Wolves will have to satisfy the Premier League that their relationship with Jorge Mendes does not break league or FA rules, following a promotion secured with a manager and key players connected to the super agent.

The club’s ownership structure and details of Mendes’s influence must be fully disclosed during the regulatory process, which will begin shortly, of accepting Wolves into the top flight.

The FA rules on clubs’ relationships with agents, now called “intermediaries”, aimed at guarding against conflicts of interest, prohibit owners also owning a stake or having an interest in an agency. Similarly agents are prohibited from having “a material influence” over the affairs of a club.

Last summer Wolves confirmed that the club’s owner since July 2016, the Chinese conglomerate Fosun, does own a stake in Mendes’s company, Gestifute. “Fosun have a percentage stake in the Gestifute company headed up by Jorge Mendes,” the club said.

That would appear to put Wolves in breach of the FA’s regulation, which states that: “[An] entity with an interest in a club shall not have any interest in the business or affairs of an intermediary or an intermediary’s organisation.”

The same rule prohibits an agent from having an interest in a club and defines “interest” as owning a 5% stake or more, or “being in a position or having any association that may enable the exercise of a material, financial, commercial, administrative, managerial or any other influence over the affairs of the club whether directly or indirectly and whether formally or informally”.

Having acquired the stake in Mendes’s agency in January 2016, the Chinese owner “canvassed advice” from Mendes before buying Wolves six months later, the club’s managing director, Laurie Dalrymple, said on Sky TV this week. Since the takeover Mendes has been involved in recruitment as the manager of his longstanding client Nuno Espírito Santo and Portuguese players who have transformed the quality of the Wolves squad.

Wolves’ ownership structure and Mendes’s activities on behalf of the club and its owner have been approved for two years since the takeover by the FA and EFL. Neither body has explained how Wolves’ arrangements comply with the rules but informed sources said the FA and EFL have been satisfied because the shareholding in Gestifute, reported to be 20%, is not directly owned by Fosun.

Jorge Mendes at Molineux where he has been described as ‘a close friend and an adviser’ to the Wolves chairman, Jeff Shi. Photograph: Malcolm Couzens/Getty Images

Public disclosures have stated the stake is owned by Shanghai Foyo, a company majority owned by the Fosun chairman, Guo Guangchang. Gestifute and Shanghai Foyo have since January 2016 been involved in a joint agency and marketing venture in Chinese football; the launch in Shanghai was attended by Mendes and officials from Benfica and Monaco, where Mendes has been highly influential.

The EFL has said it believes the rules have been complied with after Wolves gave undertakings and put “appropriate arrangements in place” following Fosun’s takeover from Steve Morgan in July 2016.

Wolves are compiling a further written explanation of Mendes’s position for the EFL, following complaints last month by the Leeds owner, Andrea Radrizzani. He tweeted during Leeds’ 3-0 defeat by Wolves: “Not legal and fair to let one team owned by a fund who has shares in the biggest players’ agency with evident benefits (top European clubs giving players with options to buy) … why the other 23 teams can’t have the same treatment?”

Radrizzani followed that with a letter to the FA, EFL and Premier League seeking clarification of Wolves’ relationship with Mendes. He told the BBC that when he was preparing to buy Leeds last year, he sold his shares in an agency, on advice from his lawyer: “I did because obviously there is a conflict of interest and I always pay attention to staying within the rules.”

Dalrymple confirmed this week that Mendes “has advised us on players we have taken but equally he has advised us on players we have not continued to take” and that: “There are some players that are connected with him who have come in and done a really good job for us.”

Despite that acknowledgment, and widespread reporting that the standout signing from Porto, Rúben Neves, and other Portuguese recruits, are Mendes clients, neither Mendes nor Gestifute is declared as any of the players’ agents on the FA’s record of Wolves’ signings published this month.

Neves signed for Wolves for £15.8m in the summer; his agent, recorded in the FA’s document based on filings by Wolves, was another Portuguese intermediary, Jorge Pires Serralheiro. The same agent acted for other young Portuguese players signed by Wolves who are commonly cited as Mendes clients: Pedro Gonçalves, Rúben Vinagre and Boubacar Hanne. The midfielder Diogo Jota, 21, who has excelled on loan from Atlético Madrid, was represented by a Spanish agent, Carlos Bucero Gómez, according to the FA’s document.

Gestifute appears only once as an agent in the signings Wolves are recorded to have made last summer: another Gestifute director, Andy Quinn, an accountant based in Dublin, is stated to have acted for Wolves when Jota was signed.

Those signings followed the acquisitions the previous year of other Portuguese players, including Hélder Costa, Ivan Cavaleiro and João Teixeira, who were represented by a lawyer, Carlos Osório de Castro, or an agent, Valdir Cardoso, understood to do work for Gestifute.

A Wolves spokesman said neither Serralheiro nor Bucero was associated with Mendes or Gestifute. The club has consistently played down Mendes’s influence. Dalrymple, despite confirming the signing of players “connected” to Mendes, described him again this week as an adviser and close friend to the chairman, Jeff Shi, who “can use him as a sounding board”.

Wolves are “still completely comfortable with their position,” Dalrymple said, and will provide the same information to the Premier League as they have given to the EFL and FA.

“We don’t believe, and I don’t believe the authorities believe, that we’ve stepped outside the rules,” he said.