The FIGC Judgment: EU Court of Justice Clarifies the Boundaries of Sporting Autonomy and Sports Justice

In this entry for the Covington Competition blog, authors Laurie-Anne Grelier & Toni Pitesa (Covington & Burling) discuss the European Court of Justice’s (ECJ) July 2026 judgment in FIGC (Joined Cases C-424/24 and C-425/24), which examines the compatibility of disciplinary sanctions imposed by sports associations with EU law. The case arose from sanctions against two Juventus directors over alleged artificial capital gains and inaccuracies in the club’s financial statements. The judgment addresses both the application of EU fundamental freedoms to sporting disciplinary measures and the requirement for effective judicial protection within sports justice systems.

The ECJ confirmed that disciplinary sanctions restricting individuals from carrying out professional activities within football governance structures may impede the free movement of workers and freedom to provide services across EU Member States. However, protecting clubs’ financial stability, ensuring reliable financial reporting, and maintaining the sustainability and competitive balance of sporting leagues can constitute legitimate public interest objectives justifying such restrictions. National courts must nevertheless assess whether sanctions are proportionate, consistently applied, and based on transparent, objective, and non-discriminatory criteria.

A central aspect of the judgment concerns the limits of sporting autonomy and the right to effective judicial protection under Articles 19 TEU and 47 of the EU Charter. The ECJ held that sports disciplinary and review bodies may provide the required judicial protection only if they satisfy strict requirements, including independence, impartiality, establishment by law, judicial functionality, procedural safeguards, and the ability to review all relevant factual and legal issues. Where these conditions are not met, national courts must retain the power to provide effective remedies, including interim relief and the suspension or annulment of unlawful sanctions, rather than being limited to awarding damages.

Finally, the authors explain that FIGC extends the principles established in International Skating Union and Royal Football Club Seraing from sports arbitration to internal sports disciplinary systems, while potentially requiring broader scrutiny of EU-law rights. Its implications may also extend beyond professional sports to other self-regulatory organizations, including bar associations, certification bodies, accreditation organizations, and industry associations exercising disciplinary or adjudicative powers…

CONTINUE READING…