CAS arbitration in Ireland expected after UEFA's landmark statute amendment

UEFA, the football governing body for Europe, has opened the door for Dublin to become a seat of arbitration for all UEFA disputes before the Court of Arbitration for Sport.

In this article, our Sports law experts examine UEFA’s decision to permit Dublin as a seat of arbitration for UEFA disputes before the Court of Arbitration for Sport (CAS), discuss the CJEU decisions that precipitated this change, and their impact on EU law and sports arbitration. They also consider the broader significance of these changes for international arbitration in Ireland.

UEFA and the International Skating Union decision

In 2024, UEFA made an unprecedented decision to allow disputes in respect of UEFA rules for authorising club competitions to be arbitrated in Dublin, Ireland under CAS procedures. Before that, the seat of CAS has always been Lausanne, Switzerland.

UEFA took this measure because of the principle articulated in the Court of Justice of the European Union (CJEU) judgment in International Skating Union v Commission (Case C-124/21 P). The CJEU found that the mandatory provision for appeals to be made exclusively to the CAS, an arbitration body which is ultimately subject to appeal exclusively to the Swiss Federal Tribunal which does not have jurisdiction to rule on EU law, undermined both the protection of rights available under EU law and the effective compliance with EU competition law.

In order to ensure those rights were protected, the CJEU held that effective judicial review must be available under EU member state law, including being able to make a preliminary reference under Article 267 of The Treaty on the Functioning of the European Union (TFEU) to the CJEU to determine a matter of EU law.

You can read our outline of UEFA's initial selection of Dublin as an alternative seat for CAS here.

FC Seraing decision

In August 2025, the CJEU doubled down on those principles with its judgment in Royal Football Club Seraing v FIFA and UEFA (Case C‑600/23). The Court held that while mandatory arbitration - such as that required by UEFA and FIFA as a means of dispute resolution - may serve legitimate objectives such as uniform dispute resolution and consistent rule application in sport, but that these objectives have limits. Sports federations cannot justify the exercise of those powers where it limits the possibility for individuals to rely on the rights and freedoms conferred on them by EU law which form part of EU public policy.

The CJEU held that:

• CAS awards which involve athletes, clubs and individuals pursuing a sports-related economic activity within the European Union must be amenable to effective judicial review in EU member state courts where EU public policy is an issue

• "effective judicial review" of EU law cannot be provided by the Swiss Federal Tribunal as a court of a non-EU country. EU member state courts must be able to examine awards for compliance with EU public policy and be capable of referring the matter to the CJEU pursuant to the Article 267 review mechanism

• in respect of disputes where EU public policy is at issue, EU member states must have the authority to grant meaningful remedies such as cancelling awards, issuing damages, or stopping unlawful practices, as well as to issue interim measures to safeguard rights during ongoing proceedings

For background and detailed analysis of decision, see our earlier article on this topic: EU law and sports arbitration: lessons from the CJEU’s Seraing ruling

UEFA approves Dublin as CAS seat

From 1 July 2026, UEFA's statutes will allow for the seat of arbitration for CAS proceedings to be Dublin or Lausanne. Unlike the 2024 amendment, this is not limited to disputes arising from particular UEFA regulations. It accommodates the possibility of other UEFA rules and regulations prescribing Dublin as a potential seat of arbitration for proceedings before the CAS should UEFA amend those relevant rules and regulations in the future.

Dublin remains electable as a CAS seat only in relation to the Authorisation Rules. However, it now appears likely that UEFA will amend other rules and regulations to also provide for the option of Dublin as the CAS seat of arbitration. This would significantly increase the prospect of Dublin being a regular seat of arbitration for UEFA disputes. For context, 779 out of 1005 cases heard by CAS in 2025 related to football. While the majority of these would have arisen from FIFA disputes, UEFA disputes would also be prevalent.

The new UEFA statutes also provide that the enforcement or recognition of a CAS award may be challenged on the grounds of public policy (which may include European Union public policy laws) in accordance with any applicable national or European Union procedural laws. The effect of this is that a CAS award may be challenged before the Irish High Court.

The UEFA statutes have also provided that a CAS award may be challenged by filing a case with a competent authority, which in Ireland is the Competition and Consumer Protection Commission (CCPC).

International arbitration in Ireland

Ireland is a favourable choice for seat of arbitration. In addition to being a neutral country which trades globally, it is the only member state that is both native English-speaking and a common law jurisdiction in the EU.

Arbitration in Ireland is governed by the Arbitration Act 2010 which adopted the UNCITRAL Model Law on International Commercial Arbitration (as revised in 2006) established by the United Nations. Ireland has accepted this model in its entirety, with limited modification. Article 8(1) of the UNCITRAL Model Law requires Irish courts to refer parties to arbitration where the agreement in dispute is subject to a valid arbitration agreement. Irish courts are also generally supportive of arbitration and the grounds upon which an arbitral award can be potentially challenged are very limited.

In 2019, the Irish government also established an initiative called "Ireland for Law" which aims to promote Irish law and Irish legal services to the international business community. Ireland is internationally recognised as a hub for international financial services and is becoming a primary centre for the provision of legal advice and services in these areas. With the UEFA decision, this can be extended to sports disputes.

Key takeaways

UEFA's decision to provide for Dublin as a seat of CAS arbitration is a seismic change to the sports arbitration landscape and a significant opportunity for Ireland as a jurisdiction. We anticipate that changes to UEFA rules and regulations affected will become clear after 1 July 2026. Watch this space.

International sports federations will undoubtedly be carefully considering the FC Seraing ruling and whether they should follow UEFA's lead to provide for an alternative seat of CAS arbitration within the EU since mandatory CAS arbitration clauses are commonplace within the rules and regulations of international sports federations.

How Ogier can help

For more information on sports arbitration in Ireland or related sports law advice, contact our team via the details provided below.

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

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