Hull City Tigers subject to two transfer window fee restriction

Cases

Hull City Tigers’ appeal against an automatic restriction from paying a fee for a player (“Fee Restriction”) has been determined. The Club is now subject to a two window Fee Restriction, with a third window suspended. This was the first appeal from the imposition of a Fee Restriction to the Independent Club Financial Review Panel (“the CFRP”).

Under Regulation 52.6 of the EFL Regulations 2025/2026, where a Club defaults for 30 days on debts owed it is regarded as a “Persistent Default” and an automatic Fee Restriction is imposed for three full transfer windows. On 3 July 2025 the EFL’s Independent Club Financial Review Unit (“the CFRU”) notified the Club that it was subject to the Fee Restriction. It was imposed because the Club failed to make various payments due under a loan agreement with Aston Villa in respect of the player Louie Barry. The Club appealed to the CFRP under Regulation 52.6.4.

As part of its appeal, it argued that the sums had not been “due and owing” at the time, that the sanction was disproportionate and that no Fee Restriction was appropriate. The CFRU’s position was that the sums were properly due and owing, and that a Fee Restriction of two transfer windows, with a third suspended was an appropriate sanction.

The CFRP held that the sums were “due and owing” and that a Fee Restriction of two transfer windows with one suspended was appropriate. The CFRP’s reasons are set out here.

Ruth Kennedy acted for the CFRU throughout the proceedings (instructed by David Williams, Alexander Lehany and Harry Hobson at Clarion).