How far can sports bodies discipline their members? The CJEU's ruling in FIGC and CONI (Part 1)
The[1] judgment of the Court of Justice of the European Union (CJEU) in ZD v Federazione Italiana Giuoco Calcio (FIGC) and Others (FIGC and CONI) lays down important principles and constraints for the compliance of sports justice with EU law.
The case concerns sanctions imposed by Italian sports bodies on two directors of Juventus Football Club (Juventus) for breach of the principles of honesty, fairness and integrity which they had to observe pursuant to the rules of the Italian Football Federation (FIGC).
The CJEU held that any sanctions imposed on individuals must comply with Articles 45 and 56 of the Treaty on the Functioning of the European Union (TFEU), on free movement of workers and freedom to provide services, respectively. Furthermore, Article 19(1) of the Treaty on European Union (TEU) and Article 47 of the Charter of Fundamental Rights of the European Union (Charter) require that an effective remedy must be provided for breaches of EU law in a fair trial before an independent and impartial tribunal previously established by law.
The judgment will have significant implications for the way in which sports associations structure their enforcement regime and the standard of review of national courts of decisions by sports associations.
This is the first of a two-part article. Part 1 addresses the first issue the Court decided: whether, and on what conditions, Articles 45 and 56 TFEU permit a national sports association to impose disciplinary sanctions that restrict a director’s professional activities.
Part 2 (see here) turns to the second issue: whether the limited judicial review available under Italian law satisfies the principle of effective judicial protection under Article 19(1) TEU and Article 47 of the Charter.
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- Tags: Charter of Fundamental Rights of the European Union | Court of Justice of European Union | European Union | Italy | Treaty of Functioning of the European Union (TFEU) | Treaty on European Union (TEU)
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Written by
Renato Nazzini KC
Renato is a barrister at Monckton Chambers and professor of competition law at King’s College London. In 2025, he was appointed King’s Counsel (Hon) for his major contribution to English law.
He is also qualified as an Italian advocate. He is an expert in competition law and arbitration, acting as counsel and arbitrator in competition, commercial and sports disputes. He has particular expertise in sports disputes involving a competition or EU law dimension, as well as disputes arising from significant commercial sports-related contracts. Renato benefits from having worked for eight years at the UK competition authority where he advised on investigations, appeals, mergers and policy work across all industry sectors.
As an arbitrator, Renato has served as sole arbitrator, tribunal chair or president, co-arbitrator, and emergency arbitrator. Renato has published widely on competition enforcement, abuse of dominance and arbitration. He has been a visiting professor at the University of Turin, the University of Zurich, and FGV School of Law, São Paulo, Brazil. He holds doctorates from the University of Milan and the University of London. He is a Fellow of the Chartered Institute of Arbitrators.
