The biggest clubs in Europe
Part 2: Achieving more progress
This is the second post in this newsletter on Europe’s biggest clubs. The first examined their progress so far toward net-zero and found that, overall, these clubs lag far behind the wider business community in setting credible targets. Where targets exist, delivery plans are weak. And where action is taken, clubs tend to focus on outputs rather than outcomes.
More of the same while expecting different results would be, as the saying goes, madness. This slow progress also means mounting risks. A change in approach and pace is needed.
UEFA previously committed to review its 2021 sustainability strategy during 2025. Four years after its publication, the world has changed, making such a review both timely and urgent. It is a chance for UEFA to adopt a more ambitious, outcome-focused delivery-driven approach. This will also sit well with fans, sponsors and investors who expect an approach reviewed and updated to current circumstances and expectations.
At the time of writing, there is no sign that UEFA has begun this review. In the meantime, below are 3 themes with 10 actions and approaches that could be in a revised strategy. Most focus on those clubs at the top of the tree, though a few apply more widely. None are rocket science to deliver; further progress is mainly a question of leadership, intent, and recognising the benefits. They are:
Theme 1 - Raising the Floor: standards, compliance and accountability
Theme 2 - System transformation: strategy, calendar and commercial reform
A(nother) review of business relationships, including procurement and sponsorship
Incorporating environmental factors into UEFA’s scheduling of club matches
Theme 3 - Collective action and influence across the football community
A more collaborative approach between supporters, clubs, governing bodies and partners
A structured approach to clubs’ and bodies’ spheres of influence
Increased support for grassroots football, especially from those with the broadest shoulders
What follows is a long read covering each of these points. A heads-up - it’s perhaps the longest read yet in this newsletter. So, if it’s your kind of thing, strap in and let’s go. And if you have comments, clarifications, corrections, or further suggestions, please get in touch.
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Theme 1 - Raising the floor: standards, compliance and accountability
1. A differentiated, proportionate approach for clubs of different sizes
A differentiated, proportionate approach to clubs of varying sizes would align with broader sustainability practices in business. At present, UEFA and other organising bodies apply a “one-size-fits-all” model.
For UEFA licensing, all clubs competing in its tournament, whatever their size, must meet the same licensing requirements, such as appointing a sustainability manager and producing a sustainability strategy. Likewise, UEFA’s sustainable infrastructure and circular economy guidelines offer no clear differentiation for clubs of different scales.
A proportionate model also reduces compliance burden for smaller clubs while giving larger clubs a clarity that partners and investors increasingly expect on sustainability.
In simple terms, larger clubs should do more. They have greater impact, face higher risks from inaction, and possess greater capacity to deliver change at scale. This does not mean smaller clubs have no responsibilities; rather, a proportionate model would help tailor expectations and support across all levels.
This prompts two questions: how should clubs be segmented, and what actions should each segment be expected to take? Further analysis is needed. Still, some existing classifications could provide a starting point for segmenting clubs. For example, European Football Clubs (EFC) identified roughly 150 major European clubs that were expected to fall into CSRD reporting requirements1. At the highest level, UEFA publishes annual financial data for the top 20 clubs by revenue2.
2. More clubs setting net-zero targets
All major clubs should be setting net-zero targets — that should be a no-brainer. And for clubs that already have targets, the priority must be pushing ahead with implementation.
However, a purely voluntary approach, leaving clubs to act independently, has kept football in the slow lane. What could an alternative look like? At least three options stand out.
First, an enhanced voluntary approach: regularly publishing how many major clubs have set targets and what those targets are. UEFA or the ECA should lead this, though an independent expert body might offer greater authority and credibility and also assess their integrity.
Second, an orchestrated campaign. The UN Sports for Climate Action Framework is one such effort, yet only 8 of the 29 biggest clubs have joined. Something isn’t resonating with the very top-tier clubs. A football-specific net-zero campaign may also be needed — potentially led by UEFA, or by clubs already committed to net-zero, or integrated into the EFC’s Football Clubs Alliance for Climate initiative.
Third, a regulatory approach. UEFA could incorporate climate-target requirements into its club licensing system. This could follow the pattern of other UEFA environmental criteria: introduced first as non-binding and later becoming a condition for participation. It could also be designed proportionately. Germany’s DFL already includes climate-target setting in its licensing rules, so the concept is not new to football.
3. Greater transparency and comparability on progress
Transparency and accountability are essential for assessing progress and driving better climate action. Yet, little meaningful reporting is happening. Where major clubs do report, understanding is often hindered by glossy, bulky, inconsistent, and no doubt costly, documents filled with cherry-picked data and headlines.
Although clubs may well have good intentions with these, their current individualised reporting practices obscure the bigger picture. Which actions by major clubs most effectively cut emissions? It’s almost impossible to tell. A few giant trees are blocking the view of the wood. Four developments here could help.
Voluntary CSRD-aligned reporting
The EU’s Corporate Sustainability Reporting Directive (CSRD) aims to ensure transparent, comparable sustainability reporting. As noted above, EFC previously identified 150 major European clubs that would have fallen under the CSRD and provided them with training.
Recent threshold changes mean these clubs are no longer required to comply—yet nothing prevents them from adopting CSRD voluntarily.
Across the business world, PwC reports that 40% of companies plan to continue with CSRD-aligned reporting even without a legal requirement, driven by stakeholder expectations and the decision-making value of the information. How many football clubs plan to follow suit?
So far, Juventus is a rare example of a major club voluntarily adopting CSRD reporting. Others are conspicuously absent. As the terrace chant goes: “This is embarrassing.” There is clearly scope for major clubs to step up and align with a recognised standard.
Given its experience with training of clubs, EFC is well positioned to publish an annual list of member clubs voluntarily aligned with CSRD. To measure its own impact, EFC could also set short-, medium- and long-term targets for increasing uptake.
The UEFA Carbon Calculator: White Elephant or Opportunity?
Launched with fanfare last March, the calculator was promoted as a tool to “improve consistency, provide clarity of reported information and support comparability over time.” Nearly two years on, what’s the uptake? And what does the data show?
We cannot say - there is no public information. Is it a dud? The intent is sound, but implementation by clubs appears weak to this outsider. There is an opportunity for UEFA to review the tool, improve and tailor it where needed, and strongly encourage and support wider use. A further step could be making it mandatory for the biggest clubs.
An annual net-zero report
UEFA already publishes its annual European Club Finance and Investment Landscape Report, which focuses on data from the top 20 revenue-generating clubs. A similar approach could be applied to sustainability.
This could be integrated into the existing report or published as a standalone document. Alternatively, an independent annual assessment by a specialist organisation—potentially funded by UEFA or the EU—would add credibility.
Standardising an Intensity Metric
One additional point: the need to standardise emissions-intensity metrics. Two issues stand out. Firstly, clubs often use different units of measurement, making comparisons difficult. Many appear to cherry-pick metrics that best suit their narrative. Secondly, revenue-based intensity metrics seem poorly suited to football. Large year-on-year revenue jumps - common among major clubs - can suggest improved emissions intensity when they simply reflect higher TV income or commercial deals. A standardised approach would improve comparability and reduce the risk of misinterpretation.
4. Enforcing and modernising regulatory requirements
Clearer rules can help reduce long-term compliance costs for clubs by providing predictability and avoiding abrupt regulatory shifts. Given the slow progress in reducing emissions and taking action, UEFA must review its regulatory approach, including looking to:
Enforce existing sustainability requirements. Clubs are required to establish and implement a sustainability strategy, yet many appear not to have not done so, despite it now being a licensing condition.
Strengthen environmental sustainability criteria. This should include:
Ensuring regulations are proportionate to club size.
Reviewing and updating voluntary guidelines and tools, and considering if any need to be formalised to drive progress.
Learning from national football licensing schemes, including those with sustainability criteria, and adopting best practices.
Clarifying existing rules. While clubs must have a sustainability strategy, the required content is currently somewhat unclear.
Considering further targeted regulations where evidence of a lack of progress in an important area is compelling - for instance, mandating climate targets for the largest clubs.
Theme 2 - System transformation: strategy, calendar and commercial reform
5. A new climate ‘sector roadmap’ for football
This might sound technocratic, but it represents a major open goal for football. At present, the sport is dotted with disconnected sustainability strategies.
Where clubs have strategies at all, they vary widely. The same is true for national and international governing bodies, whose plans often fail to link to those of clubs or to each other. Even within countries, different bodies take divergent approaches that barely acknowledge one another—for example, the FA and the Premier League, or the RFEF and LaLiga. In short, the landscape is a strategic dog’s dinner.
A sector roadmap is a multi-year strategic pathway to decarbonisation, built on rigorous analysis. It sets out how an entire sector must evolve to meet net-zero goals: the milestones and targets needed, the changes required, the resources involved, and the dependencies on progress elsewhere.
Football has unique characteristics and challenges that do not fit neatly into other sectoral plans. The sport spans complex areas—energy, travel, infrastructure, apparel, and more—that need to be viewed together.
A football-specific roadmap could address these issues holistically, provide a shared context for club-level ambitions and actions, reduce reputational risks to clubs, embed climate justice principles, and articulate expectations for clubs of different sizes.
The UN Sports for Climate Action Framework offers useful elements but is not designed to deliver a comprehensive, football-specific plan. It is rooted in (welcome) ambition and largely generic business principles rather than the detailed analysis required for a true football roadmap.
A roadmap could be created at the global level, but FIFA currently shows minimal leadership on sustainability. Given that most major clubs are in Europe, a European-level roadmap is a logical starting point—while acknowledging it would not cover the entire ecosystem.
This should be led by UEFA or commissioned independently by the EU in collaboration with UEFA. Clubs, supporters, broadcasters, commercial partners, players and other stakeholders should all be part of developing it, with innovation playing a key role in identifying new solutions and accelerating practical delivery.
6. A(nother) review of business relationships
UEFA’s sustainability strategy set a 2024 target to align its business-relationship codes of conduct with its environmental commitments. The 2022–23 Respect Report lists this target as “in progress,” while the 2023–24 report marks it as “achieved,” suggesting the review has recently been completed. However, no public information appears to explain what, if anything, has changed. Many issues fall under a review of business relationships, but two stand out.
Procurement
Based on limited available data, procurement-related emissions appear to outweigh fan-travel emissions for some of the biggest clubs3. For example, Spurs report Scope 3 Categories 1 and 2 as nearly 45% of total emissions (fan travel accounts for 42%). Liverpool reports supply chain and capital expenditure at a combined 37% of total emissions with merchandise at a further 25% and fan travel at 20%. Manchester City reports retail and merchandise at 46% of total emissions with fan travel at 12.5%.
Procurement policies sit with clubs, not governing bodies, but there appears to be a gap in shared knowledge on sustainability best practice. UEFA could help by developing sustainable procurement guidelines for clubs.
UEFA’s own procurement also shows limited attention to sustainability. Its Supplier Code has not been updated since 2019 - before it adopted its net-zero target and sustainability strategy - indicating an overdue need for revision.
Sponsorship and advertising
In 2024, the UN Secretary-General called for restrictions or bans on fossil-fuel advertising. At the COP30 international climate talks this year, a UN-backed blueprint for phasing out such advertising was launched. A recent House of Commons Research Briefing also notes that several countries and cities have introduced or are planning bans. These developments follow on from impactful ongoing sport-focussed campaigns by Fossil Free Football, Cool Down and others.
A ban in football is a matter of when, not if. UEFA sets its own sponsorship and advertising regulations. The biggest clubs, which rely most heavily on commercial revenue, will be most affected by changes. This makes it vital for UEFA to begin planning now on a structured phase-out.
7. Including Environmental Factors in UEFA’s Scheduling of Club Matches
A recent report by Scientists for Global Responsibility confirms what is increasingly evident: an expanding international match calendar leads to higher emissions. More matches and greater travel distances put additional pressure on clubs’ ability to reduce their environmental impact.
This aligns with a report released earlier this year by the French think tank The Shift Project, supported by the French Football Federation, the Ligue de Football Professionnel and others. It concluded:
“Despite our attempts, none of our scenarios reconcile climate goals with an increase in spectator numbers and/or international matches; at best, these numbers will need to stabilise.
The safest path requires rethinking the scheduling of international events around two principles: proximity (a more local audience and reduced travel between teams) and moderation (adjusting the number of matches and/or international spectators).”
UEFA has already acknowledged the link between fixture volume and emissions, saying: “The carbon footprint of UEFA events depends on the number of events organised each season.” However, it has yet to take concrete steps to look at the European club football calendar with environmental factors in mind. Alongside this is a strong argument for reforming the football calendar to protect player welfare.
The current UEFA club competition cycle runs from 2024–2027, meaning planning for formats beyond 2027 is likely already underway or will begin by 2026. Environmental sustainability must be a core criterion in designing the next cycle of club tournaments. It should also guide other UEFA calendar-related decisions, such as proposals for domestic games played overseas, UEFA’s stance on FIFA’s expanding club competitions, and the growing schedule of pre- and post-season friendlies.
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Theme 3 - Collective action and influence across the football community
8. A more collaborative approach between supporters, clubs, governing bodies and partners
Effective climate action is well known to require extensive collaboration among all stakeholders. Yet, most club and governing-body sustainability plans, where they exist, are still developed with minimal supporter involvement (notable exceptions aside).
For example, Premier League clubs’ Fan Engagement Plans contain almost no references to sustainability, while their sustainability strategies rarely mention involving supporters in their development (with a few exceptions).
The same applies to governance structures. UEFA’s Environmental Steering Group includes partner and player representation but no supporter representation, and its Social and Environmental Sustainability Committee has just one supporter representative among 26 members - despite covering a wide range of issues. Similarly, the new UEFA–EFC sustainability co-operation plan appears to overlook collaboration with supporters and others stakeholders entirely (and largely adopts a ‘more of the same’ approach).
Where engagement with supporters does occur, it is usually limited to informative or consultative methods - surveys, focus groups, and one-way communication - rather than deeper collaboration. As a result, opportunities for more hands-on partnership are being missed, along with a substantial reservoir of supporter interest, expertise, and willingness to act.
A wide range of participatory and deliberative approaches could be used instead or in addition - from co-designing initiatives to fan assemblies modelled on citizens’ assemblies.
At the same time, the capacity of supporter groups to engage on environmental issues is still somewhat nascent. This is not due to a lack of interest. Surveys consistently show strong supporter demand for greater climate action in football. But more work is needed to understand how to build capability and support meaningful involvement.
As a first step, UEFA should work with all key stakeholders, including supporters, to develop a climate-engagement strategy and/or guidelines for clubs. This links to the next approach, which is …
9. A structured approach to clubs’ and bodies’ spheres of influence
One of the most repeated phrases in sport and sustainability is that “sport, with its massive global reach, has a unique ability to inspire climate action.” It’s a bit of cliché that raises important questions: What change does sport actually aim to achieve? Who is football trying to influence? Who is best delivering the message? And what’s the most effective way to do it?
A new, more targeted way of thinking is emerging, encouraging organisations to consider their full ‘spheres of influence’. This framework looks beyond supply chains to the wider role organisations can play in advancing decarbonisation more broadly. While not yet adopted in football, Munster Rugby Club offers an early adopter example from elsewhere in sport.
This approach is especially relevant for football, given its unmatched global audience. It also broadens the focus beyond fan engagement to other influential levers - such as product and service design, financial and investment decisions, and public or policy engagement.
Take policy, for example. Transport emissions are a major issue for football. How might clubs, governing bodies, supporters and other partners influence transport policy at their national and/or local levels to reduce club-related emissions and improve public transport - a win-win for both clubs and fans?
A related side note here on communications: Several articles and studies call for a shift in climate communications to emphasise everyday benefits for people, and also the commercial advantages for businesses. How can these approaches be best taken on board in future influencing strategies too?
10. Support for grassroots football, particularly from those with the broadest shoulders
The financial impact of climate change on grasroots sport is becoming clearer. A UK Government commissioned estimate puts annual adaptation costs at around £320 million. It also notes that this figure does not capture all impacts and that additional costs are “likely to be large.” This figure also excludes the investment required for climate mitigation.
At the same time, the heavily oversubscribed EURO 2024 Climate Fund shows the significant demand for climate support within grassroots football - far beyond what the fund was able to provide or grassroots football can afford.
Investment in the grassroots will deliver long-term return on investment, whereas a delay will increase the investment needed over time to achieve similar results. Just as national governments and the EU fund a range of climate projects, there is a strong case for both national football bodies and UEFA to offer dedicated funding for grassroots climate initiatives to safeguard the game’s long-term future.
UEFA can play two key roles: first, by developing guidelines for national associations on providing climate funding for grassroots football; and second by creating an annual European climate fund that complements national climate funds, and also extends beyond its current approach which focuses on the men’s and women’s national team tournaments held every four years.
Further consideration is needed on how much funding is required, which projects should be supported at European versus national levels, and how to balance investment between mitigation and adaptation. Another crucial question is what constitutes a fair contribution from governing bodies, clubs, and especially the largest clubs?
These are issues football’s leaders must address. A core principle should be that clubs and bodies with the broadest shoulders - and the largest carbon footprints - should contribute the most. Notably, the biggest clubs are not short of a bob or two: the top 20 generated €11.2 billion in revenue in 2023/24, a 6% increase on the previous year. Revenues, particularly for the largest clubs, are set to rise further with, for instance, the next cycle of UEFA club competition broadcasting rights and participation in the FIFA Club World Cup. Alongside this profitability is rising amidst growing financial stability.
And finally - A need for a more radical thinking too
That’s your 10 for starters. But is it all that’s needed? Clearly not, more collaboration will spur more innovation in thinking, learning and action. Alongside this it is also important to explore more radical scenarios of how football is organised in the future and what these could mean for environmental sustainability. While a detailed analysis is beyond the scope of this note, some examples illustrate the potential for change:
FootBiz highlights the tension in governing bodies acting as both regulators and tournament organisers. Legal pressures suggest this dual role may not be sustainable.
Academic experts from LSE, Oxford, and Prague universities have proposed a European Sports Act to formalise rules on governance and social responsibility.
FIFA is expanding its role in club football.
Independent football regulators on financial issues have recently been set up in England and Brazil, which may lead to other countries following suit.
A shifting political and economic context. It’s fair to say this post has not had detailed attention here, it’s a biggie, and will inform future action.
These developments suggest football’s future could look very different, raising important questions about how climate action might evolve under different scenarios.
Addressing this requires further research, scenario-planning, and expertise that are beyond the scope of this note - but give us a shout if that’s your bag as I’d be happy to shoot the breeze.
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Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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This is assumed to be based on EU criteria for CSRD of more than 250 employees, annual net turnover exceeding €40 million and assets exceeding €20 million.
These UEFA figures show 11 clubs with annual revenue over €500 million and 19 clubs with over €300 million.
It would be interesting to understand if/how the emissions profiles of the biggest clubs relates to the relative importance for them of commercial revenue over broadcast and match day revenues.