Player Image Rights: Mbappé, Messi and the Legal Gap in Vietnamese Football

In mid-September 2026, Kylian Mbappé stayed in the dressing room while his France team-mates lined up for a sponsor photo shoot. The session sat on the French Football Federation's commercial calendar, scheduled immediately before two Nations League fixtures. Mbappé refused to take part. Within days, the federation president was speaking to the press, and the FFF had committed to reopening negotiations over the image-rights agreement with its international players.

One morning cancelled. What was actually placed on the scales was not a morning in the life of a 23-year-old. It was the way an entire football economy prices a face.

When I first read that story, my mind went somewhere else entirely. In the V-League, hundreds of player photographs are used every season for advertising, for banners, for social content, and almost nobody asks the person in the picture. Mbappé could stop a photo shoot. Most Vietnamese players cannot stop one, because they do not know they have the right to.

A player's face has become an asset with a cash flow. The legal system governing that asset still runs on clauses drafted when football made its money at the turnstile.

To see the fracture, you have to split image rights in football into two layers. The first belongs to the individual: face, name, signature, voice, and now the three-dimensional avatar inside a video game. The second belongs to the collective: the club, the national team, the league. The two layers overlap inside the same television frame, and almost every dispute begins with a single question — who is permitted to sign a contract for which layer.

In England, clubs typically sign a separate image-rights agreement sitting outside the employment contract, largely for tax reasons. In Spain, personal image rights are separated from the wage bill and declared under their own framework, again for tax reasons. At national-team level, the French federation has enforced a charter on players' commercial obligations since the 2026 World Cup and the Knysna strike, capping the number of sponsors a player must promote in a season. The figure most cited in the French press is five sponsors.

The structure in the V-League is far thinner. Vietnamese player contracts are usually short, built around wages and signing fees, while image-rights clauses are often a single line copied from an old template. The league's commercial rights sit with its operating company. Players have almost no collective bargaining mechanism for their own faces.

The legal floor exists. Nobody uses it. Article 32 of Vietnam's 2026 Civil Code states plainly that an individual holds rights over their own image, and that using a person's image requires that person's consent. An exception covers images of public figures at public events or in the public interest. The Advertising Law prohibits advertising for goods and services banned by law, and betting falls inside that category.

Put those three pieces together and the picture is clear: a football economy that already generates commercial value from players' faces, a legal framework strong enough to protect that value, and an enforcement gap sitting precisely in between.

Collective image-rights agreements at national-team level operate as a revenue-sharing vault. The federation sells a sponsorship package, and what makes the package valuable is that the entire squad appears together. But each player's marginal contribution to that package varies enormously. A substitute in a qualifier has close to zero advertising value; Mbappé in 2026 was the most searched athlete on the planet.

A collective image-rights deal functions as an internal tax: the largest star pays the most in, and the squad player collects. That is why the model has survived so long, and why it always strains at exactly one point — the moment the star realises he is subsidising everyone else.

I backed Mbappé when the world was still doubting him, and I am not withdrawing that bet. But the 2026 bet was about a left foot. The 2026 bet was about copyright. A player who has reached the level where national-team income is a rounding error in his total earnings has every incentive to renegotiate, because he no longer needs that share to live, while the federation needs him to sell the package.

In France, the balance tipped far enough toward the player to force the federation back to the table. In Vietnam, no player has reached that position yet. The mechanism, however, is identical — and the mechanism is the thing worth watching.

The second layer sits in tax, and it explains why image rights are such fertile ground. In 2026, a Spanish court convicted Lionel Messi and his father of tax fraud linked to image-rights income, handing down a 21-month sentence later replaced by fines. In 2026, Cristiano Ronaldo paid an 18.8 million euro fine and accepted a 23-month suspended sentence in a case of the same nature.

The shared mechanism is not complicated. Image-rights income was routed through entities registered in low-tax jurisdictions, while Spanish tax authorities argued that the income was generated by activity in Spain and therefore taxable there.

Image rights are where football's intangible value leaves the wage bill and enters the tax system — and where both the player and the tax authority end up losing more than either expected. The reason image rights became the preferred vehicle is simple: there is no market reference price for a photograph. A goal has a price. A Champions League place has a price. A photo shoot does not. Where there is no reference price, there is room for arbitrary valuation.

That leads directly to the third layer, where most of the real money is generated and where most disputes will erupt over the next few years: third parties exploiting player images outside the club relationship.

A modern football title such as the EA FC series carries more than 19,000 players across more than 700 clubs. Every face inside it is a licensing agreement, or a collective agreement signed on the player's behalf. A book about a player uses a cover photo pulled from social media. A documentary poster. A banner on an unlicensed betting site. An avatar reconstructed by artificial intelligence from composite images.

In every one of those cases, the central legal question is identical, and it is not whether the image was used. The line falls on what the image is selling: a story or a product.

Using a player's photograph in an investigative feature about his injury is editorial use. Printing the same photograph on the cover of a book that sells 200,000 copies is commercial exploitation. Putting a Vietnamese international's face on a betting banner is commercial exploitation — and exploitation for a service the law prohibits.

There is a subtler layer that lawyers call the alteration argument. When an image is recoloured, cropped, stylised or caricatured, the user typically argues that the work has been transformed enough to become a new creation, and therefore no longer a copy of a personal image. The claimant argues the opposite: the very fact of alteration to make it more commercially attractive makes the exploitation more serious.

Translated into football, that argument has an enormous future. A stylised in-game avatar, an AI likeness assembled from thousands of photographs, a book cover recoloured for shelf appeal — all of them land in that grey zone. And a grey zone without precedent is a grey zone that keeps being mined.

In Vietnam, that zone is being mined daily. Based on my experience covering V-League matches, a player's matchday kit typically carries between four and six separate commercial marks, plus the league operator's signage behind the press-conference backdrop. When the ball goes dead, I start reading the game — and in the V-League, the interval is when the signage parades across the frame, with the player standing in the middle of it.

Most of those marks belong to the club or the league operator. The player appears as a carrier. In exchange, he receives wages and a signing fee. That arrangement made sense while the commercial value of a Vietnamese player was low. It stops making sense when Vietnamese internationals' faces appear on unlicensed betting sites, on knock-off merchandise, in third-party monetised content — with nobody in the system holding a duty to stop it.

The V-League lacks a collective bargaining body for players' image rights, and that absence is paid for in banners nobody controls. A single player suing a betting site with servers abroad is a fight he knows he loses before it starts. A players' association with a legal budget is a different proposition.

The majority looks at the star; I look at the gap. And the biggest gap here is not a missing law. Article 32 has existed since 2026. The gap is a missing party with both the motive and the resources to use it.

At this point I have to argue against myself, because the case above has a fatal weakness.

If image rights are tightened, who benefits? Not the average player. The beneficiary is the small group with genuine commercial value — the group that already has money. In a league where most players earn modestly against the national labour baseline, forcing clubs to pay separately for a handful of players' likenesses takes money from the very pool that pays everyone else's wages. I would be championing a reform that narrows distribution rather than widening it.

The second weakness runs the other way. If players win broad claims, sports journalism loses first. Match photography, portrait work, illustrative images in investigations into a player's private life — all of it becomes exposed to a signature that cannot be obtained. The public-interest exception in Article 32 is a necessary wall, and it is also a wall that erodes quickly once these claims are framed as purely commercial matters.

The third weakness is the one I weigh most heavily. Perhaps the market has already priced this correctly. If V-League players' images genuinely carried large commercial value, contracts would have allocated them long ago, because every club wants to monopolise a revenue-generating asset. Thin image-rights clauses may reflect an uncomfortable truth: that value does not yet exist at meaningful scale. And if it does not exist, building a legal apparatus around it simply adds transaction costs to the parties with the least money.

I have a habit of reading every gap as an opportunity. Not every gap is one. Some gaps are simply places nobody has needed yet.

But one fact keeps this out of that second category. Image rights have already become real money in the markets Vietnamese football is integrating into. Vietnamese players are signed as brand ambassadors, appear in international campaigns, and are absorbed into foreign platforms' content. The money has arrived. Only the plumbing is missing.

So my forecast is not a landmark lawsuit. It is more specific.

Within 24 months, at least one V-League player, or his representative, will register a trademark over his name and likeness, or send a formal cease-and-desist letter to a commercial user. No courtroom required. Just a letter with a lawyer's signature on it.

In the same window, the league operator or the federation will publish a standard image-rights clause for player contracts, or a set of collective licensing rules. It is the cheapest and least risky step available, so it will arrive first.

And a third forecast, easier to verify than either: a domestic game publisher will sign individual likeness deals with a group of national-team players. When that contract appears, its price becomes the first reference price for a Vietnamese footballer's face. And once a reference price exists, everything else shifts.

Modern football has no randomness, only data that has not been read yet. Vietnamese football's next transfer window will not be about a striker. It will be about an image-rights price list, and about who at the V-League becomes the first to understand that his face does not belong to his club.

When the ball goes dead, I start reading the game. And this one is being played somewhere nobody is filming.