In football, as in many other sports, the submission of disputes to arbitration, particularly those that may arise between a football club and FIFA, is imposed unilaterally by the FIFA Statutes. On 1 August 2025 (Case C-600/23), the CJEU issued an important ruling in which, without calling into question the mandatory use of arbitration, it ruled that in order to guarantee effective judicial protection for clubs and athletes, arbitral awards rendered by the Court of Arbitration for Sport (CAS) must be subject to effective judicial review by the courts of the Member States of the European Union.
The Facts of the Main Proceedings
These particularly complex facts, as well as the proceedings leading up to the judgment of the Court of Justice of the European Union of 1 August 2025,[1] are worth recalling so that readers can fully understand the meaning and scope of that judgment.
In 2015, a Belgian football club, Royal Football Club Seraing (RFC Seraing), which was playing in the Belgian Amateur First Division, entered into financing agreements with the Maltese company Doyen Sports Investment Ltd, which provided, in particular, for the transfer to the latter a part of RFC Seraing’s “economic rights” over several specified players.
These agreements provided for the conclusion of specific future financing...
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