Who gets to decide when football is played is not only relevant for fans, but for clubs and players alike. Last month, European Leagues, which represents professional domestic leagues across Europe, announced that it had extended its existing antitrust complaint against FIFA before the European Commission. The complaint now also covers FIFA´s alleged conduct concerning the women´s international match calendar and related competitions. At its core lies a familiar antitrust question: What safeguards are required when a sports governing body does both – regulating the market and organising competitions of its own?
The new submission is an extension of the previous complaint filed in October 2024 by European Leagues, FIFPRO Europe, and LaLiga in relation to the men´s international match calendar, including the FIFA Club World Cup 2025 and FIFA World Cup 2026. The additional complaint outlines that FIFA´s alleged conduct also concerns the women´s international match calendar and related women´s football competitions. So far, there seem to be no public statements on how the Commission has dealt (or is currently dealing) with the 2024 complaint.
The legal background behind the complaint
In essence, the complainants argue that FIFA is not merely setting the rules of the game. It is also deciding how one of football´s scarcest resources, calendar space, is allocated. The complainants allege that FIFA has a conflict of interest, arising from its dual role as both governing body and competition organiser.
According to the complaint, FIFA has used its regulatory powers to shape the international match calendar in a way that favours its own competitions and commercial interests, while failing to meaningfully involve domestic leagues and player representatives in the decision-making process. In their view, FIFA´s unilateral approach to calendar planning does not only affect players´ welfare and the viability of domestic competitions but also amounts to an abuse of its dominant position under EU competition law. The complainants state that given its conflict of interest, FIFA “must exercise its regulatory function in a way that is transparent, objective, non-discriminatory and proportionate so as to neutralise this conflict of interest”.
Sounds familiar?
The same conflict is at the heart of the European Court of Justice´s (ECJ) Super League judgment. A quick reminder: Not so long ago, several football clubs announced the launch of a European Super League, which FIFA and its European counterpart UEFA were quick to prohibit (we already highlighted the case here). The case made its way to the ECJ, which proceeded on the basis that FIFA and UEFA occupy a dominant position, or even a monopoly, in the relevant market of the organisation and marketing of international football competitions and the exploitation of the various rights related to those competitions.
In addition, the ECJ decided on FIFA and UEFA´s prior approval and participation rules of interclub competitions and the exploitation of rights emanating from such competitions. The court held that rules granting FIFA and UEFA the power to approve competing competitions and impose sanctions require a framework based on “transparent, objective, precise, non-discriminatory and proportionate” criteria and detailed procedural rules. In the absence of such safeguards, those rules may infringe Article 102 TFEU. In practical terms, this meant that FIFA and UEFA could not rely on their existing approval system to block the Super League, but it did not mean that the Super League itself had been approved.
The present complaint(s) however concern a different exercise of regulatory power. Super League dealt with the prior approval of rival competitions and the threat of sanctions; the current complaint challenges how FIFA allocates limited calendar space while expanding and scheduling their own competitions. The Super League judgment therefore does not determine the outcome. It does, however, explain why the complainants focus on the process. The common concern is self-preferencing: A governing body with commercial interests can shape the conditions under which its rivals compete. A “transparent, objective, precise, non-discriminatory and proportionate” process, if it exists and is properly applied, can act as a safeguard to constraining FIFA´s discretion.
According to a news agency, FIFA rejected the allegations, claiming that “The four-year women´s International Match Calendar was backed by extensive research, analysis and consultation with key stakeholders, including with European and global leagues, with the impact on players at the heart of its design”.
A new dimension to the dispute
The extension to women´s football gives the dispute an additional economic dimension. Professional women´s football has grown rapidly in the last years, but it remains a much newer market and many domestic competitions are at an earlier stage of commercial development than their counterparts in the men´s game. Calendar decisions can affect the availability of leading players, audience growth, sponsorship and broadcasting value. As a result of the reliance of the women´s game on such factors, FIFA´s regulatory decisions might not only determine how the market may develop, but if it develops any further at all.
What´s next?
A complaint to the Commission does not automatically mean that formal proceedings will be opened, let alone an infringement found. Should the Commission decide to take the case forward, the key issue may be less whether FIFA can coordinate the calendar in principle, but rather how it exercises that power in practice (similar to the Super League decision). The case could therefore (potentially) test how far the logic of the Super League decision can be extended beyond formal approval rules to the day-to-day governance of the football market. Recent judgments in Diarra (read more about it here) or the FIFA Agents case emphasize that FIFA´s regulatory choices are not immune from scrutiny under EU law and that football governance is increasingly being assessed through the lens of competition law.
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