provide flexibility to clubs that are non-compliant on the assessment date, as CPFC claimed.
This was an expedited procedure, with an operative decision rendered two and a half weeks after the appeal, filed on 21 July 2025. Unless Parties request confidentiality, a full Award (with grounds) will be made available on the CAS website in due course’.
The CAS Panel’s written reasons are currently unavailable.
The 1 March 2025 deadline contained in article 5.01 of the Regulations of the UEL was a particularly harsh deadline in the circumstances surrounding CPFC. In particular, CPFC was competing in a UEFA competition for the first time, and round five of the FA Cup did not take place until around 1 March 2025 (CPFC ultimately winning the FA Cup and consequently qualifying for the UEL).
It is, in this author’s view, impractical and commercially nonsensical to expect a club to take steps (e.g., creating a blind trust to side step non-compliance with the criteria in article 5.01 of the Regulations of the UEL) before kicking a ball in round five of a domestic club competition which, if that club ultimately wins over two months later, could result in qualification to a UEFA club competition.
Further, the absence of any saving provision in article 5 of the Regulations of the UEL (e.g., “or otherwise the club must be able to prove at the time of an appeal that the criteria in article 5.01 are met”) is stark, again, particularly in the circumstances that CPFC found itself in. The perception of protecting the integrity of a UEFA competition, in this author’s opinion, would not be undermined so long as before a club’s participation in a club competition has commenced that club can demonstrate compliance with the criteria in article 5.01 of the Regulations of the UEL.
The decision demonstrates the inherent problem presented by permitting multi-club ownership whilst concurrently regulating on the permissible extent of that multi-club ownership.
CFCB enters settlement agreements with Chelsea FC and Aston Villa FC
On 4 July 2025, the CFCB announced that settlement agreements had been entered with and sanctions imposed on Chelsea FC (“CFC”) and Aston Villa FC (“AVFC”) following those clubs’ failures to comply with the UEFA Club Licensing and Financial Sustainability Regulations 2024 (“CLFSR”), in particular with the football earnings rule (CLFSR, article 91) and the squad cost rule (CLFSR, article 94).
In respect of the breaches of the football earnings rule (which caps acceptable losses at €60 million over a three-year period (see CLFSR, articles 85-90)):
CFC entered a four-year settlement agreement, which, inter alia, imposed a fine of €80 million (€20 million of which was unconditional), imposed stricter acceptable losses over the three-year period than standardly seen in the CLFSR (subject to contributions (as defined in article 89 of the CLFSR)), and limited CFC to ‘not [registering] any new player on its List A to UEFA club competitions unless the List A Transfer Balance is positive’ which applies unconditionally for the 2025/26 and 2026/27 seasons.
AVFC entered a three-year settlement agreement, which, inter alia, imposed a fine of €20 million (€5 million of which was unconditional), imposed stricter acceptable losses over the three-year period than standardly seen in the CLFSR (subject to contributions (as defined in article 89 of the CLFSR)), and limited AVFC to ‘not [registering] any new player on its List A to UEFA club competitions unless the List A Transfer Balance is positive’ which applies unconditionally for the 2025/26 season.
In respect of the breaches of the squad cost rule (which limits a club’s expenditure on players’ and head coaches’ wages to 80% of a club’s revenues for 2024 but which is decreasing to 70% from 2025 (see CLFSR, article 97 and Annex K)):
CFC was sanctioned with an unconditional fine of €11 million.
AVFC was sanctioned with an unconditional fine of €6 million.
Nottingham Forest FC ordered to pay Premier League’s costs
Following the four-point deduction imposed on Nottingham Forest FC (“NFFC”) during the Premier League (“PL”) season 2023/24 for its admitted breach of the PL’s Profitability and Sustainability Rules (“PSR”) during the period ending season 2022/23 (as explained in this Football Law article), a PL Commission has now also ordered NFFC to pay the PL’s and the Commission’s costs arising from that decision, assessed at £530,052.71 following the PL’s application for such costs to be paid by NFFC (“the NFFC Costs Decision”).
The NFFC Costs Decision is available here, and provides a helpful reminder of the principles applicable to determining who pays and what costs are payable following PSR proceedings (see paragraphs 34 to 37 of the NFFC Costs Decision in particular).
NFFC successful in recusal of Appeal Board chairperson
NFFC has successfully applied, by way of a Rule K arbitration (see the FA Rules, section K), for, inter alia, the recusal of the chairperson of an FA Appeal Board, Graeme McPherson KC, set to hear NFFC’s appeal against a decision imposing a fine of £125,000 against NFFC for a mass confrontation that occurred during NFFC’s PL match against CFC on 6 October 2024 (“the Chelsea Decision”).
Mr McPherson KC’s apparent bias stemmed from an earlier Regulatory Commission procedural decision where NFFC was again the club facing disciplinary charges from the FA. In that procedural decision (a copy of which is unavailable from the FA’s database), Mr McPherson KC had described a submission made by NFFC as ‘somewhat hysterical’.
Paragraphs 45 and 62 of the Rule K arbitration panel’s decision provides a helpful summary on how such applications should be considered:
’45. At least in this case, it is not necessary to look beyond what is widely accepted as the classic statement of the test, as taken from the leading decision in Porter v McGill [2002] 2 AC 357, which requires us to consider whether or not the circumstances, about which there is no material factual dispute here, would lead a fair-minded and informed observer to conclude there was a real possibility of bias. The question to be answered is not whether the tribunal resolving the issue concludes that the person concerned is apparently biassed: the tribunal has to consider whether a fair-minded and informed observer would conclude that there was a real possibility that the person concerned was biassed’.
’62. […] the test for apparent bias is not a particularly high one, partly because of the importance of justice being seen to be done, and partly because, while recusal is not pleasant for the (often blameless) person who is recused, it does not have any sort of direct effect on the parties’ substantive rights (and is unlikely to have much indirect effect on those rights)’.
In applying that test to Mr McPherson KC’s description of a previous submission made by NFFC as ‘somewhat hysterical’ and deciding in NFFC’s favour, the Rule K arbitration panel stated:
’48. It seems clear to the Tribunal that it was inappropriate of the Commission to have characterised Para 31 as “somewhat hysterical”. To describe an argument as “hysterical” is inherently highly pejorative, it plainly implies heavy criticism of the argument itself, and also of the way in which the argument has been expressed. It therefore carries with it serious disapproval of the party and its representatives who advanced the argument. The adverb “somewhat” does little, if anything, to dilute this point, as it mildly qualifies, but does not undermine, the adjective that follows.
[…]
50. […] there can be no doubt but that the description of Para 31 as ‘somewhat hysterical’ can fairly be said to be, and would be seen by the notional fair-minded independent observer to be, an unjustified, inappropriate, and personal attack on the Club and its legal representatives’.
It should be noted that before NFFC made the application by way of a Rule K arbitration, NFFC had originally applied to Mr McPherson KC as chairperson of the Appeal Board in the appeal of the Chelsea Decision for him to recuse himself, but which Mr McPherson KC dismissed (see paragraphs 28-34 of the Rule K arbitration panel’s decision). It is noted that the FA Disciplinary Regulations, Part E, Fast Track 7: Appeals – Fast Track do not expressly provide a rule or procedure for challenging the appointment of an Appeal Board member and/or for procedural applications to be made to the chairperson of an Appeal Board in a Fast Track appeal (compare with FA Disciplinary Regulations, Part C, Appeals – Non-Fast Track, para. 14). Instead, and somewhat obliquely, FA Disciplinary Regulations, Part E, Fast Track 7: Appeals – Fast Track, para. 3 simply states:
‘A decision relating to a Preliminary Application made in a matter proceeding under a Fast Track shall be final and binding and there shall be no right of further challenge’.
Confirmation of the availability to make a recusal application by way of a Rule K arbitration in the circumstances of this case is welcome, albeit convoluted. The FA should consider including express regulations that provide parties with the ability to apply for the recusal of an appointed panel member in Fast Track appeals (including for the appeal against any decision dismissing such an application).
Hull City AFC sanctioned with a transfer fee restriction
Hull City AFC (“HCAFC”) had been sanctioned with a three-window transfer fee restriction following breaches of English Football League (“EFL”) Regulations, reg. 52.6.1 and 52.6(c). HCAFC’s breaches are reported to be in respect of HCAFC’s failure to pay on time sums due to AVFC for HCAFC’s loan of Louie Barry from AVFC in January 2025.
The three-window transfer fee restriction is a standard sanction applicable under EFL Regulations, reg. 52.6(c):
‘52.6 […] where any Club defaults on payment of any amounts:
52.6.1 due to any other Club (or club) (including but not limited to any Transfer Fee, Compensation Fee, Loan Fee, other contributions due pursuant to the terms of any Temporary Loan Transfer, or any subsequent payments which become due under the terms of any original transfer(s), ticket monies, or other payments pursuant to the terms of any other agreement) […]
for a period of:
[…]
(c) 30 days (whether one default of 30 days, or a number of individual defaults which when taken together amount to 30 days) or more in any 12-month period (1 July to 30 June) (‘Persistent Default’) then that Club shall not be permitted to pay or commit to pay any Transfer Fee, Compensation Fee or Loan Fee or any other form of payment (other than a sell on fee) in respect of the registration of any Player during the period:
(i) commencing on the date on which the Persistent Default occurred; and
(ii) ending three full Transfer Windows after the Persistent Default occurred
(“Fee Restriction”)’.
EFL Regulations, reg. 52.6.4 allows a club sanctioned under EFL Regulations, reg. 52.6 to appeal against the standard sanction to the EFL’s Club Financial Review Panel (“CFRP”) on grounds that (i) a debt counting towards the Persistent Default was not due and owing at that time; or (ii) the sanction was disproportionate. HCAFC appealed against the standard sanction on both grounds. An appeal to the CFRP under EFL Regulations, reg. 52.6.4 is by way of an EFL Club Financial Reporting Unit (“CFRU”) Decision Review, and is therefore conducted in accordance with EFL Regulations, Appendix 6.
On 19 August 2025, the EFL announced that the CFRP had reduced the sanction to a three-window transfer fee restriction with one window suspended on condition that HCAFC does not default by a further seven days on any payments under the remit of Regulation 52.6 before 1 July 2026.
The CFRP’s decision is available here.
The CFRP’s decision identifies that HCAFC was unsuccessful in demonstrating that a debt counting towards the Persistent Default was not due and owing at that time (see paragraph 92 of the CFRP’s decision).
The CFRP’s decision also identifies that the CFRU proposed that a proportionate sanction would be a three-window transfer fee restriction with one window suspended on condition (see paragraphs 29(b) and 58(b)). HCAFC argued that this proposed sanction was still disproportionate and sought a sanction of a one-window transfer fee restriction to be suspended on condition that HCAFC does not commit any breach of EFL Regulations, reg. 52.6.2 before 30 June 2026 (see paragraphs 53-57).
The CFRP’s decision further identifies that HCAFC was unsuccessful in demonstrating that the EFL’s proposed sanction was disproportionate (see paragraphs 95-106). The CFRP’s decisions reiterates that the principles identified in Swindon Town Football Club v EFL dated 19 January 2024, as referred to in Football Law’s January 2024 Roundup, are the relevant factors when considering the proportionality of the standard sanctions applicable under EFL Regulations, reg. 52.6 (see paragraphs 54, 64 and 94 of the CFRP’s decision).
The CFRP’s decision also provides a point of clarity concerning the grounds of an appeal or review between EFL Regulations, reg. 52.6.4 and EFL Regulations, Appendix 6, para. 6.7 (see paragraphs 12-16).
Sheffield Wednesday FC
On 18 June 2025, the EFL announced that Sheffield Wednesday FC (“SWFC”) had been sanctioned with a three-window fee restriction after exceeding 30 days of late payments between 1 July 2024 and 30 June 2025. It is understood from that announcement that SWFC is appealing against that sanction, but an outcome on that appeal has yet to be announced.
Further, on 6 August 2025, the EFL announced that SWFC’s fee restriction had been extended:
‘[SWFC] has now surpassed 30 days of late payments for the year beginning 1 July 2025. As a result, [SWFC’s] fee restriction has been extended to the end of the winter transfer window in the 2026/27 Season’.
Independent Football Regulator
The Football Governance Act 2025 (“FGA 2025”) received royal assent on 21 July 2025, establishing the Independent Football Regulator (“IFR”).
At the beginning of September 2025, the IFR announced that it had opened consultations on its Owners, Directors and Senior Executives (ODSE) regime (see FGA 2025, Part 4). Further information on this consultation is available here. The IFR is seeking views on the draft ODSE Rules, draft ODSE Guidance and draft application forms to be used by owners and senior managers.
The IFR also announced that it had opened consultations in respect of IFR’s information gathering and enforcement (see FGA 2025, Part 7 and Part 8). Further information on these consultations is available here and here.
This article by Simon Orriss, senior associate at Mills & Reeve, provides a helpful explanation of what to expect from the FGA 2025 and the IFR in the near future.
This article by Donna Bartley and Ben Cisneros, partner and associate at Morgan Sports Law respectively, also provides a helpful explanation of the procedure for challenging decisions that will ultimately be made by the IFR (see FGA 2025, Part 9).
FIFA extends temporary rules due to ongoing war in Ukraine
On 1 July 2025, FIFA announced that the Bureau of the FIFA Council had decided to extend the application of Annexe 7 of the Regulations on the Status and Transfer of Players (RSTP) until 30 June 2026. The measures were first introduced in March 2022 as a temporary response to the crisis and has provided a critical framework for managing the extraordinary employment challenges faced by players and coaches because of the war.
10 September 2025