Ethics CasesSport

Cases · FIFA / FIFPRO / European Leagues · 2022–2026

Fixture Congestion and the Legal Fight Over Football's Calendar

As FIFA expanded the Club World Cup and the World Cup and UEFA enlarged its club competitions, players said they were playing too much. In June 2024, England's PFA and France's players' union filed a claim in a Brussels court challenging FIFA's power to set the calendar unilaterally. In October 2024, FIFPRO Europe, the European Leagues and LaLiga complained to the European Commission that FIFA was abusing a dominant position. FIFA said it had consulted and accused some leagues of hypocrisy. In June 2026, FIFA and FIFPRO signed a memorandum of understanding giving players a formal role in decisions on welfare and transfers, and FIFPRO agreed to withdraw its legal actions. The case asks who should decide how much athletes play, and whether litigation or negotiation better protects players.

By Tanner Simkins, editor

Timeline

  1. The FIFA Council confirms an expanded Club World Cup for 2025.
  2. The FIFA Council unanimously approves the 2025–2030 men's international match calendar and sets up a player-welfare task force.
  3. The PFA and France's UNFP file a claim at the Brussels court of commerce.
  4. FIFPRO Europe, the European Leagues and LaLiga file a complaint with the European Commission.
  5. The expanded Club World Cup is scheduled in the United States.
  6. FIFPRO's workload report finds Club World Cup finalists had one to two weeks of preseason.
  7. FIFA and FIFPRO sign a memorandum of understanding; FIFPRO withdraws its legal proceedings.
  8. Seventeen European unions withdraw support for a separate transfer-rules class action.
  9. European Leagues extends its EU complaint to the women's international match calendar.

The ethical issues

  • Player health and workload versus commercial expansion.
  • A governing body's conflict of interest as regulator and competition organizer.
  • Consultation and consent of workers in decisions about their work.
  • Unequal workload across elite and other players.
  • Litigation versus negotiation as tools of athlete advocacy.

Stakeholders

StakeholderInterests & obligations
PlayersHealth, rest and a voice in scheduling.
FIFAIts competitions, revenue and regulatory authority.
National leaguesProtecting domestic competitions and dates.
UEFAIts expanded club competitions.
ClubsRevenue and squad management.
Fans and broadcastersQuality and quantity of matches.

The case

By 2024, European club competitions had expanded to 36 teams, FIFA had confirmed an expanded Club World Cup for summer 2025, and the 2026 World Cup would follow a year later.[2] Players and leagues said the calendar had passed its limit and took legal action.[1][2]

Background

Players spoke out. Manchester City’s Rodri said players were close to striking; a FIFPRO report counted him in 72 matchday squads in a year. He then suffered a season-ending knee injury in September 2024.[2] Liverpool goalkeeper Alisson said, “Sometimes nobody asks the players what they think about adding more games.”[2]

In June 2024, the Professional Footballers’ Association (PFA) and France’s players’ union filed a claim at the Brussels court of commerce, challenging FIFA’s decisions to set the calendar unilaterally and to create the 2025 Club World Cup.[2] The PFA said the claim sought to enforce players’ rights to “guaranteed and protected breaks.” It asked the Brussels court to refer questions to the Court of Justice of the European Union on footballers’ rights under the EU Charter of Fundamental Rights, “including the right of players to take an annual period of paid leave.” The unions were represented by Jean-Louis Dupont, a member of the legal team in the 1995 Bosman ruling.[5]

How FIFA set the calendar

The calendar at the center of the dispute was approved on March 14, 2023, when the FIFA Council met in Kigali before FIFA’s Congress. FIFA said the men’s and women’s international match calendars were approved unanimously “following a detailed consultation process.”[11] For 2025 to 2030, the men’s calendar provides nine-day, two-match international windows in March, June and November. From 2026, a single 16-day, four-match window in late September and early October replaces separate September and October windows.[11] For the 2026 World Cup, the mandatory release period began on May 25, 2026, the day after the last official club match, and the final was set for July 19. FIFA said the 56 days of combined rest, release and tournament time were identical to the 2010, 2014 and 2018 World Cups.[11]

At the same meeting, the Council confirmed the access rules for the 32-team Club World Cup, to be played every four years from June 2025. It also approved a new annual intercontinental club competition from 2024 and a 2026 World Cup format of 12 groups of four, with a round of 32.[11] It set up a task force on player welfare “to ensure the smooth implementation of player welfare principles such as mandatory rest periods.” FIFA President Gianni Infantino said FIFA had considered “the perspectives of all key stakeholders” and wanted “meaningful football matches while protecting the well-being of the players and recognising that many regions need more competitive football.”[11]

The Brussels claim

FIFPRO Europe’s own account of the June 2024 claim sets out its legal theory. The unions asked the Brussels Court of Commerce to refer four questions to the EU Court of Justice.[12] The first asked whether workers’ rights in the EU Charter of Fundamental Rights barred FIFA from scheduling the Club World Cup in the period traditionally used for players’ annual break. Those rights include the ban on forced or compulsory labor, freedom to choose an occupation, collective bargaining and paid annual leave, set out in Articles 5, 15, 28 and 31. The second asked whether imposing such decisions unilaterally infringed players’ right to bargain collectively. The third asked whether the added workload violated the right to healthy working conditions. The fourth asked whether FIFA’s calendar decisions were “restrictions of competition” under Article 101 of the Treaty on the Functioning of the EU.[12] The unions said that, once preparation and travel were included, the Club World Cup could add “up to six weeks of additional work,” and that for the most in-demand players the right to a guaranteed annual break had become “virtually non-existent.”[12] FIFPRO Europe president David Terrier said that “since all attempts at dialogue have failed,” the unions would take the matter “to the European courts.”[12]

The rules and governance

On October 14, 2024, FIFPRO Europe and the European Leagues, representing 39 leagues and 1,130 clubs, joined by LaLiga, filed a complaint with the European Commission’s competition directorate.[1][2] They argued that FIFA’s dual role as governing body and competition organizer creates a conflict of interest, and that under the EU court’s Super League and Diarra rulings, FIFA must exercise its regulatory powers in a transparent, objective, non-discriminatory and proportionate way, including involving players and leagues.[1] Premier League CEO Richard Masters said, “It is getting to a tipping point.” Belgian Pro League CEO Lorin Parys said, “We just don’t want decisions taken about us without us.”[1]

The complaint drew on a series of EU rulings. In the Diarra case, decided on October 4, 2024, the Court of Justice ruled on a Belgian appeal court’s referral about FIFA’s player-transfer rules; FIFPRO, FIFPRO Europe and France’s players’ union had intervened.[7] FIFPRO Europe said the ruling found “central parts of FIFA’s player transfer rules are incompatible with European Union law,” and in February 2025 it said player unions believe FIFA’s calendar decisions “violate the rights of players under the EU Charter of Fundamental Rights while also potentially violating EU competition law.”[6]

FIFA said it had consulted FIFPRO and the World Leagues Association on the 2025–30 calendar, that it was “fully within our rights to set the parameters of our competitions,” and that some leagues “prefer a calendar filled with friendlies and summer tours.”[2] UEFA president Aleksander Ceferin agreed there was “no room for additional matches,” but said complaints came from the highest-paid players and the biggest clubs.[2] A CIES Football Observatory study found that average fixtures per club had stayed just over 40 per season between 2012 and 2024.[2]

The workload evidence

The two sides disagreed about how much congestion had actually grown. The CIES study cited by the BBC measured averages per club, while FIFPRO tracked individual players at the top of the game.[2][8] FIFPRO’s report on the 2024/25 season, published in September 2025 with Football Benchmark, used data on 1,500 men’s players and compared their rest with the recommendations of 70 medical and performance experts, who had agreed that players need 28 days of offseason and a further 28 days of preseason. It found that Chelsea players, after winning the expanded Club World Cup, had just 13 days of preseason, and Paris Saint-Germain players seven. Only 14 percent of the sampled Euro 2024 players had had the recommended offseason before the season. FIFPRO also noted that Lamine Yamal had played 130 games before turning 18. The report contrasted football with the NBA and Australia’s AFL, where players get 14 weeks off, and Major League Baseball, where they get 15. It also acknowledged that many players lower down the pyramid lack competitive games, while those at the elite level are “often overburdened.”[8]

Aftermath

On June 10, 2026, on the eve of the World Cup, FIFA and FIFPRO signed a memorandum of understanding running to 2031.[3] It created a Global Social Dialogue Platform, chaired by FIFA, with players, leagues and clubs as social partners. Future changes to transfer rules and player-welfare standards, including rest periods, will require collective agreement, and decisions on workload in FIFA competitions will follow “a structured collaborative process.”[3] FIFPRO gained seats on FIFA bodies and observer status on the FIFA Council for player matters, and committed to respect the international match calendar.[3] FIFPRO and its divisions withdrew all legal proceedings against FIFA and agreed to have member unions do the same.[3] In July, 17 European unions also withdrew support for a separate class action over transfer rules.[4]

The leagues did not settle. In August 2026, European Leagues said FIFA’s abandoned plan to sell stakes in its commercial activities and an assessment of a 64-team 2030 men’s World Cup, carried out “with zero consultation with the leagues, clubs and players,” showed the “systemic issues” behind its complaint. It said it would reject the expansion or creation of FIFA competitions until there was reform with “legally binding engagement” of stakeholders.[9] On September 8, 2026, it extended its complaint to the European Commission to cover FIFA’s women’s international match calendar, arguing that the same conflict of interest threatened women’s professional leagues and player health.[10] In that filing it said the Commission “must now act.”[10]

The core dilemma

Players bear the physical cost of more matches but had little formal say. Litigation created pressure, and FIFPRO traded it for an institutional voice. Who should decide the calendar, and is negotiation a better route than litigation?

Competing values

  • Player health vs. commercial growth.
  • Governing body authority vs. stakeholder consent.
  • Global competitions vs. domestic leagues.
  • Legal leverage vs. cooperative governance.

Strongest arguments

For the players and leagues: FIFA expanded competitions without meaningful consultation, while players bore the injury risk.

For FIFA: it consulted, has a duty to the global game, and leagues also add tours and friendlies. Workload data are mixed.

On the settlement: supporters see a breakthrough in player voice; skeptics may ask whether a FIFA-chaired platform will deliver real limits.

Applying the frameworks

Care ethics

A care lens focuses on duties to protect players’ bodies and well-being, especially those with the heaviest workloads.

Justice

A justice lens asks whether players have fair representation in decisions about their working conditions.

Utilitarianism

A utilitarian lens weighs revenue and fan benefits of more competitions against injury and quality costs.

Walk it through: the Simple Decision Model

  1. Spot the issue. You are a union leader weighing the FIFA agreement. Stakeholders include players, leagues and fans. Less visible are players outside the elite. The codes are EU law and FIFA statutes.
  2. Gather facts. What does the agreement guarantee? Beware trading leverage for promises without enforcement.
  3. Test options. (a) Continue litigation. (b) Sign and withdraw claims. (c) Sign with conditions and review points.
  4. Check codes and law. Check EU rulings and union mandates.
  5. Decide and document. Record the reasons and benchmarks.
  6. Communicate and follow up. Report to members and monitor implementation.

What’s settled and what’s contested

  • Settled: the 2024 legal actions, FIFA’s response and the 2026 agreement.
  • Contested: whether the platform will reduce workloads; the status of the leagues’ complaint; how much congestion has actually increased.

Why this case matters

The calendar fight shows how athletes can use law and collective action to gain a voice in governance, and the trade-offs involved.

See also: Playing Through the Heat: The 2025 Club World Cup.

Key terms

Duty of care
The responsibility of coaches, organizations and institutions to protect the health, safety and well-being of those in their charge. It is not a license for total control.
Conflict of interest
A situation where a person’s private interest could improperly influence a decision they make in an official role.
Commercialization
The process of turning sport into a product and a business enterprise, with profit pressures that can compete with principle.
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.
Agency
An athlete’s ability to make decisions and act independently about their body, career and voice.

Definitions from the Ethics Cases glossary.

Discussion questions

  1. Who should decide how many matches players play: FIFA, leagues, clubs or players?
  2. FIFA accused leagues of filling the calendar with tours and friendlies. Does that weaken the leagues' complaint?
  3. UEFA's president said complaints come from the highest-paid players. Does that matter ethically?
  4. Was FIFPRO right to withdraw legal actions in exchange for a governance role?

Sources

  1. Player unions and leagues file complaint to European Commission over FIFA's imposition of international match calendar — FIFPRO
  2. Legal complaint filed against Fifa's 'abuse of dominance' — BBC Sport
  3. FIFA and FIFPRO sign landmark agreement to usher in new era of collaboration and player representation in global football governance — FIFPRO
  4. FIFPRO Europe: Statement (9 July 2026) — FIFPRO
  5. PFA joins legal case against FIFA (June 13, 2024) — Professional Footballers' Association
  6. FIFPRO Europe board discuss ongoing action around International Match Calendar, transfer system reform (Feb. 2025) — FIFPRO
  7. FIFA v BZ (Diarra), Case C-650/22, Judgment of the Court (Oct. 4, 2024) — Court of Justice of the European Union (CURIA)
  8. Overworked and Underprotected: New FIFPRO player workload report outlines continuing threats to player health and performance (Sept. 29, 2025) — FIFPRO
  9. European Leagues Statement on FIFA Developments (Aug. 5, 2026) — European Leagues
  10. European Leagues extends European Commission complaint over FIFA's imposition of the International Match Calendar to women's football (Sept. 8, 2026) — European Leagues
  11. FIFA Council approves international match calendars (Mar. 14, 2023) — FIFA
  12. FIFPRO Europe Statement: Legal claim against FIFA (June 13, 2024) — FIFPRO