Image rights in football: contractual structure and common conflicts

When Lionel Messi signed with Nike at age 14 and then switched to Adidas in 2006 for double the money, it generated a commercial conflict with FC Barcelona, whose main sponsor was Nike. When Paulo Dybala was about to sign for Tottenham in 2019, the transfer fell through — not because of sporting reasons, but because of problems with theimage rights.

Image rights are no longer a secondary issue in professional football. For many elite players, income from exploiting their imageexceed their base salary. And for clubs, the image of their figures is a commercial tool that generates millions in merchandising, sponsorships and advertising campaigns.

However, most players — especially young players and those playing outside the major leagues — do not understand how these rights work, how they are contractually structured, or what risks they face if they sign without advice. In this article I explain everything you need to know.

What this article covers

What are image rights in football
Employment contract vs. image contract: the double structure
The Image Rights Company (IRC): what it is and why it is used
What rights does the player transfer to the club by default?
The separate image agreement: how it works
Common conflicts: sponsors, exclusivity and transfers
Image rights during FIFA competitions
Tax implications: the eye of the regulator
Practical guide for players

What are image rights

In the context of football, "image rights" refer to theproperty rights over personalityof the player: the right to control, license, exploit and prevent unauthorized use of attributes related to his image. This includes:

Name, nickname and initials
Image, photography and likeness (physical appearance)
Voice and statements
Signature and autograph
T-shirt number
Social media accounts
Any other characteristic that is identifiable with the player

These rights have aindependent commercial valueof sports performance. A player can be mediocre on the field but have an enormously valuable image due to his presence on social networks, his lifestyle or his charisma. And vice versa: a technically brilliant player may have little image value if he does not have a media presence.

The double structure: employment contract + image contract

When a player signs with a club, there is typicallytwo streams of incomeseparate:

Employment contract (employment)	Image contract (commercial)
Base salary, performance bonuses, team success bonuses, signing bonuses and loyalty	Payments for license to use image in merchandising, advertising, promotions of the club and its sponsors
The player is paid asemployee	It is paid to theImage Rights Company(IRC) of the player as commercial consideration
Subject to labor and tax legislation of the country	Subject to commercial and tax legislation (may have different tax treatment)

Recommended practice:According to experts such as Daniel Geey (one of the UK's most renowned football lawyers), best practice isnegotiate the image agreement first and then the salary. The reason: image value must have an independent business justification — it is not simply a way to disguise part of the salary with more favorable tax treatment. If structured poorly, tax authorities may reclassify the image payment as a hidden salary.

The Image Rights Company (IRC)

Most high-profile players manage their image rights through aimage rights company(Image Rights Company or IRC). The player is the sole shareholder/beneficiary of the IRC, and it is the IRC (not the player personally) that signs the image contracts with the club and with sponsors.

Why create an IRC?

Tax optimization
In many jurisdictions, income from a business partnership is taxed at a lower rate than personal employment income. But this must be structured correctly and with real business justification.

Professional management
The IRC allows you to manage all image contracts, endorsements and sponsorships in a centralized and professional way, with separate accounting of personal assets.

Post-retirement continuity
IRC can continue to generate image licensing revenue long after the player retires. The image of a legendary footballer still has commercial value.

What rights does the player transfer to the club by default?

Standard employment contracts already include an assignmentlimitedof image rights to the club. For example, Clause 4 of the Premier League standard contract allows the club to use the player's image in promotional, community and public relations activities for the club, its commercial partners, the Premier League and its main sponsors.

But there is a key limit: the use of an individual player's imagecannot be greater than the average usage of all first team players. That is, the club cannot disproportionately use the image of its star without a separate agreement.

If the club wants to exploit the image of its star intensively — in sponsorship campaigns, personalized merchandising, commercial appearances —, it needs aseparate image agreementwith the player's IRC and pay an additional fee for it.

Common conflicts

1. Conflict between the player's sponsor and the club's sponsor

This is the classic. The player has a personal contract with Nike, but signs for a club sponsored by Adidas. Or the player promotes Pepsi, but the club has an agreement with Coca-Cola. These conflicts can block transfers or lead to costly litigation.

2. Excessive or perpetual transfers

Some clubs include clauses that allow them to use the player's imageafterbefore the employment contract ends. This is especially problematic: if you signed a contract at age 19 with a perpetual image clause, your image could be exploited by that club forever.

Golden rule:Never sign a contract that gives a club the right to use your imagein perpetuity. The transfer of image rights should be limited to the duration of the employment contract, with a reasonable transition period after departure (for example, 6 to 12 months to eliminate existing merchandising).

3. Lack of commercial justification (tax problem)

In the United Kingdom, HMRC (tax authority) has investigated virtually all Premier League clubs for image deals that it considered "disguised remuneration." If a Championship substitute player has an image deal worth £500,000 a year without commercial justification, the tax authorities will reclassify that payment as salary and require payment of employment tax.

4. Image rights and video games

Games like EA Sports FC and eFootball use the image of the players. These rights are typically covered by collective agreements between game developers and player leagues/unions (such as FIFPRO), but can lead to disputes when individual players want to opt-out or negotiate different terms.

Image rights during FIFA competitions

During FIFA competitions (World Cup, Club World Cup), additional rules apply:

FIFA sponsor exclusivity:FIFA maintains official sponsors (Adidas, Coca-Cola, etc.). Promoting a direct competitor during competition windows is prohibited.

Ambush marketing ban:FIFA prohibits any attempt to create an unauthorized association between non-sponsor brands and their competitions. Even scheduling commercial campaigns around a FIFA tournament can cause problems.

Social networks:FIFA allows the use of social networks during its competitions, but distinguishes between personal content and content that could be confused with official content from FIFA or its sponsors.

Practical guide for players

Before signing any contract that involves your image

Seek specialized legal advice.A sports lawyer who understands image rights, not just employment contracts. They are two different worlds.
Evaluate if you need a CRI.If you have significant image value (personal sponsors, presence on networks, media profile), an IRC can be beneficial. But it must be well structured from a tax point of view.
Negotiate image rights separately.Don't let the club put everything into the salary. A separate, well-justified image agreement gives you more control and flexibility.
Limits the transfer in time.The transfer of image to the club must be tied to the validity of the employment contract. No transfers in perpetuity.
Review conflicts with existing sponsors.Before signing, verify that your personal sponsors do not conflict with those of the club. If there is a conflict, negotiate a solution before you sign — not after.
Keep control of your social networks.Some clubs ask for access or co-management of networks. Think carefully before giving up that control.
Document the commercial value of your image.If you are going to receive significant payments per image, have documentation that justifies that value (followers on networks, media reach, history of endorsements). This protects you from tax authorities.
Check what happens to your rights if you are transferred.When you leave the club, your image rights should revert to you (or your IRC). The club cannot continue exploiting them indefinitely.

The Latin American dimension

In South America, image rights have additional particularities. InArgentina, for example, the image rights of players are recognized by the Civil and Commercial Code (art. 53) and by the Intellectual Property Law. InBrazil, the "Lei Pelé" (Law 9,615/98, updated) and sports labor legislation establish that arena rights (rights linked to the transmission of sporting events) have specific treatment.

In general, separate image agreements are less common in South American leagues than in Europe — many players do not have IRC or formal agreements — which means that when they emigrate to Europe and are faced with sophisticated image contracts, they are often at a negotiating disadvantage. If you are in that situation, the recommendation is clear:do not sign without specialized legal advice.

This guide is based on analysis from Brabners (November 2025), Daniel Geey (February 2023), Mills & Reeve / Reevaldo (September 2025), Naik Naik (July 2024), Global Sports Advocates (September 2025), World Football Index (August 2025), the Premier League Standard Contract (Clause 4), and applicable legislation. This guidance is informative and does not replace the advice of an attorney specializing in sports law and intellectual property.

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Image rights in football: contractual structure and common conflicts