I'd look at the tactical spot first -
Brian Shanahan's advice sounded spot on to me, and dovetails with a change which SI have made for this version to make a clear "last defender" much more likely to pick up a red if he fouls an attacker. So that's my first guess.
My second guess would be your Captain, because, gosh was it back in FM'05? One of my first posts on this forum was asking why I was getting so many red cards.
The advice I got was that its not just enough to have a Captain with a high Influence: you need to look at what he influences his teammates to
do.
In my case, I had a high Bravery, high Aggression, high Influence player .. so he was getting in a lot of reckless challenges and picking up a lot of fouls and yellows. I suspect he also had the PPM "Likes to argue with officials" because he'd then argue the call and get another yellow and get sent off ... but worse, the rest of my squad picked up his habit of arguing with the refs, so I started getting matches where I'd have four or five yellows and a red .. most of them for dissent!
Changing my Captain (to somebody with lower Influence, but middling Aggression, who didn't argue with officials, and had high Determination, Team Work, and Work Rate) really changed the character of my squad over the next two to three seasons: we eventually became a hard-working determined side who could play full matches on "Hard" tackling and gracefully accept the extra fouls and yellows that brought about. It was a pretty stunning difference - and really helped "sell" me on how astonishingly deep the game is.
Even if its not either of those two .. rest assured, there
is a good reason you're having trouble, and you will be able to find and fix it.
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