‘Nice Save’: Nottingham Forest owner utilises blind trust to sidestep Article 5 UEFA restrictions

12/05/2025

With the prospect of two clubs under his ownership (Nottingham Forest and Olympiacos) qualifying for the UCL next season, Evangelos Marinakis has made the decision to place his shares in Nottingham Forest F.C. into a blind trust, declaring to Companies House that he is ‘ceasing to be a person of significant control’ in the company which controls the football club.¹

Article 5.01 of UEFA’s ‘Regulations of the UEFA Champions League’ document mandates that ‘no individual or legal entity may have control or influence over more than one club participating in a UEFA club competition’,⁴ with ‘holding a majority of … voting rights’ or ‘being able to exercise … a decisive influence on the decision-making of the club’ being two of the four examples UEFA lists as contravening this provision.²

By transferring his shares to a blind trust, Mr Marinakis forfeits his rights to influence the club or receive developments from his trustees,³ preventing Nottingham Forest F.C. from being in breach of the aforementioned Article 5.01 should the situation arise where both themselves and Olympiacos F.C. qualify for next season’s UCL. The punishment for such a breach would have been that only one of his two clubs would have been permitted to enter the competition;⁴ specifically, the club finishing highest in their domestic league⁵ (which would be Olympiacos, who currently sit top of the Greek Super League).

However, blind trusts do not need to stay permanent, and Mr Marinakis can regain his control of Forest when they are no longer in a position to compete against any of his other clubs in a UEFA competition (Mr Marinakis also has holdings in Portuguese side Rio Ave FC).⁶ Writing for Sky Sports, Rob Dorsett writes that “Marinakis is still very much the Nottingham Forest owner. He's not walking away or withdrawing his interest, but he no longer has day-to-day control of the club.”⁷

References

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1. Companies House ‘notice of ceasing to be a person of significant control’ for Mr Evangelos Marinakis: https://find-and-update.company-information.service.gov.uk/company/10613412/filing-history/MzQ2NDU5NDk3OGFkaXF6a2N4/document?format=pdf&download=0 (accessed 07/05/2025)

2. Article 5.01(c) Regulations of the UEFA Champions League, https://documents.uefa.com/r/Regulations-of-the-UEFA-Champions-League-2024/25/Article-5-Integrity-of-the-competition/multi-club-ownership-Online (accessed 07/05/2025)

3. https://www.skysports.com/football/news/11727/13358618/nottingham-forest-evangelos-marinakis-withdraws-control-of-club-but-will-remain-as-owner (accessed 07/05/2025)

4. Article 5.02 Regulations of the UEFA Champions League, https://documents.uefa.com/r/Regulations-of-the-UEFA-Champions-League-2024/25/Article-5-Integrity

5. Article 5.02(b) Regulations of the UEFA Champions League, https://documents.uefa.com/r/Regulations-of-the-UEFA-Champions-League-2024/25/Article-5-Integrity-of-the-competition/multi-club-ownership-Online (accessed 07/05/2025)

6. https://www.nottinghampost.com/sport/football/football-news/nottingham-forest-owner-evangelos-marinakis-8920036 (accessed 07/05/2025)

7. https://www.skysports.com/football/news/11727/13358618/nottingham-forest-evangelos-marinakis-withdraws-control-of-club-but-will-remain-as-owner (accessed 07/05/2025)