Essential guidance for clubs on complying with UEFA stadium safety requirements: Analysing AZ Alkmaar v UEFA
The Court of Arbitration for Sport (CAS) in June 2025 handed down an arbitration award (Award) in a case between AZ Alkmaar and UEFA. The dispute arose out of the unsavoury incidents that took place immediately before and after AZ Alkmaar’s home UEFA Europa Conference League match with Legia Warszawa (Legia) on 5 October 2023.
In response, proceedings were brought against AZ Alkmaar before the UEFA Control Ethics and Disciplinary Body (CEDB). The AZ Alkmaar was fined €40,000. The AZ Alkmaar unsuccessfully appealed that decision to the UEFA Appeals Body. The AZ Alkmaar then appealed before CAS and it is that decision which is the focus of this article.
The Award can be found here[1].
This article analyses the CAS panel’s award which clarifies the boundaries of club liability under UEFA's disciplinary framework. It demonstrates how evidencing preparation and positive official feedback can overcome disciplinary findings and provides essential guidance for clubs navigating UEFA's safety and security obligations.
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- Tags: Dispute Resolution | Football | Governance | Health & Safety | Netherlands | Poland | Regulation | UEFA | UEFA Control Ethics and Disciplinary Body | UEFA Disciplinary Regulations | UEFA Europa Conference League | UEFA Safety and Security Regulations
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Written by
Edmund Gross
Ed practices from 5 Essex Chambers. Recently he has developed a growing Public Law practice which includes being instructed for the Home Office in the Undercover Policing Inquiry. Additionally, he is instructed in several matters that raise national security issues. In 2023 he was appointed to the Attorney General’s C Panel of Civil Counsel.
In terms of Sports work, Ed was appointed to the Football Association’s National Serious Case Panel in July 2023. Furthermore, he has been sitting on MCC Disciplinary Panels for several years. In July 2024 he was appointed as a Sports Resolutions Pro Bono Service Member
Ed has been instructed in a wide range of regulatory and disciplinary matters by the Rugby Football Union which includes issues relating to anti-doping.
Ed was instructed as part of a barrister and solicitor team by a national sport’s governing body who are exploring the implementation of a new governance structure.
