UEFA’s Article 5 is clear on paper: two clubs under the same “decisive influence” cannot compete in the same European competition. Yet, season after season, we see clubs with shared investors or ownership groups on the same Champions League or Europa League stage.
The reason? Football has become too global, too commercial, and too reliant on capital flows for UEFA to strictly enforce its rules without risking major backlash. Instead, what we’ve seen is a series of creative legal, governance, and branding manoeuvres that allow clubs to technically comply while still benefiting from shared resources.
Here are three of the most striking case studies:
Manchester United and OGC Nice — The INEOS “Blind Trust” Fix
When INEOS acquired Manchester United’s football operations, alarm bells rang across Europe. They already owned OGC Nice outright, which should have triggered UEFA’s conflict-of-interest rules. The workaround?
INEOS temporarily placed its Nice shares into a blind trust for the duration of the European season. Independent trustees ran the club on paper, creating a thin legal firewall. That was enough for UEFA to approve participation, and both United and Nice played in the Europa League.
In practice, the same group still funded both. UEFA’s interpretation of “decisive influence” proved highly flexible.
Manchester City and Girona — Minority Stake, Maximum Influence
City Football Group owns just under half of Girona (47%), supported by a consortium of other investors. Officially, that’s a “minority stake.”
UEFA accepted CFG’s claim of separate governance structures and distinct boards. Both clubs played in the 2024/25 Champions League — despite Girona featuring multiple CFG-linked players, including Yan Couto, who was on loan from Manchester City.
Other clubs questioned the fairness, but UEFA backed down. It was another example of how minority stakes, clever boardroom optics, and legal separation can outmanoeuvre the spirit of Article 5.
RB Leipzig and RB Salzburg — Red Bull’s Branding Shuffle
Perhaps the most famous example came in 2017. Both Leipzig and Salzburg qualified for the Champions League, sparking an official investigation.
Red Bull’s solution?
- Transferred Salzburg’s official shares to local representatives.
- Adjusted governance documents to reduce visible overlap.
- Even tweaked logos and kits to show “independence.”
UEFA ultimately ruled that while Red Bull still had influence, it was not “decisive.” Today, Leipzig are Champions League regulars, and Salzburg continue to feed talent upwards — effectively a multi-club system operating in plain sight.
The Problem with “Decisive Influence”
The phrase itself is the loophole. UEFA applies it subjectively. For INEOS, CFG, and Red Bull, small tweaks in governance or branding were enough.
But for others, like John Textor’s Eagle Football portfolio (which includes Crystal Palace, Lyon, Botafogo, and more), UEFA deemed there was too much decisive influence, blocking participation.
Looking ahead, the tension could get explosive. Imagine Strasbourg reaching the same competition as Chelsea under BlueCo ownership. The “firewall” solutions of trusts, minority stakes, or rebranding might not hold under increasing scrutiny.
365247 View: Why This Matters
For investors, multi-club ownership remains one of football’s most lucrative growth models. It creates pathways for talent, optimises global commercial footprints, and spreads financial risk.
For UEFA, however, this is a credibility issue. If rules are seen as bendable for the biggest players but rigid for smaller investors, competitive integrity will come under fire.
The next frontier is simple: will UEFA redefine “decisive influence” with sharper criteria — or will clubs continue to out-innovate regulators with clever legal gymnastics?


