Image rights, personal brands and the budget reset for athletes: What the UK’s update on athlete image rights means for sport and business

The UK Government’s latest Budget announcement in November 2025 signals a tougher approach to the taxation of image rights. However, for athletes and their agents, this is not just a tax issue. It reflects a deeper shift in how the law views the modern sporting career, particularly where athletes are often not only employees but also now brand owners, content creators and business founders long before retirement.

The rise of the athlete as a media business

Elite athletes are no longer dependent on clubs, broadcasters or sponsors to monetise their profile. Increasingly, they control their own platforms.

A clear example is Erling Haaland’s launch of his own YouTube channel, offering fans behind-the-scenes access to training, lifestyle and personal content. This is not sponsorship. It is not a club obligation. It is direct exploitation of personal brand, audience and image, owned and controlled by the athlete.

From a legal perspective, this matters because it fundamentally changes the nature of image rights. Where an athlete owns the platform, controls the content and monetises the audience directly, the commercial substance is obvious. Equally, the tax implications become far harder to distance from the individual.

The Budget changes should be read with this reality firmly in mind.

Why image rights are under renewed scrutiny

Image rights have historically been licensed through corporate structures, often separating image income from employment income, and sometimes separating UK derived income from foreign income. Those separations are now under greater pressure, first with the move to abolish the traditional “remittance basis” for non-domiciled UK residents in favour of a 4-year Foreign Income and Gains (FIG) regime from 6 April 2025, and second with the changes announced in the Budget in November 2025 that will kick in from 6 April 2027 under which all image rights payments that have a link to employment will be subject to PAYE and NICs.

HMRC has made it clear that it will look beyond labels to assess what payments really represent. In an era where athletes are:

• running their own media channels;
• monetising personal audiences; and
• building businesses during their playing careers,

the line between salary, endorsement and personal trade is increasingly blurred.

Haaland’s YouTube activity is instructive. If commercial income flows from that channel, HMRC will ask straightforward questions:

• who is carrying on the trade?
• where does the value actually sit?
• is this exploitation of image distinct from the athlete’s performance as an employee?

These questions are no longer theoretical.

In 2019, Hull City found themselves in a tax tribunal after routing payments for Geovanni’s image rights through an offshore vehicle. The court held that the club never commercially exploited the player’s image, and the payments were, in reality, additional salary. The Tribunal’s decision now appears to have laid groundwork for what HMRC and the Treasury are formalising from April 2027.

The Tribunal’s decision in this case and other recent cases appear to have laid groundwork for what HMRC and the Treasury are formalising from April 2027.

And this is not just a football issue. In 2025, the former England cricket captain, Paul Collingwood, found himself in a UK tax tribunal after routing payments for his image rights through a UK limited company of which he was the sole owner. HMRC claimed that payments by 3 sponsors were assessable for income tax on Collingwood personally. The Tribunal held in favour of HMRC on the basis that Collingwood was a party to the sponsorship contracts and there was a lack of valid assignment of those contracts from Collingwood to his company.

Direct-to-fan platforms change the legal analysis

Athlete-owned platforms create a different risk profile from traditional endorsements.

Historically, image rights income often arose from third-party deals where sponsors paid for the use of an athlete’s image. Today, athletes increasingly act as publishers and broadcasters in their own right.

Other high-profile examples underline this shift:

• Sergio Agüero, who built a substantial streaming presence while still an active footballer
• Demetrious Johnson, whose YouTube and streaming channels operate as standalone commercial ventures alongside his UFC career.

In each case, the athlete is not simply licensing an image. They are operating a business.

From a legal standpoint, this raises issues around:

• whether income should be treated as trading income;
• the robustness of image rights company structures; and
• the interaction between employment contracts, IP ownership and tax residency.

The Budget signals that HMRC expects these questions to be answered with evidence, not assumptions.

Early commercialisation increases exposure

A particularly sensitive issue is the earlier commercialisation of younger athletes.

Haaland’s YouTube activity illustrates how brand exploitation now begins well before the latter stages of a career. That brings opportunity, but also risk.

Bukayo Saka’s image rights company (BS7 Rights Ltd) reported over £4.6m in income last year, reflecting a commercial brand built rapidly alongside his playing career. While this is a clear example of genuine commercial activity, it also highlights how early structuring can result in significant tax exposure if HMRC deems the income to be connected to employment rather than third-party licensing.

Setting up image rights structures before genuine commercial exploitation exists has long been contentious. Under the current climate, premature structures without clear substance may attract scrutiny at exactly the point an athlete’s brand starts to take off.

Agents and advisers should be cautious about treating early image rights planning as a default step. In some cases, it may increase risk rather than manage it.

Ownership beats endorsement, but attracts attention

There is an important distinction between endorsement and ownership.

Athletes like Lionel Messi, who has launched and invested in consumer brands during his career, and Cristiano Ronaldo, whose business interests span hospitality, fitness and media, demonstrate how image rights can underpin genuine entrepreneurial activity.

Jesse Lingard followed a similar route during his Premier League career, launching a fashion label and trademarking the “JLingz” brand. While not at the scale of Ronaldo, it nonetheless exemplifies how mid-career commercial ventures create independent brand value.

Where athletes are owners, founders or operators of businesses, the commercial reality is clear. However, that same clarity makes it harder to argue that income is passive or remote from the individual.

The Budget reinforces a simple principle: the more real the business, the harder it is to separate it from the athlete for tax purposes.

That is not a problem if the structure is right. It is a problem if it is not.

Image rights are not dead, but complacency is

The UK Government has not abolished image rights. What it has done is raise the standard – again.

Going forward, defensible image rights arrangements will need:

• a clear commercial rationale;
• demonstrable exploitation; and
• accuracy and consistency in implementation across contracts, IP ownership and tax treatment.

Athletes building platforms like Haaland’s YouTube channel are well placed to evidence genuine brand value. Those relying on paper structures without substance, or adequate structures poorly executed, are not.

And where there is no commercial activity at all, as the Hull City case showed, clubs and athletes may face retrospective tax bills (plus potentially interest and penalties) on payments wrongly characterised as image rights.

What athletes and agents should be doing now

The Budget should trigger a strategic review, not a rushed reaction.

Athletes and agents should consider:

• whether existing image rights structures reflect current commercial reality;
• how direct-to-fan platforms are owned and monetised;
• whether income streams are correctly characterised from a legal and tax perspective; and
• how club contracts, sponsorships and personal ventures interact.

This is about protecting long-term careers, not simply managing short-term tax exposure.

A reset moment for modern sport

The rise of the athlete as a brand owner, media outlet and entrepreneur is irreversible. The recent Budget does not change that. It simply forces the industry to align legal structures with reality.

Erling Haaland’s YouTube channel is a glimpse of the future. Athletes who structure their affairs with that future in mind will be far better placed to withstand scrutiny and build lasting value, particularly before the April 2027 changes take effect.