Front-of-Shirt: Crypto sponsorship to replace gambling? Partnership considerations

With the Premier League’s 2026/27 season ban on gambling front-of-shirt sponsorships fast approaching, it is likely the influx of crypto sponsorships will continue to rise in the competition. This season, 14 of the 20 Premier League clubs had crypto partners in some capacity, contrasted against the EFL Championship where only around a quarter of clubs had inked such a deal. However, the number of partnerships entered into with crypto organisations up and down the football pyramid is likely to increase as crypto regains popularity in the UK; currently around 1 in 10 people in the UK own cryptocurrency, and the crypto sector could be worth as much as £16.5bn by 2026. [1] [2] At the same time, the existing gambling partnerships market was recently shaken with news of TGP Europe (an operator that allowed numerous gambling sites to advertise their brands via its licensing framework) surrendering its licence last month – see the Gambling Commission’s release for more information.

What are cryptoassets and why are they popular?

At its most basic, cryptoassets can be thought of as digital representations of value or rights not reliant on any central authority (e.g. a government or bank) to uphold or maintain them. Their price can increase or decrease depending on whether other investors are willing to buy them. If investors stop buying, the price could fall dramatically. There are more and more cryptoassets out there as the market continues to rapidly evolve, but you are probably aware of the most popular, such as Bitcoin and Ethereum. At its crux, people invest in cryptocurrencies for the same reason anyone invests in anything. They hope its value will rise, netting them a profit.

Points to consider when partnering with crypto organisations

The Basics

As with partnering with any organisation, it is vital to be completely aware of who you are contracting with. This is even more important when dealing with crypto organisations. Thorough and proper due diligence on, and open and direct conversation with, the entity that you are contracting with is crucial to root out any issues at the outset. These matters may relate to the:

• ownership and organisational group structure of the crypto organisation;
• registered business address of the crypto organisation;
• reputation of the cryptoasset or associated crypto organisation;
• ownership of the intellectual property related to a particular cryptocurrency;
• source of funds;
• ability to make payment and the payment schedule;
• overall aims and objectives of the partnership.

General Considerations

The above will help you understand whether there are provisions that need to be included in the partnership agreement or whether further agreements need to be entered into, for example:

• A guarantee and indemnity from the partner’s parent company, to ensure obligations are fulfilled if the partner is unable to, or the relevant club will be paid for any damages it incurs if such obligations are not fulfilled.
• Money laundering, anti-bribery and sanctions clauses to ensure that the partner is in, and will conduct its business in, compliance with English law.
• Termination and suspension clauses relating to reputational damage, non-compliance with any applicable laws, or if required to by, for example, a football or regulatory authority or the incoming independent football regulator.
• A clause to assist in serving notices in the UK where the partner is a foreign-based entity.
• Side letters to ensure that the club understands IP ownership and can use IP without infringing any third-party rights.

Crypto-Specific Considerations

Currently, the Financial Conduct Authority (FCA), the UK’s financial regulatory body responsible for ensuring the stability and integrity of the UK’s financial markets, protecting consumers, and promoting competition, has limited regulatory oversight of crypto organisations. However, the FCA does regulate the financial promotion of crypto organisations and cryptoassets, such as Bitcoin or Ethereum. This limits the extent to which a club is able to promote its partnership with such an organisation (as it is not likely to have FCA authorisation) or a cryptoasset which does not have FCA authorisation.

Clubs are able to raise the profile of the partnership by showcasing such a partner on its strip or training wear, or making a factual statement that the crypto organisation is a partner. However, where any post or information presented by a club strays beyond putting the partner in the mind of a person, such activity is not permitted, and clubs can face action from the FCA. Such activities are as follows:

• Making suggestions that the club or a particular player believes that the cryptoasset is a positive activity which should be practised.
• Listing names and contact details of the partner in a context that encourages the recipient to contact the partner.
• Encouraging users to partake in the activity offered via a link.
• Making speculative statements which may promote the partner’s business.
• Distributing further information produced by the partner.

With that in mind, clubs should ensure that the terms of any partnership agreement are clear that:

• crypto organisations should comply with any applicable laws and regulations (in particular, compliance with FCA regulations);
• clubs should not be asked or directed to make any marketing communications which would put the club in breach of applicable laws and regulations; and
• the crypto organisation will pay the club for any losses the club incurs for making any promotions in relation to the cryptoasset.

Regulation of cryptoassets in the UK – long-anticipated overhaul recently announced by the UK Government

This April, HM Treasury published a draft order and a policy note which will significantly broaden the regulatory oversight of cryptoassets in the UK, once it comes into effect.

FCA authorisation will need to be held by any entity who deals, arranges, operates a trading platform, safeguards, issues, or stakes cryptoassets by way of business. This will apply to overseas exchanges, brokers, or market-makers dealing directly or indirectly with UK retail customers.

It is likely that this new regime will take effect from the middle of 2026, with organisations needing to file for FCA authorisation by the end of 2025 to ensure they are authorised once the regime comes into effect.

Clubs should be aware of this when they are contracting to ensure that any long-term arrangements with crypto organisations take into account this changing landscape and are able to provide for extra provisions around holding FCA authorisation, compliance with new FCA regulations etc. Look out for our future releases on this topic to keep up to date.

Crypto Sponsorships: How we can support you

It is apparent that this area of advertising will develop over the coming years, as the football pyramid appears to gradually be working to filter out gambling advertising (if you would like to read more about that topic specifically, please see our previous release). It is not yet clear how the sponsorship market will react and what role crypto will end up playing, but it is important to prepare now to ensure you are well positioned to obtain the best value for your front-of-shirt or other crypto sponsorship in a way which complies with all applicable laws and regulations. We have a wealth of experience in preparing partnerships contracts and providing advice when servicing partnerships involving crypto, so please get in touch if you have any questions.

[1] For the purposes of this article, “crypto organisations“, means organisations connected to cryptoassets, cryptocurrency exchanges and organisations offering crypto services.

[2] https://www.fca.org.uk/news/press-releases/fca-finds-crypto-ownership-continues-rise-it-delivers-plans-regulate-crypto