Image rights in football and the commercial split

Image rights are the commercial half of a footballer's earning power, and they sit in a separate agreement from the playing contract. The club buys the right to use the player's name and likeness in its own marketing; the player keeps the ability to exploit his image commercially elsewhere. How that line is drawn is worth a great deal to both sides.

The arrangement is also one of the most scrutinised structures in football finance. Tax authorities in several countries have challenged the way image payments are routed through companies, and clubs have had to demonstrate that the commercial activity behind a payment is genuine rather than a disguise for salary.

Image rights: what they actually cover

The right covers the commercial use of a player's name, likeness, signature and other identifying features. In practice a club needs those rights for shirt sales, official publications, advertising campaigns and partner activations. A player earns from the same assets through personal sponsorships, endorsements and appearances.

The negotiation is about where the club's use ends and the player's begins. A club that has exclusive rights to everything cannot market the player without paying again; a player who keeps everything can charge the club for every campaign, which nobody wants to negotiate each time.

Commercial split football: how the split is structured

Three structures dominate practice. The club can hold all commercial rights as part of the playing contract, in which case the value is embedded in the salary. The player can keep the rights and license them back to the club for a fee. Or the two can agree a defined split, with the club holding rights within football and the player retaining everything outside it.

Why the third structure is most common

A defined split matches the commercial reality. The club needs the player's image for football products, and the player needs freedom for a watch brand or a boot deal that has nothing to do with his employer. Fixing the boundary in advance avoids repeated negotiation and keeps the tax analysis cleaner.

Image rights football explained: why tax authorities take an interest

The commercial reason for separating image rights is genuine, but the structure creates an incentive to route salary through a company at a different tax rate. Regulators respond by testing whether the company performs real activity, whether the payment is at a market rate and whether the player works for the company in substance.

Where a structure fails those tests, the payment can be reclassified as employment income with interest and penalties. Clubs and agents therefore document the arrangement carefully, and the trend in recent years has been towards simpler structures with clearer pricing.

• Evidence that the rights company employs staff or contracts real services
• A valuation basis that can be defended against comparable commercial deals
• Consistency between the licence fee and the actual use of the rights
• Clear separation between playing duties and commercial obligations
• Reporting in the jurisdiction where the player is tax resident

How the value is set

Valuations are built from commercial comparables: the player's profile, market size, existing sponsorship interest and the categories a partner would pay to reach. A young player with a strong social following can carry surprisingly high image value, and an experienced player in a smaller market may carry very little.

Clubs value the rights by what they would otherwise pay for equivalent exposure. A signing that lifts shirt sales or attracts a regional sponsor changes the calculation, and those commercial projections are often part of the recruitment case put to a board.

Why it matters for the financial rules

Payments made to a player through an image rights company are still player costs in substance, and regulators look through the structure when assessing a club. A club cannot reduce its measured wage cost simply by labelling part of the remuneration as commercial income.

The distinction is tested in the same way as other contract structures. Anything that transfers value to the player in exchange for his services belongs in the cost base, which is why the terms are examined in alongside the wider wage package and modelled against the wage bill to revenue ratio.

How rights are transferred between clubs

When a player moves, any group of image rights that the selling club holds has to be addressed in the transfer. Some clubs purchase those rights outright, some license them for the duration of the contract and some leave them entirely with the player and negotiate access when a campaign requires it.

The treatment affects the fee and the wage at the same time. A club that acquires commercial rights is buying an asset; a club that licenses them is paying for access without ownership, and the two approaches produce different amounts in the accounts for the same player.

• Outright purchase, which transfers an asset to the buying club
• Licensing for the contract term, with access rather than ownership
• Access by agreement for each campaign, which requires repeated negotiation
• Deferred rights, where the club takes control only in a defined territory

Squad-wide commercial arrangements

Many clubs now negotiate collective arrangements in which players grant a defined set of rights to the club as a group, usually through a standard contract term. The approach reduces the administrative burden and creates a consistent position for sponsorship partners who need to use several players in a campaign.

From the player's perspective a collective arrangement costs little, because it usually covers only club-related activity. From the club's perspective it removes the risk of an activation being blocked months after a sponsorship has been signed.