On 23 October 2026, the French-speaking Court of First Instance in Brussels rejected a legal challenge brought by Royal Antwerp and former midfielder Lior Refaelov against UEFA and Belgian football’s home-grown player rules, as reported by Nieuwsblad. The ruling, which was quickly welcomed by the Royal Belgian Football Association, keeps continental and domestic squad quotas intact for now.
Still, the verdict leaves European football with an awkward question. A rule can be legally proportionate in the eyes of a judge while remaining a flawed way to give young footballers real opportunities on the pitch.
The case began in 2020 when Antwerp and Refaelov sought to overturn a Belgian sports arbitration ruling that backed UEFA and Belgian squad quotas. Refaelov moved from Israel to Belgium at age 25, played there for a decade, and eventually gained Belgian citizenship, yet he never counted as locally trained because his teenage training happened abroad.
When the dispute reached Luxembourg in a December 2023 judgment in Case C-680/21, the Court of Justice of the European Union did not declare home-grown quotas automatically illegal. Instead, the European judges explained that the rules restrict competition and can indirectly discriminate against foreign workers under European Union law, while leaving the Brussels court to verify whether those limits are justified and proportionate.
On remand, the Brussels judges ruled that the quotas do not exist for the bare purpose of restricting competition. They accepted that encouraging youth development and protecting competitive balance are valid public interest goals.
Because UEFA’s rules apply regardless of nationality and leave 17 out of 25 squad spots completely unrestricted, the court decided the regulations do not go further than necessary. That gives football governing bodies a useful legal victory, though as a decision from a Belgian court of first instance, it applies only to the parties in this case and does not bind courts in other European countries.
Training youth or buying from rivals?
Seeing why the rules struggle to achieve their sporting goals requires looking at how the quotas operate. In UEFA club competitions, teams can register a maximum of 25 senior players on List A. Eight of those places are reserved for locally trained players who spent at least three seasons between the ages of 15 and 21 at an eligible club.
If a club cannot fill those eight slots, it must register a smaller squad. Belgium goes further in domestic league games by requiring at least six locally trained players on every matchday sheet, which limits who a coach can pick on game day rather than solely restricting the season-long registration list.
UEFA divides its eight-player quota into two categories. At least four spots must go to club-trained players developed inside the club itself. Up to four spots can be filled by association-trained players who completed those three formative years at another club within the same national football association.
That second category sits at the heart of the debate. During the earlier European court proceedings, judges questioned how allowing a wealthy club to buy players trained by rival domestic academies encourages that buying club to train its own prospects.
The Brussels court accepted the defense that domestic transfers send fees and training compensation down to smaller clubs across the national pyramid. Even so, paying a local rival for a finished player is a financial redistribution mechanism, which is very different from a club developing young players of its own.
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Paper compliance versus minutes on the pitch
Even when clubs register their own academy graduates, a name on a squad list does not equal meaningful first-team action. A 2013 study commissioned by the European Commission concluded that UEFA’s rule had a very limited effect on youth development across the European Union.
While clubs registered slightly more locally trained players to comply with the rules, senior playing minutes for club-trained footballers did not show a steady increase. Elite clubs routinely filled their mandatory club-trained spots with reserve players and third-choice goalkeepers who rarely played.
Because that European Commission report examined the early years of the quota system, its data cannot automatically describe the game in 2026. Yet a 2022 doctoral study from Sheffield Hallam University tracked six European leagues and documented a similar stagnation in playing time for club-trained players.
Research also shows that clubs adapted to the three-year training rule by scouting foreign players aged 15 to 17, bringing them in early enough to qualify as club-trained before they turn 21.
How quotas shape the transfer market and competitive balance
In practice, home-grown status has become a valuable trading asset. Clubs with productive academies, such as Ajax, Genk, and Anderlecht, meet their quotas comfortably and can demand higher prices when selling eligible graduates to clubs short on domestic numbers.
Clubs like Royal Antwerp that rely heavily on international scouting face tougher choices, either paying higher wages and fees for domestic players or leaving squad spots empty. In England’s Premier League, where post-Brexit rules stop clubs from signing European Union players under age 18, strong demand for eligible domestic talent has contributed to rising transfer fees and wages, adding registration value on top of a player’s sporting ability.
Financial sustainability regulations reinforce this market behavior. Because academy graduates carry zero book value in club accounts, selling them records an immediate pure profit on the balance sheet. That accounting rule gives clubs a clear commercial incentive to sell home-grown graduates to balance their books rather than promote them into the senior lineup.
These market realities test UEFA’s argument that quotas protect competitive balance by stopping rich clubs from simply buying entire squads of international stars. Wealthy clubs have the money to buy the best association-trained talent from domestic rivals and recruit elite teenagers early.
Meanwhile, mid-tier clubs risk losing their best 15-to-17-year-old prospects before they reach the first team, and clubs from smaller nations such as Luxembourg, Malta, and Northern Ireland often enter European qualifiers with reduced 21- or 22-man squads because their local talent pools are so small.
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Better incentives and the legal road ahead
Rewarding actual youth participation offers a practical alternative to reserving places on a registration sheet. Poland’s Pro Junior System distributes central funds to clubs based on the first-team minutes played by young domestic footballers. Paying clubs for real pitch time targets player development directly without restricting who a club can hire under European labor law.
Financial bonuses would not solve every problem, as modest payouts might not sway Europe’s richest clubs, yet they measure what happens on the grass rather than on an administrative form.
The Brussels judgment gives UEFA and national associations a helpful argument for defending existing quotas, though future legal challenges in other countries could still target strict matchday rules like Belgium’s or question UEFA’s association-trained category.
Royal Antwerp and Refaelov have one month from formal notification of the ruling to take their case to the Brussels Court of Appeal, and while their legal team led by Jean-Louis Dupont and Martin Hissel is assessing that option, no appeal has been confirmed.
Whether or not the case returns to court, the verdict highlights a clear gap between legal survival and sporting success. European football has defended a system that makes home-grown status valuable on a squad list and a balance sheet, without ensuring that young players actually get the chance to play.
