In the first half of 2025, Real Madrid C.F underwent two separate UEFA disciplinary proceedings arising from supporter misconduct during two different matches of the UEFA Champions League.

One involved a mass chant at Santiago Bernabéu directed at rival coach Pep Guardiola; the other, a single supporter performing a Nazi salute during a match played in London, an incident witnessed by almost no one and generating no media coverage at the time. Yet in both cases, the CAS decisions reached materially the same conclusions on the governing principles: Real Madrid was found liable, the UEFA sanctions were upheld, and the appeals were dismissed.

The two awards - CAS 2025/A/11261 Real Madrid Club de Fútbol v. UEFA[1] (the “Chant Award”) and CAS 2025/A/11723 Real Madrid C.F. v. UEFA[2] (the “Salute Award”), were notified within weeks of each other and merit a joint analysis.

These awards provide guidance on three practical questions:

• how football’s anti-discrimination regime operates when liability arises regardless of fault,
• whether CAS panels are willing to interfere with disciplinary decisions; and
• what clubs and federations can do to mitigate sanctions once liability has been established.

These questions are particularly relevant as the FIFA World Cup 26TM has just concluded, and national associations may face disciplinary proceedings arising from supporter misconduct during the event. During this competition, national federations are subject to the FIFA Disciplinary Code - which mirrors the same core principles of UEFA’s framework - including FIFA’s strict approach to supporter misconduct. Accordingly, the issues examined here extend well beyond the context of club competitions and are equally relevant in the World Cup arena.

This article looks at:

• Strict Liability in Football Law: Supporter Misconduct A Key Distinction
• Facts of the Real Madrid Awards: Strict Liability in its purest form
  • The Nazi Salute Award: an isolated act
  • The Chant Award: contested liability
• If liability is inevitable, what can clubs actually do?
  • Mitigating Factors: What is recognised?
  • Financial standing
• Powers of Review of a CAS panel: How De Novo is "De Novo"?
• Comparing the UEFA incidents to the framework at The FIFA World Cup 26™
  • Applicable Framework
  • Sanctions and the three-step protocol
  • Prevention as mitigation: Article 15(7)
  • Procedure and forum
  • Applying the FIFA framework: two worked examples
• Practical Lessons for National Federations & Football Clubs
  • Isolated incidents do not create immunity
  • Swift internal reaction may reduce sanctions, but it does not prevent liability
  • Is financial capacity relevant to proportionality?
• Conclusion

[1]Part 1 (see here[2]) of this series outlined a working definition of safeguarding in esports and identified three interconnected categories of harm: sexual abuse and harassment, cyberbullying, and physical and mental health problems. It also detailed the range of stakeholders within the ecosystem.

Part 2 of this series examines the practical responses of two of those stakeholders — video game publishers and esports federations — and considers whether their self-regulatory initiatives are sufficient to address those harms. Part 3 (to be published shortly) examines the safeguarding initiatives of online platform providers Twitch and YouTube, before setting out overarching recommendations on how the esports ecosystem might develop a more unified approach to safeguarding across all stakeholder groups.

• Initiatives by Video Game Publishers
• Is There A Common Standard for “Safeguarding in Esports and Video Gaming”?
• Electronic Arts (EA)
• Ubisoft
• Riot Games
  • Self-Regulatory Framework
  • Behavioural Enforcement Mechanisms
  • New Dispute Resolution by Riot Games
• Esports Federations
  • International Esports Federation
    • Practical Safeguarding Initiatives
  • Global Esports Federation
    • Practical Safeguarding Initiatives
  • Swiss Esports Federation
  • British Esports Federation
    • Coaching and Education Standards
    • International Safeguards for Children in Esports

In international football, the moment a player represents a national team is the culmination of not just sporting ambition, but also a carefully regulated legal process. FIFA, as the global governing body, ensures that such representation adheres to strict rules designed to maintain fairness and integrity in the game.

Ryan Williams opened his international career for India in remarkable fashion, scoring on debut on 31 March 2026, etching his name into the record books. An Australian national by birth, his appearance for India followed a formal change of footballing association in line with FIFA regulations, marking a notable development in the evolving landscape of Indian football. His debut was marked by a historic achievement, scoring the fastest goal by a debutant[1]. While this moment captured headlines and excitement among fans, it also reflected the successful completion of a detailed and structured process governed by FIFA’s regulations on change of association.

The case further represented one of the significant change of association matters undertaken by the the All India Football Federation (AIFF) in recent years. The last notable case of a similar nature for the AIFF involved Arata Izumi in 2012[2], following which FIFA introduced several amendments to the eligibility and change of association regulations, along with substantial procedural developments. Given the amendments, the Ryan Williams matter presented a significant responsibility for the AIFF, requiring careful interpretation of the revised regulatory framework and strict compliance with FIFA’s procedural requirements in the context of an evolving regulatory landscape.

The author was directly involved in Ryan Williams’ change of association in his role as Head of the Players’ Status and Registration Department at the AIFF, where he also manages the federation’s FIFA Member Association account on the FIFA Legal Portal.

This article is therefore intended to provide a practical, experience-based insight into how the change of association process in football works in practice.

The article looks at:

• A Historic Debut Built on Compliance
• Understanding FIFA Regulations: Article 10 and Its Application
• The Application and FIFA’s Assessment
• Final Decision and Immediate Eligibility
• Key Principles: Eligibility, Nationality and the One-Change Rule
• Why FIFA’s Process Matters