September and October 2025 Roundup
A roundup of football law news and decisions from September and October 2025:
FA to review the safety of perimeters at National League pitches
On 25 September 2025, it was reported that Billy Vigar, a striker at Chichester City FC (“CCFC”), had died following a collision with a concrete perimeter wall during CCFC’s Isthmian League Premier Division match against Wingate and Finchley FC on 20 September 2025.
Now former footballer Alex Fletcher (“AF”) also collided with a concrete perimeter whilst playing in a National League South match for Bath City FC in November 2022, sustaining a fractured skull and ultimately resulting in his retirement from football.
AF now works as part of the Professional Footballers’ Association’s Brain Health Team as a Player Support Associate.
Speaking in respect of Mr Vigar’s death, AF commented that it was ‘an entirely preventable situation’, that this will ‘will not be the last [death] if action isn’t taken’ and that there is ‘frustration that the calls for change haven’t been listened to by the FA’.
On 26 September 2025, the FA released the following statement:
‘We are deeply saddened by the passing of Billy Vigar. Our thoughts and heartfelt condolences are with his family, friends, loved ones, and everyone at Chichester City FC, and tributes will be paid to Billy at National League System and Emirates FA Cup games this weekend.
Whilst the health and safety of participants and spectators at the National League System level is the responsibility of the clubs and their local authorities, we will now conduct an immediate review, working with leagues, clubs and relevant stakeholders across the game, that will focus on the safety of perimeter walls and boundaries around pitches in the National League System’.
The deepest condolences are sent to Mr Vigar’s family and friends.
Lucas Paqueta sanctioned with a reprimand and warning
As explained in Football Law’s July and August 2025 Roundup, on 31 July 2025 the FA announced that:
Four charges brought under FA Rules, r. E5.1 against Lucas Paqueta (“LP”) (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.
Two charges under FA Rules, r. F3 (LP’s failures to comply with his obligations to answer questions and provide information to the FA's investigation) had been proven.
On 30 October 2025, the FA announced that the fine imposed on LP for his breach of the FA Rules, r. F3 was a reprimand and a warning.
The FA Regulatory Commission’s further written reasons are available here.
Whilst the starting point for LP’s breach was a financial penalty, the Regulatory Commission considered that there were significant mitigating factors in LP’s favour, which, when taken together, were sufficient to reduce the sanction to a reprimand and a warning (see paragraphs 9-11 of the written reasons). Those mitigating factors included LP’s clean disciplinary record and the collapse of LP’s potential transfer to MCFC as a consequence of the charges brought against him.
The Regulatory Commission’s further written reasons also identify that the FA has been ordered to pay 90% of the Regulatory Commission’s costs, and LP ordered to pay 10% of the Regulatory Commission’s costs (see FA Disciplinary Regulations, Part A, Section Two: Regulatory Commissions, para. 52; see also paragraph 13-19 of the written reasons).
FA charge against Chris Wilder found not proven
On 24 October 2025 the FA announced that a charge brought against Sheffield United FC (“SUFC”) manager Chris Wilder (“CW”) for an alleged breach of the FA Rules, r. E3.1 had been found not proven by an FA Regulatory Commission.
The FA’s charge against CW alleged that CW had acted in an improper manner contrary to FA Rules, r. E3.1 when CW kicked a football towards the stand and which hit a spectator during halftime in SUFC’s match against Southampton FC on 30 September 2025.
A video of the incident is available here.
The Regulatory Commission’s written reasons are available here.
CW’s evidence was that the ball going into the stands and hitting a spectator was a pure accident (see paragraph 16 of the written reasons). In particular, CW explained:
‘As I was walking, a ball came onto the field of play from almost directly in front of me, rolling in my direction, pretty much exactly onto the line I was walking on. I didn’t think much about it (I only saw it momentarily before kicking it) but assumed it had come onto the field of play by accident, given everyone was walking off and a ball wouldn’t be left on the field through half-time.
As a former player myself, I just kicked it, somewhat absent mindedly, to get it back off the field of play – and pretty much for the enjoyment of kicking a ball, in the way a player would – aiming for the side boards one sees in the camera footage, from where it could be picked up by whoever was in charge of it. There was no anger or frustration in my doing so, as one can see from my expression and body movement on the footage...
Unfortunately, as I kicked the ball, my foot got under it a bit and it rose up. Causing it to travel over the side boardings and make contact with one of our own fans behind the dugouts...
The footage shows that as soon as I realised the ball was rising and going into the stand, put my hand up in surprise, to caution the fans that the ball was coming in their direction and to apologise at pretty much the same time. I then walked up to the fan the ball had hit and picked up and handed back his glasses, apologising to him personally before walking back to the tunnel entrance thinking nothing more of it. I was then dismissed, which was a surprise to me, but I accepted it’.
The Regulatory Commission noted that the ‘task was to decide whether CW’s conduct in kicking a ball that ended up in a crowd and hit a spectator was objectively improper’ (see paragraph 24 of the written reasons).
In finding that the charge was not proven, the Regulatory Commission summarised the following at paragraph 26 of its written reasons:
‘The Commission agreed with Mr [Craig] Harris’s [(counsel for CW)] submission that the fact that the ball had gone into the crowd and hit a spectator did not mean that the kicking of the ball inevitably amounted to improper conduct. Likewise it agreed that in the absence of any suggestion that CW was deliberately aiming at the crowd, it had to consider whether by kicking the ball in the direction of the crowd, CW was acting recklessly and without regard for the consequences of his action. Had it seen evidence of anger or frustration, the Commission may have been minded to reach that conclusion. However, having watched the footage multiple times, the Commission preferred CW’s evidence on the Incident to the case advanced by Mr Phillips [(FA Regulatory Advocate)] of someone lashing at a ball in frustration with obvious disregard for the consequences’.
Manchester City FC and the Premier League announce settlement of Associated Party Transaction Rules challenge
As explained in Football Law’s January and February 2025 Roundup, Manchester City FC (“MCFC”) had brought a second challenge against the Premier League’s (“PL”) amended Associated Party Transaction Rules (“the APT Rules”) introduced in November 2024, such amendments introduced following a previous challenge by MCFC against the PL’s earlier version of the APT Rules.
On 8 September 2025, MCFC and the PL announced that a settlement agreement had been reached, which ‘brings an end to the dispute between the parties regarding the APT Rules. As part of the settlement, [MCFC] accepts that the current APT Rules are valid and binding’.
The settlement agreement has not been made publicly available.
Chelsea FC charged by the FA
On 11 September 2025, the FA announced that it had brought 74 charges against Chelsea FC (“CFC”):
‘The Football Association has today charged Chelsea FC with breaches of Regulations J1 and C2 of The FA Football Agents Regulations, Regulations A2 and A3 of The FA Regulations on Working with Intermediaries, and Regulations A1 and B3 of The FA Third Party Investment in Players Regulations.
In total, 74 charges have been brought against Chelsea FC. The conduct that is the subject of the charges ranges from 2009 to 2022 and primarily relates to events which occurred between the 2010/11 to 2015/16 playing seasons.
Chelsea FC has until 19 September 2025 to respond’.
On the same day, CFC released a statement in respect of the charges:
‘The Club’s ownership group completed its purchase of the club on 30 May 2022. During a thorough due diligence process prior to completion of the purchase, the ownership group became aware of potentially incomplete financial reporting concerning historical transactions and other potential breaches of FA rules. Immediately upon the completion of the purchase, the Club self-reported these matters to all relevant regulators, including The FA.
The Club has demonstrated unprecedented transparency during this process, including by giving comprehensive access to the Club’s files and historical data. We will continue working collaboratively with The FA to conclude this matter as swiftly as possible. We wish to place on record our gratitude to The FA for their engagement with the Club on this complex case, the focus of which has been on matters that took place over a decade ago’.
Reporting from BBC Sport indicates the following in respect of the charges:
‘The alleged rule breaches concern agents, intermediaries and third-party investments in players.
It is understood the transfers of Hazard from Lille, and Willian and Eto'o from Russian side Anzhi Makhachkala are central in the case’.
Further details on the background leading to the charges are also available in this Guardian article from November 2023.
Further reporting from the Guardian released on 4 November 2025 identifies that if CFC is sanctioned with a fine should any of the charges be proven and/or admitted, then CFC has a £150 million holdback amount in place to cover any such fine (and/or to compensate for any other consequences), which was agreed during Clearlake Capital’s acquisition of CFC in 2022.
No further update on the case has been provided since the FA’s and CFC’s statements released on 11 September 2025.
Nottingham Forest FC partially successful in reducing £125,000 sanction
As explained in Football Law’s July and August 2025 Roundup, Nottingham Forest FC (“NFFC”) appealed against an FA Regulatory Commission decision to sanction NFFC with a £125,000 fine for a mass confrontation that occurred during NFFC’s PL match against CFC on 6 October 2024.
On 16 October 2025, the FA announced that NFFC had been partially successful in its appeal, with an FA Appeal Board reducing the fine against NFFC to £112,000.
The Appeal Board’s written reasons are available here.
NFFC’s partial success that resulted in a reduction to the fine was on the basis that NFFC should have received the same discount (20%) applied to the “starting point” of the fine to be imposed following an early admission being provided by NFFC, as was applied to CFC and their early admission when also being sanctioned with a fine in this case (see paragraphs 40-44 and 56 of the Appeal Board’s written reasons).
Administrators appointed for Sheffield Wednesday FC
On 24 October 2025 the English Football League (EFL) announced that Dejphon Chansiri, the sole director of Sheffield Wednesday FC (“SWFC”), had appointed administrators to Sheffield Wednesday Football Club Limited (the company entity of SWFC).
In accordance with EFL Regulations, reg. 12.2 and 12.4.1, the EFL’s statement also confirmed that an immediate 12-point deduction was imposed on SWFC following the appointment of administrators.
Grimsby Town FC fined for fielding ineligible player
On 2 September 2025, the EFL announced that Grimsby Town FC (“GTFC”) had been fined £20,000 (£10,000 of which is suspended on condition until the end of the 2025/2026 season) for fielding an ineligible player during GTFC’s Carabao Cup match against Manchester United FC (“MUFC”) on 27 August 2025.
The EFL’s announcement explains the following circumstances of the incident:
‘The breach relates to the Club fielding an ineligible player against Manchester United in a Round Two tie on 27 August 2025. Grimsby Town progressed to Round Three following a 12-11 penalty shoot-out win at Blundell Park.
The circumstances leading to this transgression are that Grimsby Town submitted the registration of Clarke Oduor at 12:01 pm on the day before the fixture i.e. shortly after the 12:00 pm deadline required in accordance with the 2025/26 competition rules.
The Club self-reported the breach upon discovery the day after the fixture had been completed’.
Rule 6.1-6.2 of the EFL Cup / Carabao Cup Rules state:
‘6.1 In all rounds of the Competition a Player must be a “Registered Player” of his Club, as defined in Rule 6.2 below, in order to be eligible to participate in a Competition Match.
6.2 A Registered Player is one who would be regarded and eligible to participate in a Premier League match and/or League Match (as defined in the League Regulations) commencing at the same time and on the same date as the Competition Match in accordance with the Premier League Rules and/or the League Regulations, or would have been but for the operation of Premier League Rule U.1.1 or League Regulation 44.9 (as amended from time to time)’.
Regulation 44.8 of the EFL Regulations states:
‘Subject to Regulations 44.2, 44.3, 44.9 and 58, a Player will only be eligible to play in a match organised by The League if:
44.8.1 the appropriate forms for his registration or the transfer of his registration (including, for the avoidance of doubt, Temporary Loan Transfers) are submitted (in such manner as the League shall specify from time to time) to and received by The League by 12.00 noon on the day prior to the date of such match and confirmed by the League to be in order […]’
As indicated in the EFL’s announcement, GTFC failed to comply with the above-stated requirements by submitting the appropriate forms for Clarke Oduor one minute after the applicable deadline.
Whilst, a previous example involving Liverpool FC in the Carabao Cup 2019/2020 competition shows that the EFL’s approach is to issue a fine for such offences, GTFC could consider themselves fortunate that they have not been removed from the Carabao Cup 2025/2026 competition or otherwise been ordered to replay the fixture against MUFC. Although a different competition, the FA has more recently imposed such sanctions on clubs committing such offences in the FA Cup (see Football Law’s December 2024 Roundup).
UEFA considering amendment to its multi-club ownership rules
As explained in Football Law’s August and September 2025 Roundup, Crystal Palace FC were removed from the UEFA Europa League (“UEL”) and required to play in the UEFA Conference League due to failing to comply with article 5 of UEFA’s Regulations of the UEL. In particular, CPFC failed to demonstrate compliance with the criteria identified in article 5 of UEFA’s Regulations of the UEL by the deadline of 1 March 2025.
It has been reported that UEFA, in discussion with the European Football Clubs (formerly known as the European Club Association), is considering amending the deadline. This article published by the Guardian on 12 October 2025 explains the following:
‘UEFA is planning to give clubs more time to resolve potential multi-club ownership (MCO) issues next season following the controversy that led to Crystal Palace being expelled last summer from the Europa League.
In a proposed change to its regulations discussed with elite clubs at a meeting last week of the newly named European Football Clubs in Rome, UEFA is poised to relax the 1 March deadline, which Palace failed to meet last season in an oversight that led to the FA Cup winners losing their Europa League place to Nottingham Forest.
Under the new rules any club in contention for European qualification the following season would still be required to highlight any potential MCO issues to UEFA by 1 March, but would then be given additional time at the end of the season to resolve any problems if multiple clubs in the same ownership group have qualified for the same competition.
With the draws for the qualifying rounds of the Europa League and Conference League taking place in June, the final deadline for resolving any MCO clashes would be put back to the start of that month. A failure to flag any issues by March would still be deemed a breach of the rules’.
FIFA Launches jurisprudence database
In a statement released on 9 September 2025, FIFA explained:
‘FIFA today announced the launch of the FIFA Football Jurisprudence Database, a landmark initiative providing the football community and legal practitioners with access to football-related legal decisions.
The public will be able to explore and analyse football decisions resolved by the Court of Arbitration for Sport (CAS) and the Swiss Federal Tribunal (SFT) through a structured, user-friendly platform. Football-related disputes account for more than 72% of all CAS cases, underlining the sport’s pivotal role in international sports law.
The database spans cases from 2002 to the present and offers powerful search functionality. Users can filter results by procedure, year, topic and subtopic, language, outcome, arbitrators, and the relevant regulations or articles applied. This functionality enables legal professionals, academics and stakeholders across the football ecosystem to engage directly with the jurisprudence that shapes the game’.
The database is accessible here.
Independent Football Regulator
On 23 October 2025, the Football Governance Act 2025 (Commencement No. 1) Regulations 2025 brought into force sections 65, 66 and 73 of the Football Governance Act from 1 November 2025.
On 27 October 2025, the Department for Culture, Media & Sport also released draft guidance on the meaning of ‘significant influence or control’ in accordance with Schedule 1, Part 2, para. 15 of the Football Governance Act 2025 (“FGA 2025”). The draft guidance is available here, and will lie before both Houses of Parliament for 40 days, during which period either House of Parliament may resolve that the draft guidance be not approved. In the absence of any disapproval, the guidance will be formally published.
It is noted that the current version of the draft appears to abruptly end at paragraph 4.13, and it is unclear whether this is intentional. Nonetheless, the guidance offers illustrative and non-exhaustive examples of how a person may exercise ‘significant influence or control’ for the purposes of Schedule 1, Part 1, para. 2(1) and (5) of the FGA 2025.
11 November 2025