FIGC and CONI (Disciplinary sanctions in the area of sport - Temporary prohibition on the pursuit of certain professional activities, imposed by a national sports association on two directors of a professional football club - Judgment) [2026] EUECJ C-424/24 (16 July 2026)

Executive summary

The Court of Justice answered a preliminary reference about disciplinary sanctions imposed by the FIGC on two Juventus directors for making or approving false financial and accounting statements. It held that such temporary bans on professional sporting activity can restrict free movement and services, but may be justified by the public-interest aim of ensuring the proper conduct of sporting competitions, provided the sanctions are proportionate and based on transparent, objective, non-discriminatory, proportionate, and verifiable criteria; it also assessed whether the available judicial review satisfied Article 47 of the Charter.

Key points

• Parties: ZD and MI v FIGC, CONI, and related FIGC/CONI disciplinary bodies; the sanctions were temporary prohibitions on pursuing professional activities within the FIGC.
• Holding: sports disciplinary sanctions can fall within Articles 45 and 56 TFEU as obstacles to movement/services, but may be justified by the proper conduct of sporting competitions.
• Reasoning: the Court emphasized proportionality and the need for transparent, objective, non-discriminatory, proportionate, and verifiable criteria when determining sanctions.
• Procedural rights: the judgment examined whether effective judicial protection existed where a court could award compensation for an indirectly reviewed sanction but could not annul or suspend it.
• Sanctions/export-control angle: not a sanctions or export-controls case in the restrictive-measures sense; its relevance is analogical, showing how EU law scrutinizes sectoral disciplinary bans and review mechanisms.

Why it matters

This is relevant to sanctions and sovereign-risk analysis because it tests when an internally imposed professional prohibition becomes an EU-law restraint on cross-border work and services, and what safeguards are required before such a ban is lawful. It also underscores that limited remedies may be insufficient where a disciplinary measure has immediate market-access effects.

Implications

For compliance and litigation strategy, regulated associations and quasi-public bodies should ensure disciplinary rules are precise, objective, and reviewable, with a record showing proportionality. Entities facing sectoral bans should frame challenges not only as internal governance disputes but as EU free-movement and effective-remedy questions, especially where the sanction blocks professional activity while appeal rights are incomplete.