Regulating the Regulators: Competition Law Takes on FIFA’s Agent Rules

On 15 May 2025, Advocate General (“AG”) Nicholas Emiliou delivered his much-anticipated Opinions in RRC Sports v FIFA[1] and ROGON v DFB[2], two cases concerning FIFA’s Football Agent Regulations (“FFAR”) that go to the heart of how sports bodies regulate economic actors under EU competition law.
These Opinions revisit foundational principles — including the Meca-Medina[3] test — and raise fresh questions about the scope of sporting autonomy, the burden of justification for agent-related rules, and the coherence of competition enforcement across jurisdictions. With the Court of Justice of the European Union (“CJEU”) expected to deliver its ruling in the coming months, the AG’s Opinions provide critical guidance on how far sports governing bodies (“SGBs”) can go in regulating commercial actors such as agents.
This article explores the AG’s legal reasoning and considers the implications for sports federations, agents, and the future of sports governance.
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- Tags: Court of Justice of the European Union (CJEU) | Dispute Resolution | FIFA | FIFA Football Agent Regulations | Football | Regulation | The Football Association (The FA) | United Kingdom (UK)
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Written by
Anand Patel
Partner, Level
Anand is a competition/antitrust and regulatory specialist with significant experience advising on competition law and compliance issues, the drafting of rules and regulations, and disputes.
Anand's clients include sports governing bodies, international federations, player associations, clubs, teams, agents and executives. He has a wealth of experience advising sports bodies and stakeholders on competition law issues and the drafting of rules, regulations and policies, and has worked across a range of sports, including football, tennis, cricket, rugby, boxing, motorsport and sailing.