FIFA Faces Billion-Euro Class Action: The Lawsuit That Could Change the Transfer System Forever

The summer of 2025 may be remembered as a turning point in the legal scrutiny of FIFA’s (Fédération Internationale de Football Association) transfer system within the European Union. On 4 August 2025, the Dutch foundation Justice for Players[5] (“JfP”) announced the launch of a collective action against FIFA and a number of European football associations[6]. The case will be filed before the District Court of Midden-Nederland under the Dutch Act on the Settlement of Mass Damages in Collective Action[7]. It is a bold attempt to confront FIFA’s transfer rules at their core, and it arrives less than a year after the Court of Justice of the European Union (“CJEU”) declared parts of those rules incompatible with European law.[8]

Legal Background: The Diarra Judgment of the CJEU

This JfP action at hand is anchored in the CJEU’s Diarra judgment of October 4, 2024[9]. In that case, the Court held that several core provisions of FIFA’s Regulations on the Status and Transfer of Players[10] (“RSTP”) were incompatible with fundamental principles of EU law, in particular the freedom of movement of workers under Article 45[11] of the Treaty on the Functioning of the European Union (“TFEU”) and the prohibition of anti-competitive agreements under Article 101 TFEU[12]. The judgment thus struck at the heart of the regulatory framework governing player mobility.

Lassana Diarra (whose professional career included periods at Chelsea, Arsenal, Portsmouth and Real Madrid) became the central figure in this legal dispute. In 2013, he signed a four-year contract with Lokomotiv Moscow. Barely a year later, the employment relationship deteriorated after the club-imposed wage cuts, a decision Diarra contested. Lokomotiv Moscow proceeded to terminate the contract, and the dispute escalated to FIFA’s dispute resolution chamber and ultimately to the Court of Arbitration for Sport (“CAS”). CAS concluded that Lokomotiv Moscow had terminated with just cause and ordered Diarra to pay €10.5 million in compensation, a sum wholly disproportionate to the player’s earnings capacity.

Yet the consequences extended beyond the award itself. Under the RSTP as then drafted, a player who terminated a contract without just cause was not only personally liable for compensation but also exposed any prospective new club to joint and several liability. Moreover, the issuance of the International Transfer Certificate, a prerequisite for registration with a new federation, could be withheld. Faced with such risks, Belgian club Charleroi abandoned negotiations to sign Diarra. Although he eventually returned to professional football with Marseille in 2015, the collapse of the Charleroi transfer left him sidelined for an entire season, depriving him of income and competitive continuity.

In response, Diarra initiated proceedings before Belgian courts, seeking €6 million in damages against FIFA and the Belgian federation. The Belgian courts, recognizing the broader implications for EU law, referred questions to the CJEU for a preliminary ruling. The Court used the opportunity to conduct a structural examination of FIFA’s transfer rules. It was found that the rules in question imposed restrictions that were neither inherent nor proportionate to the objectives claimed by FIFA. In particular, the Court emphasized that the possibility of clubs competing for talent through recruitment is an essential element of professional football, and that rules which immobilize players or predetermine their allocation among employers undermine both market competition and worker mobility. The CJEU went so far as to characterize the regime as “similar to a no-poach agreement,” a type of arrangement widely recognized in competition law as anticompetitive because it suppresses competition for labour.

The Diarra judgment thus made clear that FIFA’s regulatory framework cannot stand above EU law. While the Court acknowledged the specificity of sport, it reaffirmed that the autonomy of sporting bodies ends where fundamental Treaty principles begin. In doing so, it provided not only a victory for Diarra but also a legal foundation for broader challenges, of which the Justice for Players action is the first and most ambitious.

The comparison with the famous Bosman ruling was inevitable[13]. Just as Jean-Marc Bosman’s struggle in the mid-1990s reshaped European football by granting players the right to move freely at the end of their contracts, the Diarra case has opened the door to a new wave of litigation. FIFPRO (Fédération Internationale des Associations de Footballeurs Professionnels), the international players’ union, hailed the ruling as a major decision on the regulation of the labour market in football. It saw in it not only vindication for Diarra but also an opportunity to restore balance to a system that had long privileged clubs and governing bodies over individual players.

The Case at Hand: “FIFA, I want my freedom!”

Against this backdrop, JfP was created as the vehicle for collective redress. The foundation has moved swiftly, supported by litigation funder Deminor, which ensures that players face no financial risks in joining the claim. The Dutch boutique Finch Dispute Resolution leads the proceedings, while Dupont-Hissel, the firm that represented Diarra and has been involved in some of the most consequential sports law cases of the last three decades, provides additional expertise. Jean-Louis Dupont, the lawyer synonymous with the Bosman ruling, is advising JfP[14].

The defendants are as prominent as the claimants. Besides FIFA, the action targets the football associations of Germany, France, Belgium, the Netherlands and Denmark. United Kingdom’s Football Association has also been notified and may yet be added. All have been given until September 2025 to respond to the notice of action[15]. If a settlement cannot be reached in advance, the case to get to court in 2029, JFP expects [16].

The potential consequences for football are significant. Although FIFA adopted an interim regulatory framework in December 2024 amending the RSTP (including the methodology for compensation and certain burdens of proof), FIFPRO and other commentators view the changes as insufficient and not compliant with the Diarra principles. If successful, the claim could accelerate a structural shift in the football labour market. Treating players as ordinary workers for EU-law purposes weakens the normative basis for fee-based allocation mechanisms, with predictable effects on contract duration, wage formation and bargaining dynamics. Distributional impacts are non-trivial: many clubs—particularly smaller ones—rely on transfer proceeds and on capitalising player registrations as intangible assets; an abrupt contraction of such income, coupled with immediate exposure to damages, raises solvency and restructuring risks.

Beyond substance, the case underscores the limits of regulatory autonomy for sporting bodies under EU law and the growing role of collective redress in sports governance. The proceedings are at an early stage; public reporting suggests a protracted timetable, while a settlement-driven redesign of the rules remains plausible in light of FIFA’s stated intention to engage in dialogue and update the framework.

Regardless of its ultimate outcome, the JfP action forces a fundamental question: should footballers, like other workers in the European Union, enjoy full mobility and freedom of contract, or is football’s unique ecosystem sufficient to justify restrictions? The answer will shape not only the careers of players but also the finances of clubs, the authority of FIFA, and the very identity of the world’s most popular sport.

[1] Attorney Gülce Korkmaz is the external competition law consultant of Baş | Kaymaz Law Firm. After completing her master’s degree at Bilkent University, she is currently pursuing her doctoral studies in the field of competition law at the Faculty of Law of Lüneburg Leuphana University (Germany) as a PhD researcher with the scholarship of the Joachim Herz Foundation.

[2] “Justice for Players was founded to advocate for the interests of professional footballers” https://justiceforplayers.com/  https://justiceforplayers.com/fifa-i-want-my-freedom-back/

[3] Please see the press release: FIFA Class Action Press Release

[4] The Dutch Act on redress of mass damages in collective action (Wet afwikkeling massaschade in collectieve actie or “WAMCA”) came into force on 1 January 2020.

[5] Please see the press release: FIFA Class Action Press Release

[6] Please see: The lawsuit that could change football – DW – 08/06/2025
Fifa facing multibillion-pound compensation claim from players | Football | The Guardian

FIFA faces class action over player transfer regulations | Reuters
Legal case a ‘seismic confrontation’ between players and Fifa – BBC

[7] Press release FIFA Class Action Press Release: “A preliminary analysis by economists at Compass Lexecon has es mated that affected professional footballers have earned approximately 8% less over the course of their career than they would have if the FIFA Regulations had not been unlawfully restrictive.”

[8] Please see: The lawsuit that could change football – DW – 08/06/2025

[9] CJEU, Fédération internationale de football association (FIFA) v. BZ, Case no. C 650/22, 4 October 2024, ECLI:EU:c:2024:824. For further please see: Hendrickx, F. (2025). Transfers in Professional Football and the Diarra Case. International Labor Rights Case Law, 11(2), 249-254. https://doi.org/10.1163/24056901-11020015

[10] The FIFA Regulations on the Status and Transfer of Players outline general rules on the status of players and their eligibility to participate in organized football, as well as for their transfer between clubs affiliated with different associations. In other words, the FIFA Regulations on the Status and Transfer of Players establish general and binding rules regarding the status of players, their eligibility, or even their transfer. For more, please see https://fifa.sportsagentinstitute.com/en/subject/regulations-on-the-status-and-transfer-of-players-rstp. For the full text of the FIFA Regulations on the Status and Transfer of Players, please see https://digitalhub.fifa.com/m/620d0240c40944ed/original/Regulations-on-the-Status-and-Transfer-of-Players-October-2022-edition.pdf

[11] Freedom of movement for workers has been one of the founding principles of the EU since its inception. It is laid down in Article 45 TFEU and is a fundamental right of workers, complementing the free movement of goods, capital and services within the European single market. For more on the Free movement of workers, please see https://www.europarl.europa.eu/factsheets/en/sheet/41/free-movement-of-workers

[12] Article 101 TFEU constitutes one of the three cornerstones of EU competition law. It addresses restrictive arrangements between undertakings that operate independently on the market. Such arrangements may occur horizontally—between actual or potential competitors at the same level of the supply chain—or vertically—between operators at different levels, such as producers and distributors. In addition, the provision covers decisions of associations of undertakings and concerted practices. These forms of coordinated conduct fall within the scope of EU competition law insofar as they are capable of appreciably affecting trade between Member States and have the object or effect of preventing, restricting, or distorting competition in the internal market.
Lorenz M. Key concepts of Article 101 TFEU. In: An Introduction to EU Competition Law. Cambridge University Press; 2013:62-127.
“Without a doubt, Article 101(1) TFEU is applicable to the activities of football clubs and of their associations, be they the national ones, UEFA, or FIFA. These associations are associations of undertakings.” Podszun R., Kirk A., FIFA’s football agent regulations and European competition law, Journal of Antitrust Enforcement, Volume 13, Issue 2, July 2025, Pages 458–483, https://doi.org/10.1093/jaenfo/jnae045

[13] For example, please see The Guardian’s article titled “The Lassana Diarra case: what is it and will it change football like Bosman?” https://www.theguardian.com/football/2024/oct/03/lassana-diarra-case-explained-fifa-european-football For the Bosman decision, please see: Case C-415/93 (Court of Justice) Union royale belge des sociétés de football association ASBL v Jean-Marc Bosman, Royal club liégeois SA v Jean-Marc Bosman and others and Union des associations européennes de football (UEFA) v JeanMarc Bosman [1995] ECR I-4921.

[14] Please see the press release: FIFA Class Action Press Release

[15] Please see: https://www.theguardian.com/football/2025/aug/04/fifa-multibillion-pound-compensation-claim-former-players-transfer-regulations?utm_source=chatgpt.com

[16] Please see: The lawsuit that could change football – DW – 08/06/2025

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