England Supporters Club

There's a clause in the new ticketing T&Cs which nobody has commented on so far. I can't check whether this clause was in the original T&Cs because they're no longer on the UEFA website, but I can confirm that there was no corresponding clause in the Euro 2016 T&Cs.

In the event that a Ticket Holder (which, for the avoidance of doubt, includes the Successful Applicant and any Guest(s)) is unable to attend the relevant Match for medical reasons (including but not limited to medical reasons in the context of COVID-19), the Successful Applicant shall not be entitled to a refund in respect of such Ticket but shall, subject to any PNA Allocation Rules to the contrary, be entitled to transfer such Ticket to a friend or family member (who shall in turn become the Guest for the purposes of these Terms and Conditions), provided that such transfer is carried out in compliance with, and subject to, Articles 7.1 and 7.2 and that the personal details of such individual are provided in accordance with the procedure notified to the Successful Applicant by UEFA.

"Medical reasons" doesn't necessarily imply that you have to be ill for this clause to apply. I read it to mean that you will be able to pass your ticket to someone else if :-
-  you catch covid-19,
-  you return a positive PCR test and have to self-isolate, even if you're not ill,
-  you have to self isolate because you have come into contact with someone else who tested positive.

Note that any transfer has to be done through the UEFA process. Also, tickets acquired through a PNA (which means from the official FA allocation) will have to be transferred in a way consistent with the PNA allocation rules, i.e. only to another ESTC member.