I'm also on 25/27 and am the 1 of the 4 that I mentioned above that will be going on someone else's ticket for this. Loads of our lot are on 25/27 as well but will not have a sniff for this unfortunately.
The thing is, you would get one on 25 no issues if they said card holder only
if they stopped named transfers, anyone with a couple of euro away credits would shoot right up, and those like you would get literally every single game regardless of allocation if you continued to go every game
But like you said they can't change it mid season, and they would need to announce chances prior to the draws taking place so people don't book
If they were to do it, maybe they'd need to do a fan update or work out whos attended what over the last few years
So many ways it could/should change, the only certainty is that it is not sustainable in its current form
I get the feeling Milan original criteria wasn't a mistake in terms of intention or process, but was a mistake in terms of making the wrong type of change and unannounced