November and December 2025 Roundup
A roundup of football law news and decisions from November and December 2025:
Cristiano Ronaldo to appear at FIFA World Cup 2026 opener despite red card
Cristiano Ronaldo (“CR”) received a direct red card during Portugal’s FIFA World Cup 2026 qualifying match against the Republic of Ireland (“ROI”) on 13 November 2025, following CR elbowing ROI’s Dara O’Shea.
Articles 9.4-5 of the Regulations of the FIFA World Cup 2026 Preliminary Competition (“FWC PC Regulations”) state:
‘4. If players or team officials are sent off as a result of a direct or an indirect red card, they will be automatically suspended from their team’s subsequent match. In addition, further sanctions may be imposed by the FIFA Disciplinary Committee.
5. Any match suspension resulting from a player or team official being sent off (as a result of a direct or an indirect red card) that cannot be served during the preliminary competition of the FIFA World Cup 2026™ (due to the team’s elimination or last match in the competition) will be carried over in accordance with the relevant provisions of the FIFA Disciplinary Code’.
Accordingly, the standard or automatic punishment for CR’s offence under the FWC PC Regulations is a one-match ban, subject to any further sanction imposed by the FIFA Disciplinary Committee.
Article 56.2(c) of the FIFA Disciplinary Code (“FDC”) provides the FIFA Disciplinary Committee with jurisdiction to extend the duration of a match suspension incurred automatically by a sending-off.
Article 14.1(h) of the FDC identifies that players shall be suspended for ‘at least three matchers for violent conduct’. Article 14.1(i) also identifies that players shall be suspended for at least three matches for ‘assault, including elbowing, punching, kicking, biting, spitting at or hitting an opponent or a person other than a match official’.
IFAB’s laws of the game, which are one of the bases upon which the FIFA Disciplinary Committee bases its decisions (see FDC, article 5(a)) define ‘violent conduct’ as:
‘Violent conduct is when a player uses or attempts to use excessive force or brutality against an opponent when not challenging for the ball, or against a team-mate, team official, match official, spectator or any other person, regardless of whether contact is made.
In addition, a player who, when not challenging for the ball, deliberately strikes an opponent or any other person on the head or face with the hand or arm, is guilty of violent conduct unless the force used was negligible’.
Accordingly, CR’s conduct should have resulted in a three-match ban.
However, on 25 November 2025, it was announced that CR was sanctioned with only an immediate one-match ban, and a further two-match ban suspended on condition that no similar offence is committed by CR within one year.
It is unclear on what basis CR achieved a more lenient sanction than that which should ordinarily be imposed, however article 25 of the FDC states the following:
‘1. The judicial body determines the type and extent of the disciplinary measures to be imposed in accordance with the objective and subjective elements of the offence, taking into account both aggravating and mitigating circumstances.
[…]
3. When determining the disciplinary measure, the judicial body shall take into account all relevant factors of the case, including any assistance of and substantial cooperation by the offender in uncovering or establishing a breach of any FIFA rule, the circumstances and the degree of the offender’s guilt and any other relevant circumstances.
4. In exercising its discretionary powers, the relevant FIFA judicial body may scale down the disciplinary measure to be imposed or even dispense with it entirely’.
Further, article 27.1 of the FDC states that the FIFA Disciplinary Committee ‘may decide to fully or partially suspend the implementation of a disciplinary measure’.
As CR served a one-match ban during Portugal’s FIFA World Cup 2026 qualifying match against Armenia on 16 November 2025, CR will therefore be able to participate from the start of Portugal’s participation in the FIFA World Cup 2026.
Milutin Osmajić sanctioned with nine-match ban and £21,000 fine
Preston North End’s (“PNE”) Milutin Osmajić (“MO”) has been sanctioned with a nine-match ban and a £21,000 fine following a decision of a FA Regulatory Commission which found that a charge against MO that he had committed an aggravated breach of the FA Rules, rr. E3.1 and E3.2 (“Aggravated Breach”) had been proven.
MO was found to have used the words ‘fuck you, fuck your black mother’ against Burnley FC’s (“BFC”) Hannibal Mejbri (“HM”) during PNE’s English Football League match against BFC on 17 March 2025.
Paragraphs 69 to 75 of the Regulatory Commission’s decision provide the key factual findings in determining that the charge had been proven, and which in this author’s experience are crucial points to consider when considering defending a charge of an Aggravated Breach:
’69. In our view the immediacy of HM’s reaction and the nature of it are significant factors in this evidence […] As soon as it had been said HM became extremely animated and went directly to the referee. He shortly afterwards complained that the words, “Fuck you, fuck your black Mother” had been said to him by MO. In all the circumstances we conclude that HM would comfortably have been able to hear what was said to him and that he did hear it […]
70. The manner and content of HM’s evidence impressed each member of this Commission. We found him to be an honest witness and we each assessed his overall evidence positively and all agreed that it was compelling. We conclude his evidence was cogent, appeared to be without embellishment and was consistent from the time he first approached the referee […]
72. In relation to MO’s evidence, we agree with the suggestion from Ms Deasy that the footage shows he was frustrated by his failure to control the ball. MO reacted to that and had become provoked. He accepted the mocking was not pleasant and he felt uncomfortable as a result of it. He agreed that he wanted to get back at HM for what he did, that he had lashed out in a verbal attack and that the mocking had got the better of him. We are satisfied that in that moment, he reacted and in doing so used the words “Fuck you, fuck your black mother.’
[…]
74. MO’s account of what he had been told of the allegation and when was not clear. In his evidence he said that whilst he was on the pitch, he did not know the words he had been accused of saying. In large part he maintained that stance, but it was put to him that in interview, he said other Burnley players came to him and claimed that I said, “that word” and he was asked to explain what he meant by “that word.” Initially he continued to deny he knew anything of the precise allegation but later, in response to questions from the Commission he accepted he had been accused on the pitch of using the word ‘black.’
75. It is clear to us that MO knew, at that time, that he was being accused of a racist act which included the word black. By his own admission, he did not at that point give anyone on the pitch his account of what he had said, instead all he did was make a general denial. We agree with the FA that it is more likely than not the reason MO did not immediately protest his innocence in detail is because he had not at that point come up with the alternative explanation of ‘fuck you bad man.’ MO agreed that on the pitch he knew he was accused of using the word black and he agreed ultimately that Mr Kitchen was correct in saying HM's allegation was read to him before he gave his first account to the official. In our view there was sufficient information available to MO and for some time before the meeting in the referees changing room, to allow him to try and fit his explanation as best he was able around the allegation that he knew was being made against him. We conclude it is more likely than not this is what he did’.
In respect of the sanction imposed on MO, the Regulatory Commission applied the Standard Sanctions and Guidelines for Aggravated Breaches (see FA Disciplinary Regulations, Part A: General Provisions, Section Two, para. 47 and Appendix 1) (“the Sanction Guidelines”).
The Sanction Guidelines identify that an Aggravated Breach attracts an immediate suspension of between six to 12 matches (“the Sanction Range”), with a six-match suspension being the “Standard Minimum”. The Sanction Guidelines list a number of non-exhaustive aggravating and mitigating factors, and also identify that:
‘A Regulatory Commission shall take all aggravating and mitigating features into account, including but not limited to those listed in the guidelines when determining the level of sanction within the Sanction Range.
[…]
A Regulatory Commission will have due regard to the circumstances and seriousness of the incident when determining the appropriate sanction […]’.
The Sanction Guidelines also permit a Regulatory Commission to ‘impose any one or more of the other penalties as provided by paragraph 41 of Part A to the Disciplinary Regulations’, which include a fine, and that any Participant found to have committed an Aggravated Breach ‘shall be made subject to an education programme, the details of which will be provided to the Participant by The Association’.
The Regulatory Commission noted that ‘There was a deliberate choice by MO to use the words he did and although we acknowledge he said those words only once and that it was said in response to come mocking, nothing about HM’s behaviour was outside that which occurs regularly on football pitches […] It certainly did not warrant the response it received’ (see paragraph 85 of the written reasons). The Regulatory Commission also noted that the incident was of a ‘public nature […] playing out as it did in front of a significant crowd of approximately 21,000 and covered on television in front of a much larger audience’ (paragraph 86). The Regulatory Commission also noted MO is a player with a high profile, playing in the EFL and for the Montenegro international team, and that in October 2024 MO had received an 8-match ban and a £14,000 for biting another player during an EFL match (as explained in Football Law’s October 2024 Roundup) (see paragraphs 87-88).
MO failed in establishing any mitigating factors, and the Regulatory Commission therefore proceeded to impose the sanction of a 9-match ban and a £21,000 fine, in addition to MO being required to attend an education programme (see paragraphs 94 and 96-97).
Of note to practitioners is that the Regulatory Commission’s decision makes only passing reference to the FA Appeal Board’s decision in The FA v Louza (David Casement KC) 18 November 2022 (see paragraphs 14 and 15), which was fully considered in Football Law’s Article The FA v Louza: One Standard of Proof to Rule Them All).
Further, the Regulatory Commission’s decision shows a further application and endorsement of paragraphs 59-61 of the Appeal Board’s decision The FA v John Yems (Ch. Christopher Quinlan KC) 13 April 2023 and the proper approach to the liability stage of Aggravated Breaches of this nature (see paragraphs 8-12). Paragraphs 59-61 of the Appeal Board’s decision in Yems state:
59. The correct approach to such cases is not controversial. The test for breach of Rule E3.1 is objective. The question is simply whether the words and/or behaviour are objectively abusive or insulting. This is a matter for the Regulatory Commission to decide, having regard to all the relevant facts and circumstances of the case. It is not necessary to prove that the alleged offender subjectively intended his words or behaviour to be threatening, abusive, indecent or insulting
60. Further, in respect of an ‘Aggravated Breach’ contrary to Rule E3.2 it is a question of fact whether a breach of Rule E3.1 includes a reference to a protected characteristic. That too is to be answered objectively and no question of subjective intention arises.
61. When determining liability in a case involving an ‘Aggravated Breach’ the Regulatory Commission (or indeed Appeal Board) is not required to determine whether the Participant is or is not, for example, a racist. It is not uncommon for Commissions to express such an opinion. It is not required to do so. Nor often will it be well placed to do so as it would require Commissions to engage in an exercise of assessing and judging an individual's personal beliefs or prejudices. Further, to do so risks leading the Commission into serious error, in respect of the correct approach to liability or sanction or both. Instead of expressing such views, Commissions must at the liability stage focus solely on whether, assessed objectively, each of the ingredients of the Rule E3.2 breach is proved so as to establish liability’.
Sheffield Wednesday FC sanctioned with a further six-point deduction
As explained in Football Law’s September and October 2025 Roundup, Sheffield Wednesday FC (“SWFC”) had been sanctioned with an immediate 12-point deduction on 24 October 2025 following SWFC entering administration.
On 1 December 2025, SWFC and the EFL announced that SWFC had been sanctioned with a further immediate six-point deduction ‘for multiple breaches of EFL Regulations relating to payment obligations, with Mr Dejphon Chansiri prohibited from being an owner or director of any EFL Club for a period of three years’.
Further details or written reasons for that decision had not been released at the time of that announcement. However, Football Law’s May and June 2025 Roundup explained that SWFC and Mr Chansiri had been charged in respect of failures to pay players’ wages on time and in full in March 2025 and May 2025, and it is understood that this latest decision and sanction relates to that charge.
The announcement also stated:
‘While matters remain ongoing in respect of the issues being considered by the independent Club Financial Reporting Unit, for alleged breaches in the 2025/26 season prior to the Club entering administration, the League can confirm that it is not seeking any further points deductions from the Club. A full statement will be issued once these matters have been formally concluded.
Separately, the EFL and Sheffield Wednesday remain in discussions regarding its appeal against the fee restriction, which is currently set to run until the end of the winter 2027 transfer window. This is likely to be resolved as part of the Club’s exit from administration’.
On 19 December 2025, the EFL announced that an agreed decision has been entered between the EFL, SWFC and Mr Chansiri reflecting the above (and seemingly dealing with additional charges against SWFC and Mr Chansiri, albeit all relating to late payments of wages, transfer or loan fees and HMRC liabilities, and failures to report the same to the EFL). The agreed decision is available here, and which also identifies that SWFC has been sanctioned with an £85,000 fine.
Premier League clubs approve amendment to financial rules
On 21 November 2025, the Premier League (“PL”) announced that its clubs had voted in favour of introducing ‘Squad Cost Ratio and Sustainability and Systematic Resilience, a new set of financial rules which will come into effect from 2026/27 season’.
The announcement stated:
‘[Squad Cost Ratio (“SCR”)] will regulate clubs’ on-pitch spending to 85 per cent of their football revenue and net profit/loss on player sales. Clubs will have a multi-year allowance of 30 per cent that they can use to spend in excess of the 85 per cent. Utilising this allowance will incur a levy and once the allowance is exhausted, they will need to comply with 85 per cent or face a sporting sanction.
The new SCR rules are intended to promote opportunity for all clubs to aspire to greater success and brings the League’s financial system close to UEFA’s existing SCR rules which operate at a threshold of 70 per cent. The other key features of the League’s new system include transparent in-season monitoring and sanctions, protection against sporting underperformance, an ability to spend ahead of revenues, strengthened ability to invest off the pitch, and a reduction in complexity by focusing on football costs.
The Sustainability and Systemic Resilience [(“SSR”)] rules assess a club’s short, medium and long-term financial health through three tests – Working Capital Test, Liquidity Test and Positive Equity Test’.
The PL Handbook has not yet been updated to include the SCR rules and the SSR rules (and nor have they otherwise been made publicly available), and the current Profitability and Sustainability Rules remain in place until the end of the current 2025/26 season.
However, the PL has produced a helpful and detailed explainer of the SCR and SSR, which is available here.
Independent Football Regulator
As explained in Football Law’s September and October 2025 Roundup, on 27 October 2025, the Department for Culture, Media & Sport (“DCMS”) released draft guidance on the meaning of ‘significant influence or control’ (“the SIC Guidance”) in accordance with Schedule 1, Part 2, para. 15 of the Football Governance Act 2025 (“FGA 2025”).
The SCI Guidance has now been formally published, and is available here, along with a short explanatory note.
The DCMS’s announcement of the publication of the SIC Guidance explains:
‘The examples in this guidance are not a complete list of all possible situations, nor should the guidance be read as an exhaustive statement of what constitutes significant influence or control.
When applying and interpreting this guidance careful consideration should be given to the facts of the particular case which will be important in determining whether significant influence or control exist in any particular case’.
As identified in the Independent Football Regulator’s (“IFR”) announcement publishing the Consultation Paper on the Licensing Regime under the FGA 2025 (“the Licensing Regime Consultation Paper”) in October 2025:
‘[…] the IFR is currently working towards licensing clubs ahead of the 2027/28 season, with the provisional licence approval process conducted during the 2026/27 season’.
That consultation closed on 8 December 2025, with the IFR now considering responses to the same and, in time, consulting further on draft rules to give effect to the provisional licensing process. Those draft rules will include guidance explaining key elements of the provisional licensing process, application forms, and details of the mandatory licence conditions.
The Licensing Regime Consultation Paper provided details on the anticipated provisional licensing process, in addition to details on financial reporting requirements that football clubs will need to comply with as part of that process and thereafter.
Football clubs should now start considering the SIC Guidance and the Licensing Regime Consultation Paper in anticipation of the provisional licensing process coming into effect. Pinsent Masons LLP has developed a self-assessment tool for football clubs to assess their readiness to comply with the requirements identified in the Licensing Regime Consultation Paper and the FGA 2025, which is available here.
Finally, the Football Governance Act 2025 (Specified Competitions) Regulations 2025 came into effect on 24 November 2025, defining ‘specified competitions’ subject to the FGA 2025, and the Football Governance Act 2025 (Commencement No. 2) Regulations 2025 were made on 8 December 2025, bringing into force numerous provisions of the FGA 2025 on 12 December 2025.
UEFA Circular confirms 1 March deadline for MCO submission
On 8 December 2025, UEFA released Circular 69/2025 (“the 69/2025 Circular”), addressing the continued application of Article 5 of UEFA’s club competition regulations, in particular: football clubs’ requirement to confirm compliance with UEFA’s multi-club ownership (“MCO”) rules by 1 March in the season before they may qualify for a UEFA club competition.
As explained in Football Law’s August and September 2025 Roundup, Crystal Palace FC (“CPFC”) was removed from the UEFA Europa League (“UEL”) and required to play in the UEFA Conference League due to failing to comply with the deadline in article 5 of UEFA’s Regulations of the UEL.
The 69/2025 Circular identifies the following after CPFC’s unsuccessful appeal to the Court of Arbitration for Sport (“CAS”) against that decision (and other football clubs’ unsuccessful appeals against similar decisions):
‘The UEFA Executive Committee has confirmed, at its meeting of 3 December 2025, that the 1 March assessment date provided in Article 5.01 of the UEFA club competition regulations will continue to apply for the 2026/27 season. The assessment date is the deadline by which clubs must comply with the multi-club ownership criteria provided in Article 5.01 of the UEFA club competition regulations.
This confirmation by the UEFA Executive Committee acknowledges the findings of three separate awards rendered by the Court of Arbitration for Sport (CAS) in respect of the appeals lodged by clubs whose admission to the 2025/26 UEFA club competition for which they had qualified through their domestic competition had been refused by the UEFA Club Financial Control Body due to their non-compliance with Article 5.01 of the UEFA club competition regulations as at 1 March 2025. In these awards, the CAS found that the assessment date of 1 March provided in Article 5.01 of the UEFA club competition regulations was a strict deadline for compliance with the multi-club ownership criteria.
The UEFA Executive Committee also confirmed that no substantial changes to Article 5 of the UEFA club competition regulations would be adopted for the 2026/27 season’.
Readers should note that the CAS’s written reasons for dismissing CPFC’s appeal are now available here, along with the CAS’s written reasons in dismissing similar appeals brought by FK DAC and Drogheda United FC. This author will be writing an article for LawInSport in early 2026 explaining and analysing those three decisions.
23 December 2025