A review of key Financial Fair Play cases through the lens of the CAS

Published 12 April 2018 | Authored by: Mark Hovell

In the five or six years that UEFA’s Club Licensing and Financial Fair Play Regulations (FFP / the Regulations)1 have been with us, the Court of Arbitration for Sport (CAS) has had to consider a number of appeal cases. This has included, in the last couple of years, some break-even cases, as opposed to simply observing settlement agreements. There are also many other cases that relate to FFP that have never made it as far as the CAS, and indeed there are potentially many different cases coming down the rails.

This article recaps the history of FFP and focuses on some of the key cases that have been before the CAS. It is based on a speech that the author gave at the 7th International Congress on Football Law staged by the Spanish Football Association (RFEF) in November 2017. Specifically, it examines:

  • The history of UEFA’s FFP regime

  • The refusal of a licence

  • Overdue payables

  • Break Even

  • The Queens Park Rangers case

  • The Paris Saint-Germain and Neymar case

  • Third Party Challenges

The history of UEFA’s FFP regime

FFP sits within the club licensing regime that UEFA established in 2002. That said, it was not until 2009 that UEFA’s Executive Committee approved the FFP model and 2010 and that the decision was taken that FFP would be integrated into the Club Licensing Regulations. In 2012 we saw the launch of the CL and FFP Regulations which were updated in 2015. We also saw the procedural rules being launched in 2014 with the new addition of those also coming out in 2015.

So why were these regulations introduced? The answer lies in the UEFA Benchmarking Report. One of the parts of this report looks to aggregate the profit and loss accounts of all the clubs in all the top divisions of all the UEFA member associations. By 2010 the aggregate position was a loss of €1.6bn, by 2011 it was nearly €1.7bn2. It was clear that the financial health of European Football was declining, and UEFA needed to do something to stem the tide.

The objectives of FFP are to improve the economic and financial capability of clubs, to protect creditors, to add more discipline and rationality and club football finances, to get clubs to operate on the basis of their own revenues, to encourage responsible spending and to protect the long-term viability and sustainability of European Club Football.3

Basically, any club that qualifies on the pitch to play in the following seasons UEFA Champions League or Europa League requires a licence to enter into those club competitions.

In order to get the licence the club must establish that it has satisfied certain minimum requirements covering sporting, info structure, personnel / administrative, legal and financial aspects. The initial review is delegated to UEFA’s member associations or federations (or indeed are further delegated to the League’s in those countries) who in turn have to determine whether or not to grant the UEFA Licence.

That decision can be appealed and some member associations have determined that the appeal should go to the Court of Arbitration for Sport in Switzerland. Others have determined to keep it internal.

UEFA has established its Club Financial Control Body (CFCB) which oversees the information given by clubs to the licensors and ensures that all clubs that are granted a licence continues to comply with the regulations. The CFCB is split into an Investigatory Chamber which carries out the monitoring and investigations and an Adjudicatory Chamber which carries out the judicial functions for any clubs that need to be sanctioned. Effectively, the association / league that is acting as the licensor is looking to see if any of the four indicators have been breached when considering the FFP aspects of these regulations. Those indicators are to see whether or not the club is a going concern, whether it has negative equity (i.e. are its liabilities greater than its assets) is it living within its means (break even result) or does it have overdue payables.

In addition, the CFCB can make additional enquiries if the employee costs of any club exceeds 70% of its revenues or if its net debt exceeds 100% of its revenues. If the indicators are breached then the licence may not be granted in the first instance or if it has been granted and the indicators are breached during the monitoring process, then the CFCB can impose disciplinary measures which in turn can be appealed to the CAS.

So in summary, the CAS is typically brought in to play to consider appeals by clubs when they have been refused a licence by domestic association, federation or league, where there is a breach of the overdue payables indicator during the monitoring period, or if there is a breach of the breakeven indicator.

The refusal of a licence

There have been half a dozen cases or so before the CAS dealing with the refusal of licences. The important lessons are:

  • not all licensors decisions can be appealed to the CAS. Many associations have their own internal domestic appeal bodies that would deal with such appeals. By way of example, Russia4 and Romania5 do delegate their appeals to the CAS, whereas Spain6 and Italy7 do not.

  • These cases have ironed out some important issues to date. Can sums due from a club to its association or league be classed an overdue payable? (No)8; do the accounts of a separate body that runs a clubs training facility need to be consolidated with the accounts of the club concerned? (Yes)9.

Staying with the granting of a licence this year saw the important Red Bull case10. The case was not an FFP case but a licencing with an integrity case and it was not one that had been appealed to the CAS. However, it is worthy of consideration especially as we are now seeing more groups of clubs being formed where the clubs are playing in different leagues and different countries. For example, with Manchester City, Girona has recently joined its global group. Watford have the same owner as Udinese in Italy and formerly of Granada in Spain.

Can two teams in the same group of companies play each other in UEFA Club Competition? At the end of last seasons Red Bull Leipzig and Red Bull Salzburg both qualified for this seasons Champions League competition. The Investigatory Chamber of the CFCB concluded that the clubs had failed to satisfy the criteria aiming at ensuring the integrity of the competition (basically the two clubs were linked, and Red Bull GmbH had influence over them both) so it referred the case to the Adjudicatory Chamber to decide their fate. Both football clubs were limited companies that were wholly owned by a members’ association. Red Bull GmbH was able to exert influence and have access to the members of both associations. Additionally, it had granted significant sponsorship deals to both Leipzig and Salzburg and it granted loans to Salzburg. Further, Salzburg rented its stadium from a subsidiary of Red Bull GmbH and there was a co-operation agreement between Salzburg and Leipzig which meant that a number of players were loaned or transferred between the two clubs, there was common branding and they even had shared individuals on their management teams.

The Investigatory Chamber felt that the clubs had failed to satisfy the criteria11. It recommended to the Adjudicatory Chamber that only Salzburg go through to the Champions League (as it had won its league in Austria with Leipzig coming runner up in Germany). The Adjudicatory Chambers referred to the ENIC Decision12 which considered common ownership of clubs and wanted to be sure whether or not Red Bull GmbH was able to influence the decision making of both clubs. The Chamber took a strict line and wanted the evidence of a legal power that enabled Red Bull GmbH to influence those clubs and that it could be exercised in this particular competition.

Before the hearing, a number of changes were made by the clubs. In particular, Salzburg had removed individuals from its association that were linked to Red Bull GmbH (including its Chairman), the loans had been terminated, the co-operation agreement with Leipzig had also been terminated and the sponsorship agreements had been amended. Salzburg had also made commitments to address any issues regarding its lease with the Red Bull subsidiary and to address the issues of its branding.

In its decision the Adjudicatory Chamber rejected the Investigatory Chambers recommendation and concluded that the changes made by Salzburg ensured that Red Bull did not have any decisive influence or legal power over that club and that there was no longer any sufficient connection between the clubs. As such both were able to enter this seasons Champions League competition.

Overdue payables

All clubs seeking a licence to compete in the club competitions have to produce audited financial documentation to the licensor. One of the things a licensor is looking for is evidence of any overdue payables.

For a definition “payables are considered as overdue if they are not paid according to the agreed terms13.

Clubs are not allowed to have these at the relevant dates due to other clubs14, to players15 nor to social / tax authorities16.

There are, however, some exceptions to that. If a club can show on a relevant reporting/monitoring date that overdue payables have been repaid then they will be allowed to continue in the competition, if they have a written agreement to extend the payment date then those payables are not deemed as overdue and if there is legal proceedings on foot contesting whether these payables are due or not those sums are also not taken into account. To date there have been 7 disputes that have come before CAS interestingly though, not many or any cases for the last couple of years.

The key lessons from these cases are:

  • do not try to lie or hide overdue payables – this would result in harsher sanctions from UEFA17;

  • excuses such as the invoice wasn’t in the right format18, the club I owe money to is insolvent19, I have an informal or written agreement to pay late20, I have asked for time to pay but haven’t received an answer yet, I received my written agreement after the relevant monitoring date21, or I am being sued (but really have no defence) won’t work!

  • if a club has a third party that pays some of the players remuneration but that third party has overdue payables, the club can still be sanctioned22;

  • if the Adjudicatory Chamber sanctions a club with a ban, but agrees to cancel that ban if the overdues are paid within a couple of months of the decision, CAS is unlikely to interfere with the time given to clear the overdue payables. Further, if a club reaches a time to pay agreement with its creditors by such additional date, instead of actually paying them off, then the ban will not be cancelled23.

In reality the classic overdue payable case was one where the club simply acquired players from many different clubs and refused to pay the transfer fees, training competition or solidarity payments until forced to by FIFA or the CAS. This is what was known as the “FIFA loan24 as clubs often struggled to get a loan facility from a bank (who would want to apply a higher rate of interest, charge a facility fee, want security, want to ensure that the money was used in certain ways, etc.) as at the end of the day the club effectively borrowed “millions of pounds from other clubs and then simply had to prepay what it owed with 5% interest and some legal costs”.

Additionally, the CAS did see some secondary cases. Ones where clubs were looking to get their players to sign waivers to say that they weren’t actually owed any money from the club when they were. There were instances where players refused to sign these waivers and found themselves terminated by the clubs in question. A case under Article 17 of the FIFA Regulations on the Status and Transfer of Players (RSTP) would then follow which was typically defended by the clubs on the basis that the player had failed to follow “reasonable” instructions!

But in summary it is clear that the sanctioning has softened since the first cases and now clubs can expect a carrot and stick approach where if they do get a ban it is usually suspended or they are given a couple of months to clear their debts in which case the ban is removed. Additionally, there is usually a fine which is approximately 10% of the amount of overdue payables the club had.

Overdue payables is perhaps not the issue it was from the UEFA Benchmarking Report in 2011, when the clubs participating in the European Club Competitions had €57m overdue payables whereas by 2015 this had dropped to £5m25. In addition FIFA had introduced its own overdue payable regime (Article 12bis of the RSTP) which meant that a lot of cases were being dealt with directly through FIFA.

Break even requirements

Break even regulations aim to ensure that clubs live within their footballing means. Effectively football expenditure must be met out of football income over a 3-year rolling period with an allowable deviation of €5m. To acknowledge that in some years some clubs may have surpluses and other years deficits hence the 3-year averaging.

On top of this owners are able to prop up clubs that have aggregate losses of up to €30m by introducing equity (not loans). Plus, the system allows for some investment. In fact, when the rules were first produced, owners could put in up to €45m.

Certain expenditure is disregarded (expenditure on youth community or women’s teams / development, money spent on stadia and other similar assets) and certain income is disregarded (donations and payments from related parties above fair value – typically sponsorship deals). CFCB is also able to take mitigating factors into account such as events of force majeure, currency swings, major and unforeseen changes in economic environments and the like. Since 2015, clubs can seek voluntary arrangement with UEFA which has allowed some clubs to spend large sums of money in early years of the agreement with a view to becoming break even compliant a few years later. However, in order to qualify for a voluntary agreement, a club needs to show previous compliance with the regulations, it needs to have had a significant change in ownership or control within the last 12 months and cannot have been subject to a previous voluntary agreement, sanction or settlement agreement in the last 3 reporting periods.

For a long period of time there were no breakeven cases that came to the CAS. Since the 2014 procedural rules were brought into play, the CFCB was able to enter into settlement agreement with many clubs. In that first year 9 clubs including Manchester City and Paris Saint-Germain entered into settlement agreements, 13 more in 2015 with 4 more in 2016 and just one club in 2017.

Details of all the settlements are on UEFA’s website, but not details of the alleged breaches of the FFP Regulations so people are left speculating whether the alleged breach was relating to a sponsorship contract, perhaps different accounting techniques or even the sale and valuation of assets.

What we could see was that these settlements were not insignificant. In the case of Manchester City in 2014, it had agreed on a €60m fine (although €40m of this was suspended and ultimately not paid as the club became breakeven compliant). It also took a reduced squad side for the next two Champions League seasons, had transfer spending restrictions and a reduction in the amount the owners could put in to prop up the clubs losses going forward.

The first case that did come to the CAS was that of Galatasaray26. Galatasaray had entered into a settlement agreement with the CFCB in 2014 under which it needed to be breakeven compliant by the 2015/16 season, its employee expenses could be no more than €90m and if it failed to comply, then its case would be referred to the Adjudicatory Chamber.

In October 2015 the club was found to have exceeded the breakeven deficit by €134.2m and to have employee expenses of €95.5m. The matter went to the Adjudicatory Chamber who in March 2016, sanctioned the Club by excluding it from the next competition it would qualify for in the next 2 seasons and set a limit on its employee expenses to €65m. Galatasaray appealed the case to the CAS claiming that the FFP Rules were illegal, that specifically the 2012 version didn’t allow for voluntary agreement and that the sanctions were grossly disproportionate.

The Panel initially had to decide what the applicable laws were for the matter at hand. The UEFA CL and FFP Regulations along with Swiss Law on a subsidiary basis were deemed to be applicable. The panel also determined that the Treaty on the Functioning of the European Union (TFEU) was applicable even though the club was from Turkey, the economic activity (i.e. the Champions League) takes place on EU territory and there are mandatory rules in the EU territory that are therefore applicable to this association, UEFA.

The panel reviewed Article 101 of the TFEU (that the breakeven rule restricts competition and investment) Article 102 TFEU (that UEFA were guilty of abusing their dominant position) and the fundamental freedoms (Articles 45, 56 and 63) of TFEU being the free movement of workers, the free movement of services and the free movement of capital respectively.

Galatasaray argued that the breakeven rule impeded small clubs from investing and ultimately protected the well-established clubs from any competition. They felt that FFP could not be justified by its objectives and even if these objectives were legitimate, they were not proportionate compared with alternatives (such as applying a luxury tax as seen in the US sports) further the rules were discriminatory as no voluntary agreement was available to Galatasaray.

Effectively this was the classic Meca-Medina27 test:

  • what is the context in which the rule was adopted and what are its objectives;

  • are any restrictions (such as restricting investment) caused by the rule inherent in the pursuit of those objectives (or are there other ways that these objectives could be satisfied, such as the luxury tax); and

  • is the rule proportionate in light of those objectives.

UEFA disagreed with Galatasaray. They certainly noted that the club didn’t complain of the rules when it took advantage of a settlement agreement in 2014. However, the rules didn’t restrict competition, they facilitated innovative and sound competition and any restrictions there may be were to pursue legitimate governments objectives and were proportionate to their achievement. Ultimately CAS rejected the appeal. The panel pointed out that the club had failed to provide any economic analysis or empirical evidence on the impact of the FFP Rules on competition in the market. Ultimately it didn’t meet its burden of proof that the rules have the effect of restricting competition. Further Galatasaray brought no precedents from the ECJ, EU Commission or any domestic authority.

The panel considered Article 101 TFEU but didn’t find that the breakeven rule was there to restrict or distort competition rather it was there to control the financial conduct of clubs wishing to participate in the European Club competitions. Further the rule wasn’t “blunt”; it considered a 3-year rolling period so if clubs overspent in years 1 or 2 then they could cover those deficits in other years; there is an acceptable deviation of €5m; owners can inject 6 times that amount in as equity to cover further losses and the UEFA CFCB Adjudicatory Chamber is able to consider mitigating factors. If there was any distortion of competition this is when clubs overspend seeking to gain an advantage over those that respect financial balance.

The panel also recognise that the breakeven rule and the regulations in general evolve over time so the lack of a voluntary agreement mechanism in the 2012 regulations was not seen as relevant.

The panel also considered Article 102 of the TFEU and found no evidence of any abuse and likewise, when considering the fundamental freedoms, found no evidence from the club whatsoever that these had been breached. Rather, they found that there was no discrimination on grounds of nationality as players can and often are transferred across borders so there were no freedom of movement issues and capital clearly moves from country to country to as we find owners from one country owning clubs in another country.

For completeness they considered the Swiss competition laws but as these are similar to EU law they came to the same conclusion. Ultimately the club had breached the settlement agreement. The settlement agreement was a second chance already so if there was a breach it was seen as a particularly serious offence. There were no mitigating factors advanced and certainly no accounting evidence to back up those that were. Matters such as the Syrian Refugee crisis and terrorism in Turkey were not seen as issues of force majeure that made it impossible for the club to comply with the rules. Ultimately the Adjudicatory Chamber decision was seen as proportionate and the appeal was dismissed. Soon after the Galatasaray case came the Karabukspor case28. Here again there was a settlement agreement entered into with the CFCB and the Club.

In this case the club must be within the €5m allowable deficit by March 2016 and if it did have a deficit in excess of that €5m sum (but below the €30m allowable) then it must be covered by equity contributions. Again the club was warned that if it failed to comply then its case would be referred to the Adjudicatory Chambers. At the next monitoring date it was determined that the club had breached the breakeven indicator and indeed was in deficit to the tune of €24m. The club had not found any equity injections to cover this sum. As such in June 2016, the Adjudicatory Chamber sanctioned the club with an exclusion from the next competition it would qualify for in the next 2 seasons. The club was ultimately relegated (although promoted straight back the year after) and decided to appeal the decision to the CAS. It should be noted that the Club was an association that hadn’t incorporated to an entity limited by shares which would have facilitated equity investment.

The club acts for the CAS if it was able to suspend the Adjudicatory Chamber’s decision giving it some time to comply but also felt that that would be more proportionate and in line with the principle of equal treatment.

The CAS ultimately dismissed the appeal and stated that the settlement agreement was already a second chance. It is acknowledged that the club’s relegation would have had an effect on it but felt that the club should have made the appropriate adjustments (such as selling players or having divisional pay within its employment contract) to deal with this. Relegation of itself was not an event of force majeure.

The panel also felt that the club could have altered its structure from an association to a company sooner and it therefore bears the consequences of non-compliance with the settlement agreement and the panel found no grounds for suspending the ban. Finally, there was no proof that the ban was “evidently and grossly disproportionate” nor that there was any unequal treatment.

The Queens Park Rangers case

So much as you are able to take great comfort from the two CAS decisions, neither decisions are binding on the next panel (although they are highly persuasive) and the lack of evidence put forward by both appellants could be seen as a key factor in the decisions. As such, you therefore undoubtedly take more comfort from the Queens Park Rangers case that was heard in England in 201729. Here there was a 2-week arbitration before an extremely experienced panel not considering the UEFA Financial Fair Play Rules, but the English Football League’s own rules. However, a number of the issues were the same, Articles 101 and 102 of the TFEU were considered along with the UK Competition Act.

The breakeven rules are not identical. There is no rolling 3-year basis with the EFL rule, and indeed that rule is more akin to a luxury tax so that if a club spends more than £10m over the allowable deviation, then a fine is 100pence in the £ which was initially to be shared with the other clubs in the EFL. But perhaps the key difference here was that the panel had the benefit of economic, accounting and legal expert witnesses as well as many factual witnesses.

Despite the EFL breakeven rules being perhaps “blunter” than UEFA’s, the panel did not find that the EFL had used its dominant position nor that its regulations restricted investments or a competition.

Additionally UEFA will take comfort from the 2014 European Commission rejection of the Striani complaint relating to FFP, the fact that in 2015 the European Courts of Justice declared “manifestly inadmissible” a request again by Striani for a preliminary ruling on the legality of FFP made by a first instance court in Brussels and took the view that the case had no merits whatsoever; that in February 2016 two other challenges to FFP brought by groups of fans were dismissed by judges at a Paris court and that finally UEFA had a case before a Swiss Competition authority back in 2015 where the complaint was rejected. UEFA can also take great comfort from the trends that are portrayed in its latest edition of the Benchmarking Report. The number of clubs where there are significant annual losses between 2009 to 2015 has dropped dramatically; the overdue payables of clubs coming in to the European Competitions has changed from €57m in 2011 to just €5m in 2015 and the all-important balance sheet of clubs playing in the top level of European Leagues has improved by some 81% from 2011 (€1.7bn loss) to 2015 of €323m loss. This sum is more than covered by the amount of equity that is invested in European Football Clubs each season30.

What is also impressive is the fact that these regulations have had an upstream and downstream impression. FIFA in April 2015 introduced Article 12bis to the RSTP which now tackles overdue payables and indeed this is also within numerous CAS cases perhaps to replace the one that originally came from UEFA decisions31.

In addition, all but 3 of the UEFA member associations have now had some form of licensing most of with their own form of domestic FFP. So, when we revisit the FFP objectives at UEFA could UEFA argue that all of these have now been kicked off? Have they improved the economic and financial capabilities at clubs, have they protected the creditors by reducing the level of overdue payables and leading FIFA into doing the same, have they introduced more discipline and rationality at the football clubs with their finances and have they encouraged clubs to now operate on the basis of their own revenues and embarked on responsible spending for the long term benefit of football? Ultimately UEFA may well say that they have protected the long-term viabilities obtainability of European Club Football.

So, is that it? Job done? All the regulations look to address new issues or evolve further?

Alternatively, will it make the breakeven regulation more vulnerable to a rich owner who might say why is FFP needed anymore? If it is really to cure the financial problems that existed 6 or 7 years ago then all it does now is stop me from investing in my club and trying to compete with the big boys.

The Paris Saint-Germain and Neymar case

Everybody saw the move of Neymar from Barcelona to Paris Saint-Germain last summer for an incredible figure in excess of €200m. That is just the transfer fee, before you even start talking about his salary. People wondered is this a circumvention of FFP? Does the transfer jeopardise these regulations? We saw UEFA announce that PSG is now under investigation.

So how might this unfold? Well the author is not aware of any change in ownership or control of the club so a voluntary agreement doesn’t seem on the cards. It could be possible that the club has built up surpluses over the last 2 reporting periods which may go some way to offsetting any losses it may make in this season perhaps it will sell other players? Perhaps it will enjoy financial success as a result of Neymar. More commercial revenues, perhaps winning the Champions League and the like? Neymar signed a 5-year deal so the full €200m for his transfer fee doesn’t need to hit the accounts in one go rather it hits it at the rate of €40m a year. That said the club seems set to buy Mbappe next season too from Monaco!

So, what may come out of the CFCB’s investigation? Perhaps another settlement agreement, perhaps a trip to the Adjudicatory Chamber where a harsher sanction may be imposed. But one would suspect if that did happen PSG would be better placed to challenge FFP before the CAS when Galatasaray did. Lessons could certainly be learnt from the Galatasaray case and one would expect them to bring economic and empirical evidence in attempt to meet any burden of proof. On the other hand, UEFA will undoubtedly take comfort from the QPR case and the other unsuccessful challenges based on European law.

Third party challenges

I have always been a little surprised that we have never seen a third-party challenge yet. There is also lots in the press about people complaining about clubs like Paris Saint-Germain and Manchester City but is there anything that they can actually do about their spending or is this solely for UEFA to deal with? Under the procedural rules32 a party directly affected has the right to appeal a final decision of the CFCB to the CAS. So perhaps if Paris Saint-Germain entered into a settlement agreement a third party could appeal?

If we wound-back the clocks to 2014 when Manchester City and UEFA entered into a settlement agreement, Everton came fifth in that season so could have said to UEFA something along the lines of “you should have banned Manchester City not settled with them. If you had then we would be in the Champions League, so we are directly affected”. However, the difficulty here is that they would be litigating in the blind. They would just get to see the same settlement agreement as everybody else does on UEFA’s website. It states what the terms of the settlement are, not what the alleged breaches of the regulations were. So, what would a club in Everton’s situation do? Perhaps file a protective appeal with CAS, perhaps ask for a stay of the appealed decision and some time to file the appeal brief but to do so after they had had full disclosure of the CFCB’s file? These are all requests that can be made to the CAS in normal appeal proceedings, but it is certainly not straightforward.

It is interesting when one reads the UEFA Benchmarking Report that it is monitoring domestic loan systems and it is looking at domestic squad sizes. Perhaps regulations across Europe will follow through the CL and FFP Regulations. We also read in the press complaints about certain English clubs buying up young talent that are unlikely to ever make their first 11 and more likely to be sold on to other clubs as part of a secondary money-making business. It is also well known that English clubs are extremely concerned about the powers of intermediaries and perhaps UEFA will look into this to fill the gap left by FIFA when they stopped regulating agents a couple of years ago. Ultimately, you need a crystal ball to see what and where these regulations are going next. In conclusion, CAS are certainly seeing less of these cases and UEFA can rightly hail these regulations as a great success. The numbers speak for themselves and their objectives have been largely met.

However, does that make these regulations redundant? Does it mean that they are more susceptible to an EU law challenge by a party that brings the appropriate evidence? Or will we seek the scope of the regulations broaden to enable UEFA to tackle other issues it sees necessary and to ensure that clubs do not slip back into old habits?

As always, only time will tell.

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About the Author

Mark Hovell

Mark Hovell

Mark is a partner and the head of the sports team at Mills & Reeve LLP.

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