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I dont believe so, the English teams that qualified for champions league football in my Season 2 save were Liverpool, Manchester City, Chelsea (The top three in Season 1) and Nottingham Forest (Which qualified by winning Europa League in Season 1). Also to note that PSG won the Champions league again in season 1 of my save. I believe in this scenario, my 4th placed Man Utd team should've still qualified for the Champions League. I found other people had this problem too while researching online, back in FC25 as well, so its a possibility that there's a problem in how the game sorts out who qualifies for the Champions league. Thanks for sharing that article by the way, if correct, it would've made sense and explain the problem 👍
Your case intrigued me so I did some digging.
It is a bug, but it seems like a bug in EA's attempt to implement the dynamic co-efficiency system.
Sadly, considering how these bugs tend to accompany the game for several years before addressed (career players aren't cash cows like the casino mode players), you'll probably experience this until at least EAFC 27, in which time they'll "fix" the co-efficiency implementation and a new bug will surface for 3-4 years.
I see there are reports of other leagues as well, which pretty much confirms it to be a general bug. I thought the Carabao cup providing a Europe spot may be a factor, but at least when it comes to bugs EA is an equal opportunity developer.