
Introduction
Advocate General (AG) Nicholas Emiliou recently delivered three landmark Opinions (15 May 2025) addressing the application of EU Law - in particular, Article 101 of the Treaty on the Functioning of the European Union (TFEU) - to regulations in professional football. These Opinions, in Cases C‑209/23 RRC Sports, C‑428/23 ROGON, and C‑133/24 CD Tondela, all concern the tension between sporting bodies’ self-regulation and EU competition rules.
The first two cases involve challenges to rules governing football agents (intermediaries) at the international level (FIFA Football Agent Regulations - FFAR) and the national level (the
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