From Riyadh to London: A Comparative Guide to Sports Arbitration in Saudi Arabia and England & Wales

This article^[1] considers how the Kingdom of Saudi Arabia (the Kingdom) is building its own sports arbitration framework, and what that framework does, and does not, share with the more mature English model.

The Kingdom’s increasing participation in the international sports economy has generated substantial legal and regulatory demands. The expansion of professional sports governance, foreign investment, athlete transfers, sponsorship arrangements, shifted the focus on the need for a modern and specialized legal framework capable of resolving sports disputes efficiently and consistently with international standards. The most concrete recent sign of that focus is the Kingdom’s enactment, in December 2025, of the Saudi Sports Law (Royal Decree No. (121)). The Law gives statutory footing to the Saudi Sports Arbitration Center (SSAC) which was first authorised in 2015 by the Saudi Arabian Olympic committee (SAOC) and was later formally established in Riyadh in 2016, creating, for the first time, a single specialised forum for the resolution of sports disputes within the Kingdom. 

Its adoption is no accident.  Over the last decade, the Kingdom has become one of the most active investors in global sport — in football (the Public Investment Fund led investment group’s ownership of Newcastle United^[2] and its investment into four of the top clubs of the Saudi Pro League^[3]), in motorsport (the Formula 1 Saudi Arabian Grand Prix and Aston Martin)^[4], and in boxing, tennis and esports — and the practical consequence of that investment is a sharp rise in disputes connected with the Kingdom which, in turn, requires a serious domestic forum to resolve them.

That makes the SSAC worth understanding in its own right.  It also makes the comparison with England & Wales — whose statutory and institutional framework for arbitration has had two centuries to mature — instructive.  This article considers the Saudi framework first, before turning to the more developed English model and then identifying where the two regimes converge and where they diverge.

This article looks at:

• Sports Arbitration in the Kingdom of Saudi Arabia
• The Saudi Sports Arbitration Center (SSAC)
  • Primary Forum for Domestic Sports Disputes
  • Limited Recourse to State Courts
  • Finality of Awards
• Institutional Structure of the SSAC
• The Court of Arbitration for Sport (CAS)
• Interaction Between SSAC and CAS
  • Purely Domestic Disputes
  • Appeals Involving International Federations
  • Contractual International Arbitration Clauses
• Jurisdictional Perspective: Domestic and International Levels
• Enforcement of Arbitral Awards
• Public Policy Considerations
• Sports Arbitration in England & Wales
• Convergences and Divergences between the Two Frameworks