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Cases · FIFA · 2015–2026

Counting to Three: Infantino and FIFA's Presidential Term Limit

After the 2015 corruption crisis, FIFA's Reform Committee recommended limiting the president to three four-year terms. Gianni Infantino, a member of that committee, was elected at an Extraordinary Congress in 2016 and re-elected in 2019 and 2023. In December 2022, the FIFA Council endorsed a committee view that his 2016–2019 period did not count as a term, allowing him to seek re-election in 2027 and potentially serve until 2031. No written reasoning was published. In 2026, an accountability group asked FIFA's Review Committee to rule him ineligible, as several national associations withdrew their support. The case asks whether term limits mean anything if they can be reinterpreted.

By Tanner Simkins, editor

Timeline

  1. The 2016 FIFA Reform Committee, with Gianni Infantino among its members, recommends a limit of three four-year terms, a maximum of 12 years, for the president.
  2. Infantino is elected FIFA president at an Extraordinary Congress in Zurich.
  3. Infantino is re-elected unopposed.
  4. The FIFA Council unanimously agrees with the Governance, Audit & Compliance Committee that 2016–2019 does not count as a term of office.
  5. Infantino is re-elected unopposed for what FIFA treats as his second term.
  6. Infantino tells the 76th FIFA Congress in Vancouver he will stand again in 2027.
  7. FairSquare asks FIFA's Review Committee to rule Infantino ineligible, arguing a 2027 win would be a fourth term.
  8. The Scottish FA says it will not vote for Infantino, joining England, Wales and the Republic of Ireland amid controversy over an abandoned commercial spin-off.
  9. The FIFA Council sets up a working group to examine FIFA's governance framework; no eligibility ruling has been announced.
  10. UEFA writes to FIFA's general secretary questioning the independence of the chair of the committees that check candidates' eligibility.

The ethical issues

  • Whether a term limit should be read by its words, its purpose or the interpretation of those in power.
  • Who has authority to interpret a governance rule that affects the sitting president.
  • The lack of published reasoning for a decision that benefits the incumbent.
  • Whether incomplete terms should count toward a limit.
  • The role of term limits in preventing the concentration of power after a corruption scandal.

Stakeholders

StakeholderInterests & obligations
Gianni InfantinoEligibility to seek another term and a fair reading of the rules.
FIFA member associationsClear rules and the ability to choose their leader.
ConfederationsAccountable leadership and influence over FIFA's direction.
FIFA's Governance, Audit & Compliance and Review CommitteesIndependence and credibility in applying the statutes.
Players, fans and sponsorsA governing body they can trust.
Governance watchdogsEnsuring post-scandal reforms are respected.

The case

Term limits are one of the simplest tools for keeping power in check. After the corruption scandal that ended Sepp Blatter’s 17-year presidency, FIFA adopted one: no president may serve more than three terms. Gianni Infantino, elected in 2016, has now been elected three times. In 2022, the FIFA Council agreed that his first stint did not count. If he wins again in 2027, he could lead FIFA until 2031, a total of 15 years. The case asks whether a term limit still means anything if those it binds can reinterpret it.

Background

In December 2015, with FIFA in what its own Reform Committee called “the worst crisis of its history,” the committee proposed changes “to prevent corruption, fraud, self-dealing and to make the organisation more transparent and accountable.”[1] Among them: the president should serve “no more than three terms of four years (whether consecutive or not) for a maximum of 12 years.”[1] The committee’s members, drawn from the six confederations, included Infantino as a UEFA representative.[1]

On February 26, 2016, an Extraordinary Congress in Zurich did two things. First, 179 of the 207 member associations present and eligible to vote approved the reform package, including term limits, which was then written into amended statutes. Second, it elected Infantino as FIFA’s ninth president. He led Sheikh Salman Bin Ebrahim Al Khalifa by 88 votes to 85 on the first ballot and won the second ballot with 115 votes to 88. FIFA’s own record states that he “was elected as the President of FIFA for the remainder of the current term of office (until 2019)” and that, “in line with the FIFA Statutes, the mandate of the new FIFA President started after the conclusion of the Congress.”[11][5] The term he completed had originally been won by Blatter. Inside the Games reported that his first stint lasted about 39 months.[3] He was re-elected unopposed in 2019 and again in 2023.[6] When he was re-elected by acclamation at the 73rd Congress in Kigali on March 16, 2023, FIFA announced that he would “serve a second term” running “from 2023 to 2027.”[12]

The rules and governance

FIFA’s statutes now provide, in the opening sentences of Article 33(2):[4]

“The President shall be elected by the Congress for a period of four years in the year following a FIFA World Cup™. The term of office shall begin after the end of the Congress at which the President was elected. No person may serve as President for more than three terms of office (whether consecutive or not).”

The statutes recognize both ordinary and extraordinary congresses, and the Council may convene an extraordinary congress at any time.[4] Candidates for the presidency must pass an eligibility check by the Review Committee, part of FIFA’s Governance, Audit & Compliance Committee.[7]

The 2022 decision

On December 16, 2022, the FIFA Council met in Doha during the men’s World Cup. Near the end of a long press release about budgets, tournaments and agent regulations, FIFA stated: “The FIFA Council also unanimously confirmed its agreement with the view of the Governance, Audit & Compliance Committee that the period between 2016 and 2019 does not count as a term of office for the current FIFA President, who is therefore about to end his first term.”[2]

Inside the Games noted that it “had been previously understood” that the 39 months from 2016 to 2019 were Infantino’s first term. The change, it said, “frees up the Swiss-Italian official to lead FIFA until 2031 - a 15-year reign, despite the supposed limit of three four-year terms.”[3] ESPN later summarized FIFA’s position: “His first three years did not count as he was finishing the term of the ousted Blatter.”[6]

FairSquare, a group that later challenged the decision, says the Council agenda referred to a committee report “and on the decisions taken by correspondence,” but that it has been unable to find that report or any published reasoning.[7]

The 2026 challenge

On April 30, 2026, at the FIFA Congress in Vancouver, Infantino announced: “I will be (a) candidate for the election of FIFA President next year.”[5] The election is due at the 77th FIFA Congress in Rabat, Morocco, which FIFA has scheduled for March 2027.[6][10] ESPN reported that if re-elected, Infantino would then reach the 12-year limit as FIFA counts it.[6]

On August 13, 2026, FairSquare wrote to the three members of the Review Committee asking them to rule Infantino ineligible. Its letter, drafted with help from Professor Miguel Maduro, a former head of FIFA’s Governance Committee, made three main arguments:[7][8]

  • The text: the statutes make no exception for incomplete terms or for terms won at an extraordinary congress. The rule is that “no person may serve as President for more than three terms of office.”
  • The purpose: the Reform Committee intended a maximum of 12 years. An interpretation that counts only full four-year terms would let a president use the Council’s power to call early elections “to remain in power indefinitely.”
  • The procedure: the Council “has no competence to decide on the eligibility of candidates or to issue any binding interpretation of the Statutes.” Only the Congress can change the limit.

FairSquare urged that “any exception to a rule aimed at restraining executive power should be considered with extreme caution and, in principle, discarded.”[7]

Aftermath

The challenge arrived amid a wider crisis. BBC Sport reported that Infantino faced pressure over an abandoned plan to move FIFA’s commercial rights into a new company and sell a 21 percent stake to a private investor. The Football Associations of England, Wales, the Republic of Ireland and Scotland said they would not vote for him, while the confederations of Africa, South America and Oceania backed him.[9] BBC Sport reported that, at the time, no rival candidate had come forward before a November 18 deadline.[9]

At its October 15, 2026, meeting, the FIFA Council agreed to create a working group “to examine in detail FIFA’s governance framework,” and Infantino apologized for “mistakes made” over the commercial proposal.[10] FIFA’s statement did not mention term limits or the Review Committee.[10] Inside World Football reported on October 21, 2026, that UEFA had written to FIFA’s general secretary, Mattias Grafström, raising concerns about the election process. The letter questioned the independence of Bruno Chiomento, who chairs the Governance, Audit & Compliance Committee and the Review Committee that checks candidates’ eligibility. UEFA said it understood that Chiomento had known Infantino for about 20 years and had attended the 2026 World Cup with his expenses paid by FIFA, and it asked whether he would recuse himself for the presidential election. UEFA also asked how Grafström’s public declaration of support for Infantino could be reconciled with the administration’s “duty of neutrality.”[13] As of October 21, 2026, the sources reviewed for this case show no public ruling on Infantino’s eligibility and no published response from FIFA to UEFA’s questions.

The core dilemma

FIFA’s term limit is short and seems clear. But it does not say whether a partial term counts, and FIFA’s leadership read that silence in the incumbent’s favor, without published reasoning and with the endorsement of a Council that works closely with him. The dilemma is whether a rule designed to limit power should be read by its words, by its purpose or by the interpretation of the body it binds, and who should decide when the answer benefits the person in office.

Competing values

  • Letter vs. purpose: the words “three terms of office” can be read in more than one way, but the Reform Committee’s stated aim was a 12-year maximum.
  • Democratic choice vs. constitutional limits: member associations can re-elect a leader, but term limits exist to constrain even popular leaders.
  • Institutional deference vs. independent review: FIFA bodies have authority to interpret statutes, but bodies close to the president may lack independence.
  • Transparency vs. confidentiality: internal deliberations may be private, but decisions that benefit the incumbent need public reasons.
  • Stability vs. renewal: continuity can help an organization, but long tenures risk the problems the reforms targeted.

Strongest arguments

For FIFA’s interpretation: Infantino completed a term that Blatter had won, and the statutes describe presidential terms of four years beginning after an election in the year after a World Cup.[3][4][6] Treating an interim period differently from a full term is a familiar idea in many organizations. The Governance, Audit & Compliance Committee is the body with expertise, and the Council endorsed its view unanimously.[2] Member associations remain free to vote for or against him.[9]

Against it: The statute’s words make no exception for partial terms or extraordinary congresses.[4][7] The Reform Committee, on which Infantino sat, set an explicit 12-year maximum.[1] The interpretation allows a 15-year presidency, close to Blatter’s 17 years.[3][7] No reasoning was published, and the Council’s involvement raises questions about independence.[7][8] If partial terms do not count, a president could arrange early elections to restart the clock.[7]

Applying the frameworks

Kantian (duty)

Kant asks whether a principle could be universalized. “Rules limiting power may be reinterpreted by the powerful when it benefits them” would destroy the point of having such rules. The Kantian also stresses consistency: if FIFA would count a partial term against a council member or a rival, it should count one against the president. Acting on a rule only when it is convenient fails the test.

Justice & fairness (Rawls)

Behind a veil of ignorance, not knowing whether you would be the incumbent, a challenger, a small member association or a fan, you would want term limits interpreted by an independent body using public reasons. You would not want the incumbent’s allies to decide in private. Rawls’s emphasis on fair procedures supports referring a contested exception to the Congress, where all member associations vote.

Virtue ethics

Virtue ethics asks what a leader of good character would do. Infantino helped recommend the 12-year limit. A leader committed to the integrity of post-scandal reforms might decline an interpretation that extends his own tenure, or at least seek a transparent ruling from the Congress. Integrity means honoring the purpose of rules, especially those meant to restrain oneself.

Walk it through: the Simple Decision Model

  1. Spot the issue: A term limit was interpreted to exclude the incumbent’s first period in office, allowing up to 15 years in office.
  2. Gather facts: The statute’s text, the Reform Committee’s intent, the 2022 committee report and reasoning, how FIFA has treated partial terms for other officials, and who took part in the decision.
  3. Test options: Keep the 2022 interpretation; have the Review Committee rule afresh with published reasons; put the question to the Congress; amend the statutes to address partial terms explicitly.
  4. Check codes and law: FIFA Statutes Article 33(2), the eligibility check rules and Swiss association law.
  5. Decide and document: Any ruling should be made by an independent body and published with full reasoning.
  6. Communicate and follow up: Explain the decision to member associations and the public, and clarify the statutes for the future.

What’s settled and what’s contested

  • Settled: FIFA’s statutes limit the president to three terms; the Reform Committee recommended a 12-year maximum; Infantino was elected in 2016 and re-elected in 2019 and 2023; in 2022 the Council agreed his 2016–2019 period did not count; he has announced he will stand in 2027.[1][2][4][5][6]
  • Contested: whether the 2022 interpretation is correct; whether the Council had authority to endorse it; whether the Review Committee will revisit it; whether the 2027 election will go ahead with Infantino as a candidate.

Why this case matters

Term limits appear in the governance codes of many sports bodies, often introduced after scandals. The FIFA case shows that the details matter: how partial terms are counted, who interprets the rule and whether reasoning is published. A limit that can be quietly reinterpreted by the people it binds may offer little protection when it is most needed.

See also: Selling a Stake in the World Cup? FIFA Forward Enterprise and UEFA’s Legal Fight.

Key terms

Institutional accountability
Structures that make a sport organization explain its decisions and face consequences: clear authority, transparency, appeals, independent oversight and enforcement.
Rules vs. spirit of the game
Rules are the written minimum; the spirit is the fairness and respect the rules exist to protect. Rules set the floor; spirit sets the ceiling.
Conflict of interest
A situation where a person’s private interest could improperly influence a decision they make in an official role.
Trust
The public’s belief that what they are watching is real. Integrity failures are ultimately failures of trust.
Legal but unethical
Law sets out what can be punished; ethics asks what is right. Compliance is a minimum, so an action can be lawful and still wrong.
Stakeholders
Everyone with something at stake in a decision: athletes, coaches, parents, officials, fans, employees, sponsors, media, communities and regulators, including the less visible ones.

Definitions from the Ethics Cases glossary.

Discussion questions

  1. FIFA's statutes say no one may serve 'more than three terms of office (whether consecutive or not).' Does an incomplete term count? What evidence would you use to decide?
  2. Infantino served on the Reform Committee that recommended a 12-year maximum. Does that make the 2022 interpretation more troubling?
  3. Should the FIFA Council, whose members work closely with the president, have endorsed a ruling on the president's eligibility?
  4. FIFA has not published reasoning for the 2022 decision. How much does that affect its legitimacy?
  5. If most member associations want to re-elect Infantino, should a term limit stand in their way?

Sources

  1. 2016 FIFA Reform Committee Report (December 2, 2015) — FIFA (via Sports Integrity Initiative)
  2. FIFA World Cup 2022 praised for its 'unique cohesive power' — FIFA
  3. Infantino could lead FIFA until 2031 as Council says first 39 months did not count towards term limits — Inside the Games
  4. FIFA Legal Handbook 2025 (FIFA Statutes, 2024 edition) — FIFA
  5. FIFA President Gianni Infantino tells 76th FIFA Congress he will stand for re-election in 2027 — FIFA
  6. Gianni Infantino confirms re-election bid for FIFA president — ESPN
  7. Letter to FIFA Governance Review Committee, 13 August 2026 — FairSquare
  8. FairSquare calls on FIFA committee to declare Infantino ineligible to run again for presidency — FairSquare
  9. Scottish FA withdraws support for Fifa president Infantino — BBC Sport
  10. FIFA President calls for unity at Council meeting and stresses commitment to serving FIFA Member Associations — FIFA
  11. Extraordinary FIFA Congress, Zurich 2016 — FIFA
  12. FIFA President Gianni Infantino re-elected by acclamation at historic FIFA Congress — FIFA
  13. UEFA question independence of Chiomento and Grafström and whether Infantino's re-election is already rigged — Inside World Football