Nypan to Man City and how clubs navigate post-Brexit market

On the face of it, Manchester City's £12.5m deal to sign Norwegian teenage prodigy Sverre Nypan is the Premier League side looking to the future.

But with the UK no longer part of the European Union, clubs now have to navigate a more complex transfer and work permit system to ensure players - especially those who are yet to establish themselves at the top level - are able to move to England.

Nypan is 18, has yet to earn full international honours for Norway, but he has signed a five-year contract at Etihad Stadium in what has been a record sale for Rosenborg.

Since Brexit, clubs have to consider regulations around Governing Body Endorsements (GBE) and, more recently, Elite Significant Contributions (ESC) - the criteria which has made it easier for English teams to sign players.

Manchester United's deal for left-back Diego Leon this summer and Tottenham's move two years ago for defender Luka Vuskovic are perfect examples, while Chelsea have also used the system well.

But how do clubs plot their way through the market now?

GBE stands for Governing Body Endorsement which, since January 2021, has been required for any non-British player to play professionally in the UK.

There are two main ways to get a GBE - an autopass, or qualification through criteria compiled by the Football Association.

Some players gain an autopass through their international record, earned by the number of appearances for their national team over the past two years.

In most cases only competitive fixtures are included, with friendlies only considered in extreme cases such as a lack of competitive internationals in the timeframe.

If players have played more than 30% of games for a nation ranked 1-10 in the world they will be eligible for an autopass. If they represent a side ranked 31-50 - including Norway, Romania and Ivory Coast - they must have played over 70%.

Spain international Martin Zubimendi, who joined Arsenal for a deal worth almost £60m from Real Sociedad, has an autopass. But Brighton signing Charalampos Kostoulas, bought from Olympiakos for over £30m in June, had to qualify for a GBE with 17 points.

A minimum of 15 points is required, earned through a variety of criteria - league quality, domestic minutes played, league position, continental progress and minutes played in continental competitions, including the Champions League or the Copa Libertadores in South America.

The Premier League, Bundesliga, La Liga, Serie A and Ligue 1 are all considered Band One and earn players 12 points.

Band Two includes the English Championship (when signing non-British players who do not automatically qualify), Portugal's Primeira Liga, the Eredivisie in the Netherlands, Belgian First Division A, the Turkish Super Lig, while Band Three includes Major League Soccer in the United States. The Greek Super League is considered Band Four, while Band Five includes Poland's Ekstraklasa.

Kostoulas has yet to feature for Greece, but playing in the Super Lig earned him six points, his domestic minutes percentage counted for three, Olympiakos winning the title earned him three and reaching the Europa League quarter-finals earned four, with his minutes played on that run earning another one point.

The ESC rules allow a team in England [only England in the UK] to hold the registration of a player who does not qualify for a full GBE - one who cannot reach 15 points or get an autopass.

Clubs in the Premier League and Championship have up to four ESC spots each, but they are not entitled to all four automatically.

The main consideration for the number of slots is the percentage of minutes clubs give to their English players.

The magic number is 35%. Dropping below that begins to reduce the number of ESC slots available to Premier League and Championship clubs.

League One and Two clubs have a maximum of two ESC spots, although sides at that level are unlikely to be in the international market as much.

Once a slot is used on a signing, such as Nypan, it is gone until such time as the individual is sold or converted into a full GBE player.

Conversion can happen after 12 months if a player in an ESC slot then meets the GBE criteria or plays a certain percentage of available minutes for the team. Their ESC slot is then returned.

It could happen if the player plays in 25% or more of matches which qualify for the club.

There are criteria to bring in a player on an ESC - it is not a complete wildcard.

A player can hit any of eight clauses presented by the FA in their GBE regulations. These include: playing in at least one competitive youth or senior international match for a top-50 ranked nation, or five times if the country is outside the top 50.

Players could also have played in at least five domestic youth or senior competition matches, but they must be in a Band 1-5 league.

For example, Cherif Yaya, who joined Nottingham Forest in July from Portuguese club Rio Ave - both clubs owned by Evangelos Marinakis - moved to England on an ESC.

Manchester City made their first move using an ESC to secure Nypan. The teenager did not qualify for a GBE as he only has seven points.

The avenue of clubs bringing in 16-year-olds, like Arsenal did with Cesc Fabregas in 2003, are over because of Fifa regulations stopping them from signing players under 18 directly.

Until Brexit, this rule was superseded by the EU's freedom of movement, therefore the movement of 16 and 17-year-olds is still frequent within the EU and one of the main reasons more Irish players can now be found in European clubs.

However, there are other ways. Tottenham signed Vuskovic under ESC rules when he was 16 in 2023. The centre-back stayed with Hajduk Split before being loaned to Radomiak Radom in Poland and Belgium side Westerlo.

He played 36 times last season, scoring seven goals, as Westerlo finished seventh in Belgium's top flight. Spurs' work paid off with Vuskovic now classed as a GBE and he made his Croatia debut against Czech Republic last month.

Chelsea have also utilised the system to their advantage. Andrey Santos signed in January 2023 from Vasco de Gama, remaining with the Brazilian side on loan after initially missing out on a work permit.

He was issued one that summer and sent on loan to Nottingham Forest for 2023-24, but he managed just two appearances before instead joining Strasbourg, Chelsea's French sister club, on an 18-month loan.

Kendry Paez, Mike Penders, Dario Essugo and Estevao Willian have also all moved to Stamford Bridge this summer on GBE deals, after initially staying with their parent clubs.

Newcastle have been active in the ESC market by signing 18-year-old winger Antonio Cordero from Malaga.

"The trend is to get young players and put them on a long contract and it gives you a lot of flexibility," said Andy Watson, owner of website GBE Expert Hub, who guides clubs on the intricacies of the system.

"Then hopefully they establish themselves. Santos at Chelsea is a great example. They will probably keep him but could have sold him for tens of millions.

"It's become a business in terms of player trading. You need to have careful planning. You can't just sign anybody.

"With the ESC slots there has been more freedom, but there still needs to be a plan of how to get the players out of those slots. You can only use four.

"ESC is being used to sign players who are very young and a bit more of a risk and it wouldn't surprise you if the ones who have used ESC more than others are Bournemouth, Aston VIlla, Wolves.

"About 75-80% of the ESC transfers [in 2024-25] have been for 18-year-olds."

There has been a rapid rise in international recruitment in the Championship, owing much to the introduction of the ESC.

Last season, according to GBE Expert Hub, there were approximately 59 ESC transfers, up from approximately 23 in 23-24 season, while there were 107 GBE-related deals, rising from 19 in 2021-22 when the regulations were first introduced.

Wilson Isidor scored 12 goals for Sunderland after initially joining on loan from Zenit St Petersburg, helping the Black Cats return to the Premier League after an eight-year absence.

His ESC move became a GBE one once the Black Cats made the deal permanent in February.

Defender Torbjorn Heggem missed just one league game for West Brom after joining from Sweden's IF Brommapojkarna, while Derby goalkeeper Jacob Widell Zetterstrom played 41 games having signed from Djurgaarden in Sweden.

"There's been almost an explosion of overseas recruitment in the last 12 months which I don't think people foresaw - a lot of people felt Brexit would restrict foreign trade and it hasn't," said Watson.

"It tells you recruitment teams are using the data more in the non-domestic market.

"There aren't as many bad decisions being made at Championship level [compared to the past] and not as many clubs getting into trouble. ESC and Brexit form part of it.

"The regulations of GBE almost ringfence the pool of players you can go for, so you are not taking as many risks or making as many bad decisions. That is one of the good things from the regulations."

With the 15 points needed for a GBE, it is unlikely players available to League One and League Two clubs would qualify, so the ESC opens up more options.

Reading profited from the rule by signing New Zealand centre-back Tyler Bindon from LAFC academy in 2023, before selling him to Nottingham Forest in February. He is due to play on loan for Sheffield United this season.

Notts Country signed American goalkeeper Tyler Miller on an ESC in April after striker Alassana Jatta played enough minutes to qualify as a GBE and free up an extra spot. Miller was released at the end of the season.

Bolton's Szabolcs Schon played 44 times last season after joining on an ESC from Hungarian side Fehervar, while Peterborough signed defender Oscar Wallin and forward Gustav Lindgren from Degerfors last season.