With a return to European football looking likely for AC Milan, the management will have to start thinking about the squad list regulations.
It is April 15th, so it’s only right that the team and players are fully focused on the final stretch of the season, with six games to go and a top four spot to defend. Despite four defeats in their last seven matches, the Rossoneri are currently third and still have their fate in their own hands.
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Returning to the Champions League is a must for a number of reasons – both sporting and financial – but the discussion regarding squad lists also applies to the other two UEFA competitions, the Europa League and Conference League.
The directors will work to strengthen the squad available to Massimiliano Allegri but will also have to do so while considering and respecting the UEFA regulations regarding homegrown players. So, what is Milan’s situation at the moment?
What the regulations say
For European competitions, teams are permitted to name a squad of 25 players in List A. Eight of those 25 places are reserved exclusively for ‘locally trained players’ and no club may have more than four ‘association-trained players’ listed among those eight places.
What’s a ‘locally trained player’? There are two categories:
1. Club-trained players who were on a club’s books for three entire seasons (i.e. the period between the first and last official match of the relevant national championship) or 36 months between the ages of 15 and 21.
2. Association-trained players who were on another club’s books in the same association for three entire seasons (i.e. the period between the first and last official match of the relevant national championship) or 36 months between the ages of 15 and 21.
Then, there is List B. This is reserved for players aged 21 or under who have been with the club for two consecutive years. Below is how Milan currently look:
Non Italian-trained:
1. Maignan
2. Tomori
3. Pavlovic
4. Estupinan
5. Athekame
6. Modric
7. Rabiot
8. Jashari
9. Fofana
10. Loftus-Cheek
11. Saelemaekers
12. Pulisic
13. Nkunku
14. Leao
15. Gimenez
16.
17.
Club-trained:
1. Gabbia
Italian-trained:
1. Terracciano
2. Ricci
3. De Winter
List B
1. Torriani
2. Bartesaghi
3. Camarda (?)
4. Comotto (?)
As MilanNews write, Odogu is currently a question mark for several reasons. The first is because it remains to be seen whether he will remain at Milan or go on loan, while the same discussion also applies to a lot of other players regarding their fate in 2026-27.
The second doubt is about whether he would have to replace one of the 17 non-Italian trained players, given he would not have List B status. The same will apply with Andrej Kostic, who Milan officially announced recently but for the Futuro.
Summer strategy
What does this mean in view of the summer transfer window? Having a smaller squad for 2025-26 means that Milan have the room to register two more non-Italian trained players for their List A squad, and they can have one more Italian trained player (but no more).
If Milan were to try and recruit some domestic players, they would have to factor this in. For example, Moise Kean is a striker Allegri knows well from their time at Juventus and could be a leading candidate to fill the No.9 role.
Nicolo Zaniolo has been linked in recent weeks and could occupy the second striker position, given that he is another player the current coach apparently holds in high esteem and could boost the Italian presence.
Other potential transfer ideas for a more Italian Milan include Diego Coppola, a Brighton central defender currently on loan at Paris FC. Honest Ahanor of Atalanta is highly admired by the club’s management too, while €8m was spent to sign Alphadjo Cissè from Hellas Verona.
Once the final two non-Italian spots are taken and the last Italian trained slot is filled, any more room for registering new signings will have to come through exits, otherwise there is the risk of having to make some difficult decisions in terms of excluding players.
For example, last season the big headline was the omission of Luka Jovic who scored nine goals in 2023-24 but was left out because of the presence of Alvaro Morata, Noah Okafor and Tammy Abraham. Alex Jimenez was left out too. Milan would like to avoid similar headaches.




Milan Primavera has been so trash over the years when it comes to producing players that you can’t find many playing in the league that Milan can use.
Bring Bellanova back. He can actually play. And bring back Patrick Cutrone to be the 3rd striker.
Italian trained, give me Pellegrini from Roma on a free transfer
Is that based on all of the Primavera games you watch closely?
We’ve no idea of their level because they never play.
I said: “you can’t find many playing in the league that Milan can use”
How can I watch them closely if, as you said, they never play?
If they never play, we can pretty much assume their level.
No that assumes that it’s all based on merit not backhanders.
The system is broken so you can’t judge anything.
Nice article. Great to see a breakdown of these rules and which players fit in each category.
It would be nice to have seen a list of players we could bring back that would fit the list of club trained places. E.g.
Locatelli, Colombo, Brescianini, D Maldini
Also the players on loan. How they would fit into the squad list if they returned.
It’s not clear why these rules aren’t working but it seems clubs are going out of their way to circumvent them.
How does Gabbia qualify if he’s 26? Plus he was away on loan less than 3 years ago???
Terracciano has been at 3 different clubs in 3 years.
What does “on the books” mean?
If it includes being loaned out but still technically “on the books” then that’s not achieving anything.
The issue is the turnover. They need to limit the numbers of transfers and loans.
And these should be the minimum. Milan should be scraping through to tick some box.
All you need to do to qualify has home grown academy is play for you club for 3 seasons during the ages of 15 to 21. Which should equate to at least 6 potential seasons. So Gabbia qualifies as home grown academy as he spent at least 3 seasons with the club at youth or senior level during this time. It doesn’t matter if you have some time away on loan. Or even if you full transfer away and then back again. As long as you can show 3 full seasons during this under 22 years period.
Similarly Italian trained players qualify if they have played 3 full seasons between 15- 21 years at any Italian clubs. Hence why they note De Winter as Italian trained even though he plays for Belgium. He came to Genoa young enough to do 3 full seasons by the age of 22.
Pesume Odogu will eventually qualify as Academy trained for Milan if we keep him for long enough even though he is a German national.
These rules are all about prioritising players who have spent development years in your national league pyramid.
E.g. I presume Mateo Retegui despite playing for the Italian national team likely never qualified as an Italian trained player for Uefa List purposes. As he was already over 20 when he arrived in Italy.
Re. “on the books”
that means listed for you club senior or youth level. In our case this includes being listed with Milan Futuro, I believe.
If you go out on loan that season does not qualify as on a list with Milan for that season. it may still contribute to your status as an Italian trained player. E.g. Camarda this season accrued a year of development with a different Italian club to go with the 2 years he has already done with Milan since he turned 15. So that 2+1 means he will forever qualify as National trained for any Italian club. Milan need to get him back for at least 1 more full season before he turns 22 by my calculations for him to also qualify as Academy trained for us in the future.
He will already qualify as List B eligible for us until he turns 22 if/when he returns.
Bartesaghi would already qualify as Academy trained but while he also qualifies as List B it might be simpler to keep him on that. Not sure. Perhaps moving him off List B to officially senior Academy trained uses a spot we otherwise cannot use and allows a different very young player to be added to the List B. But you generally don’t want to be using that many List B players unless there is a major injury/suspension crisis.
Thanks.
So it basically doesn’t work!
Re “Terracciano has been at 3 different clubs in 3 years.”
These UEFA list rules have no interest in where you play after the age of 22. Presume Terraccianno played at least 3 full seasons for Italian clubs during this 15-21 years period and so will qualify as National trained for any Italian club forever. Given he is now 36. The relevant seasons for him were a very long time ago.