Cases · Liga MX · 2020–2026
Closing the Gate: Liga MX, Promotion and Relegation, and Antitrust
In April 2020 the Mexican Football Federation (FMF) suspended promotion and relegation between Liga MX and the second division for six seasons, as part of a rescue package for financially struggling second-tier clubs that included annual subsidies of 20 million pesos per club. Second-division clubs twice lost at the Court of Arbitration for Sport (CAS), which in 2025 held that the suspension ran through 2025–26. Then the 2026–27 regulations kept the top flight closed, Liga MX dropped the fines it had imposed on its lowest-ranked clubs, and the subsidy fund ended. In September 2026 Mexico's antitrust commission opened an investigation into access to professional football competitions, and a Senate bill proposed making promotion and relegation mandatory. The case asks whether a closed league is a legitimate business model or an unfair barrier to entry.
Timeline
- The FMF Executive Committee approves a rescue plan for the second division, and the FMF General Assembly unanimously suspends promotion and relegation for six seasons.
- CAS dismisses an appeal by three second-division clubs against the suspension.
- COFECE fines 17 Liga MX clubs, the FMF and eight individuals 177.6 million pesos for a women's salary cap and a no-poach 'gentlemen's pact'.
- The FMF confirms the suspension remains in force for 2025–26.
- CAS dismisses an appeal by six Liga de Expansión clubs seeking immediate reinstatement.
- The Liga MX 2026–27 competition regulations are published, with no promotion or relegation and no fines for the lowest-ranked clubs.
- Mexico's National Antimonopoly Commission opens an investigation into access to professional football competitions.
- A Senate bill proposes making promotion and relegation mandatory.
- Scheduled date of a CAS hearing on a new appeal by five Expansión clubs.
The ethical issues
- Whether a closed league is a legitimate business model or an unfair barrier to entry.
- Sporting merit versus investor stability.
- Whether rescue subsidies tied to a temporary suspension created obligations once the period ended.
- Multi-club ownership and conflicts of interest in league governance.
- The role of competition law and legislators in regulating sport.
Stakeholders
| Stakeholder | Interests & obligations |
|---|---|
| Liga MX club owners | Protecting their investments and revenues from the risk of relegation. |
| Liga de Expansión clubs | The chance to earn promotion and access top-flight revenue. |
| Mexican Football Federation (FMF) | Governing the sport and balancing members' interests. |
| Fans | Meaningful competition at both ends of the table and opportunities for their clubs. |
| Players | Career opportunities and fair labor markets. |
| Regulators and legislators | Competitive markets and public interest in sport. |
The case
Background
In most of the world’s football, a club can rise from the lower divisions to the top flight by winning on the field. Mexico used that system for decades. The last relegation from Liga MX took place at the end of the Clausura 2019 tournament.[7] In 2020, amid the financial distress of second-division clubs and the COVID-19 pandemic, Mexican football suspended promotion and relegation for six seasons.[1][7] When the six seasons ended, the top division did not reopen. The case raises a basic question: is a closed league a legitimate business model or an unfair barrier to entry?
The rules and governance
Under the FMF’s structure, the format of Mexico’s professional competitions is set through decisions of the federation’s Executive Committee and General Assembly, and the FMF’s statutes allow appeals against its decisions to CAS. The CAS panel described the relationship between the federation and its members as an associative contract governed by statutes and regulations the members have voluntarily accepted.[1] Between January and April 2020, the clubs of the second division, then called Ascenso MX, met with Liga MX clubs to discuss the second division’s financial difficulties.[1] On April 24, 2020, the FMF Executive Committee approved a rescue plan. It ended the 2019–20 second-division season, created a new league (now the Liga de Expansión MX) operating under rules “for a period of six seasons,” required its clubs to pool commercial and television rights, and limited the share of support money that could go to payroll to 50 percent.[1]
The plan included 60 million pesos split equally among the 12 existing second-division clubs and 240 million pesos a year for the following six seasons, 20 million pesos per club per year. That money was to come from fines on the Liga MX clubs finishing last, second-to-last and third-to-last in the coefficient table, a three-season points-per-game ranking: 120 million, 70 million and 50 million pesos respectively.[1] The same day, the FMF General Assembly voted unanimously to “temporarily suspend, for six seasons, promotion and relegation in Liga MX” and the second division (translated).[1]
FMF president Yon de Luisa later said he had discussed the plan with FIFA president Gianni Infantino, who was supportive. De Luisa said FIFA expected that “in the medium and long term we have to return to normal with promotion and relegation,” and that multi-club ownership “is not well regarded” (translated).[9]
The first challenges
Three second-division clubs appealed to CAS in May 2020. CAS dismissed the appeal on November 19, 2020, and confirmed the General Assembly’s decision.[1]
Separately, in September 2021 Mexico’s competition authority, COFECE, fined 17 Liga MX clubs, the FMF and eight individuals a combined 177.6 million pesos. It found the clubs had colluded to cap women players’ salaries from 2016 to 2019 and had operated a “gentlemen’s pact” from 2008 to 2018 that prevented male players from freely negotiating with new clubs when their contracts expired.[4] That case did not concern promotion and relegation, but it showed that competition law could reach the decisions of Mexican clubs and the federation.
The 2025 appeal
In March 2025, Expansión clubs asked the FMF to restore promotion and relegation for 2025–26. On April 29, 2025, the FMF said the suspension remained in force for that season.[1][2] Ten clubs appealed; four later withdrew, leaving Atlético La Paz, Atlético Morelia, Cancún FC, Mineros de Zacatecas, Venados and Leones Negros de la UdeG.[2]
The clubs argued that the suspension had begun with the 2019–20 season and so had expired, and that continuing it violated the principle of sporting merit. They also argued that the model breached Mexico’s constitutional ban on monopolies and its competition law by reserving the most profitable market to a closed group of clubs, and that at least eight Liga MX clubs belonged to four business groups, contrary to FIFA and FMF rules on multi-club ownership.[1]
The FMF replied that the second-division clubs themselves had asked for the measures in 2020, and that the suspension and the 20-million-peso subsidies were designed to run in parallel through 2025–26. It noted that the clubs were asking CAS to order the subsidies to continue into 2026–27.[1]
After a hearing in Mexico City on August 28, 2025, CAS dismissed the appeal on September 4. The panel concluded that the FMF had always intended the suspension to last until the end of 2025–26.[2] It cited the subsidy agreement, which described 240 million pesos a year “for the following 6 seasons,” during which the clubs “will not have the right of promotion” (translated), and found the subsidy was “intimately linked” to the suspension.[1] The panel declined to rule on the clubs’ other requests, including orders against a closed league and against multi-club ownership, because they fell outside the decision under appeal.[1]
A closed league
The 2026–27 Liga MX regulations, published July 15, 2026, state that “from the 2026–2027 season, Liga MX clubs will not be relegated to Expansión MX; likewise, Expansión MX clubs will not be promoted to Liga MX” (translated), citing an FMF Executive Committee agreement.[7] The Expansión MX regulations contain the same rule, citing the same agreement.[3]
The Liga MX regulations also contain no fines for the lowest-ranked clubs. Under the previous rules the bottom three clubs had paid 80, 47 and 33 million pesos.[7][8] Récord reported in April 2026 that the stabilization fund for Expansión clubs had ended, and linked its end to the clubs that had gone to CAS.[8] The Expansión MX regulations now impose smaller payments on its own bottom three clubs of 1.5 million, 1 million and 500,000 pesos.[3]
Aftermath
On September 14, 2026, the investigative authority of Mexico’s new National Antimonopoly Commission (CNA), COFECE’s successor, opened an ex officio investigation (file IO-001-2026) into possible relative monopolistic practices, meaning abuse of market power, in the market for “affiliation, organization and access to federated professional football competitions in Mexico.”[5][6] The commission said the opening did not prejudge anyone’s liability; sanctions can reach 10 percent of annual income.[6]
On September 23, 2026, a Senate bill led by Senator Clemente Castañeda proposed amending the General Law of Physical Culture and Sport. It would require national sports associations with two or more professional categories to guarantee promotion and relegation based on sporting merit and would prohibit “unjustified barriers to entry” (translated).[10]
Five Expansión clubs filed a third CAS appeal, and CAS scheduled a hearing in Mexico City for November 18, 2026.[11]
The core dilemma
Liga MX owners can argue that removing relegation protects investment, stabilizes clubs and mirrors successful closed leagues in North America. Expansión clubs, fans and some lawmakers argue that sporting merit is fundamental to football and that closing the league shields incumbents, some owned by the same business groups, from competition. The dilemma is whether owners should be free to close a league they collectively control, or whether access to the top division is a public interest that federations, courts or regulators must protect.
Competing values
- Sporting merit vs. investment stability: promotion rewards performance; a closed league protects investors.
- Contract vs. expectation: CAS read the 2020 agreement as temporary, but the clubs expected promotion to return.
- Self-governance vs. public oversight: the FMF and its members make the rules, but regulators and lawmakers are now involved.
- Solidarity vs. autonomy: subsidies supported lower-division clubs but ended with the suspension period.
Strongest arguments
For keeping the league closed: The 2020 measures were requested by the second-division clubs to survive, and both CAS panels upheld the FMF.[1][2] Owners can invest without the risk of relegation. Entry criteria such as infrastructure and finances protect the league’s quality.[10]
For restoring promotion and relegation: FIFA’s message in 2020, as described by the FMF president, was that Mexico should return to promotion and relegation in the medium term.[9] Expansión clubs argued the closed model breaches competition law and protects multi-club owners.[1] The fines that once punished poor performance and funded the second division have disappeared.[7][8] Regulators and legislators have taken up the issue.[5][10]
Applying the frameworks
Justice & fairness (Rawls)
Behind a veil of ignorance, not knowing whether you would own a Liga MX club or an Expansión club, you would likely want a system that gives every club a fair chance to rise. Rawls’s principle of fair equality of opportunity favors open access, while allowing reasonable entry criteria if they are objective and public.
Utilitarian
A utilitarian weighs the stability and investment a closed league may bring against lost excitement at the bottom of the table, lost hope for lower-division clubs and their communities, and risks of complacency. The disappearance of fines for the lowest-ranked teams raises questions about incentives to compete.[8]
Virtue ethics
Virtue ethics asks what a good steward of a national sport would do. Good faith suggests honoring the spirit of a temporary rescue, not using it as a path to a permanent closed league. It also asks whether owners with stakes in several clubs can act impartially.
Walk it through: the Simple Decision Model
- Spot the issue: Whether to reopen promotion and relegation after a six-season suspension.
- Gather facts: The 2020 agreement, the subsidy terms, club finances and the effects of the suspension.
- Test options: Reopen with clear criteria; reopen gradually; keep the league closed with revenue sharing; keep it closed without changes.
- Check codes and law: FMF and FIFA statutes, CAS rulings, Mexican competition law and any new legislation.
- Decide and document: Publish entry criteria and the reasons for the decision.
- Communicate and follow up: Consult clubs and fans and review the effects on competition.
What’s settled and what’s contested
- Settled: The FMF suspended promotion and relegation for six seasons in 2020; CAS twice upheld the suspension; the 2026–27 regulations keep the league closed; the CNA has opened an investigation.[1][2][3][5]
- Contested: whether the closed model is anticompetitive; whether the 2020 agreement created an obligation to reopen; whether legislation is appropriate; the outcome of the pending CAS case.[1][6][10][11]
Why this case matters
Promotion and relegation are central to football’s identity worldwide. Mexico’s case shows how a temporary emergency measure can become permanent, and how courts, competition regulators and legislators may step in when a league’s members decide who is allowed to join.
Key terms
- 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.
- Distributive justice
- Fairness in how scarce opportunities, resources, benefits and burdens are shared.
- Commercialization
- The process of turning sport into a product and a business enterprise, with profit pressures that can compete with principle.
- Institutional accountability
- Structures that make a sport organization explain its decisions and face consequences: clear authority, transparency, appeals, independent oversight and enforcement.
- Conflict of interest
- A situation where a person’s private interest could improperly influence a decision they make in an official role.
- 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.
Definitions from the Ethics Cases glossary.
Discussion questions
- Is a closed league like those in North America an acceptable model for Mexican football? Why or why not?
- Did the 2020 rescue package create a moral obligation to restore promotion after six seasons, even if the legal agreement was limited?
- Should lawmakers require promotion and relegation by law? What are the risks?
- How might multi-club ownership affect decisions about whether to open or close a league?
- Who should decide the structure of a national league: owners, the federation, courts, regulators or fans?
Sources
- CAS 2025/A/11442: Laudo arbitral (award) — Court of Arbitration for Sport
- The CAS dismisses an appeal by 6 second division Mexican football clubs — Court of Arbitration for Sport
- Reglamento de Competencia Expansión MX, Temporada 2026–2027 — Federación Mexicana de Fútbol
- COFECE sanciona a 17 clubes de la Liga MX, a la FMF y 8 personas físicas — Comisión Federal de Competencia Económica
- Aviso de inicio de la investigación de oficio IO-001-2026 — Diario Oficial de la Federación
- La CNA abre formalmente una investigación por prácticas monopólicas en el futbol mexicano — El Economista
- ¡Oficial! La Liga MX se queda sin ascenso, descenso y multas — Sports Illustrated México
- Liga MX pone fin a las multas por 'no descenso' — Récord
- FIFA apoya suspensión del Ascenso MX, aseguró Yon de Luisa — Infobae
- Revelan qué propone la iniciativa del Senado que obligaría a la Liga MX a regresar el ascenso y descenso — Infobae
- CAS sets date to rule on return of promotion and relegation in Liga MX — OneFootball