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It is with much pleasure that we welcome readers to the March 2026 edition (citation: SLT 2026/1) of our ground-breaking journal Sports Law and Taxation (SLT) and online database https://sportslawandtaxation.com.

During 2026, there will be a number of major international sports events to look forward to, including the expanded 2026 FIFA Men’s World Cup, which takes place in 16 host cities in Canada, Mexico and the United States, from 11 June to 19 July and in which 48 teams, from around the world, will compete in 104 fixtures.

In February, we have already enjoyed the most spread-out Winter Olympic Games, which were held in Milan and Cortina d’Ampezzo in Northern Italy from 6 to 22 February and involved around 3,500 athletes, who competed in 16 disciplines and 116 events. The Games, however, were not without controversy as we report below.

As mentioned, 2026 promises to be an interesting and challenging sporting year in other parts of the world, not least in the Republic of South Africa. So, we asked Razia Mahomed of the School of Law of the University of South Africa, in Pretoria, to map out what is in store for us in this well-known sporting nation, in particular, identifying the legal issues to be expected this year. Here is her most interesting report:

“Sports law issues to watch out for in South Africa in 2026: from eligibility disputes to integrity, welfare, and governance

Introduction

South African sport enters 2026 facing an unusually crowded legal agenda.

Some legal issues are familiar, such as discipline, contracts, doping, match integrity, yet the fault lines are shifting. Athlete welfare is moving from “best practice” to “liability exposure”. Integrity regulation is being pulled into the orbit of gambling advertising and influencer marketing. Governance expectations are rising, not only from the state and sponsors, but also from new governance standards that are filtering into sports bodies.

And then there is the question that, increasingly, sits at the intersection of equality law, sporting autonomy, and public controversy: eligibility in the female category, including transgender participation and related sex-characteristics regulation.

The International Olympic Committee (“IOC”) has publicly committed to issuing new eligibility criteria in early 2026, an international move that will inevitably shape South African policy debates and disputes, given our athletes’ participation in global competitions and the reliance of local sports federations on international rules.

What follows is a practical “legal issues map” for 2026: where disputes are most likely; how they may present procedurally; and what risk-management steps governing bodies and stakeholders can sensibly take now.

The next wave of eligibility disputes: transgender participation and the “female category”

The South African legal order is constitutionally committed to equality, dignity, and non-discrimination. But sport, especially sex-segregated sport, has always presented a more complex legal challenge. It is simultaneously a site of inclusion; a field of safety regulation; and a competitive system built on categorisation. In 2026, this tension is likely to crystallise into disputes, as the global regulatory environment remains unsettled and in rapid flux.

Internationally, the IOC, as mentioned, has indicated it will set new eligibility rules in early 2026, reversing its earlier posture of leaving the matter entirely to individual sports federations and thereby seeking more consistency. The significance for South Africa does not lie in any direct governance of local sport by the IOC, but in the cascading effect of international rule changes. Sports federations routinely align eligibility policies for pathway athletes, team selection, and qualification events with international standards, and domestic administrators frequently adopt these criteria to avoid inconsistency and conflict in selection and participation.

For contact sports, the “safety” dimension is especially sharp. World Rugby’s transgender guideline framework is explicitly framed around safety and fairness in a collision sport, and it remains one of the most cited examples in global eligibility debates. Even where a South African federation is not bound to mirror those rules, they provide a template for how sports governing bodies justify restrictions (or inclusion models) through scientific and risk-based reasoning rather than moral claims.

In South Africa, eligibility disputes in 2026 are likely to take several forms. These include challenges to national or provincial selection decisions where eligibility criteria are contested, particularly if international rules change mid-cycle, as well as participation disputes at school and club level where policies are unclear, inconsistently applied across regions, or not updated to reflect international developments.

Such disputes are likely to be framed in administrative-law terms, with claims of irrationality, procedural unfairness, inadequate reasoning, or inconsistency, and in equality-law terms, with arguments centring on discrimination versus lawful differentiation justified by safety or fairness considerations. Eligibility controversies also carry a heightened risk of safeguarding and harassment spillover, especially where privacy concerns arise, requiring robust complaints-handling and protective mechanisms.

Sports governing bodies need not wait for a test case to respond. Federations should adopt policies that clearly distinguish between participation and competition categories and should develop differentiated pathways for social participation; open categories; mixed formats; and elite competition, each with distinct risk profiles.

Where eligibility restrictions are contemplated, policies must be supported by a defensible and evolving evidence base linking the restriction to legitimate aims, such as safety, fairness, or meaningful competition. Procedural fairness must be embedded throughout, requiring eligibility criteria to be published in advance; decisions to be accompanied by clear reasons; affected athletes to have access to internal appeal mechanisms; and medical and privacy-sensitive information to be handled lawfully, proportionately, and only to the extent as may be strictly necessary. Finally, eligibility decision-making must be aligned with safeguarding frameworks so that athletes are protected from harassment and abuse through established reporting and response mechanisms.

The key point for 2026 is, even if South Africa does not see a “headline” court case, eligibility disputes are likely to increase inside federations, precisely the kind of conflict that becomes high-profile when mishandled.

Athlete welfare and concussion risk: from protocol compliance to liability management

The legal conversation on concussion has matured globally from “what is best practice?” to “what is the standard of care, and who is accountable when it is breached?” South African rugby, in particular, cannot be insulated from the broader litigation and regulatory pressure shaping the sport worldwide, especially in the United Kingdom, both at the elite and grass roots’ levels.

Globally, large-scale concussion-related claims for damages against governing bodies continue to evolve, sustaining close scrutiny of governance practices and the medical duty of care. In parallel, the sport has responded through regulatory experimentation aimed at reducing head-contact risk, including World Rugby’s extension of lower tackle-height trials into elite competition at the U20 Championship in 2026.

South African stakeholders should approach 2026 as a period in which risk controls will be scrutinised, not merely implemented. This scrutiny will extend to coaching practices and tackle-technique interventions; the robustness and independence of return-to-play decision-making systems; the degree of medical independence within teams and institutions; the adequacy of compliance documentation; and the manner in which risk is managed across different sporting contexts, particularly the distinctions between youth and school sport and professional environments.

Notably, World Rugby and SA Rugby have also moved towards more structured support systems for former players’ brain health in South Africa; an example of welfare measures that can influence expectations of what “reasonable steps” look like.

At a local level, several categories of legal issues are likely to surface. These include negligence-based claims framed in delict, focusing on whether unions, schools, clubs, or event organisers owed and breached duties of care, including through inadequate protocols or training practices.

Employment and labour law dimensions are also likely to arise, particularly in relation to medical clearance disputes; the disciplinary consequences of dangerous play; and tensions between athlete protection and performance imperatives. In addition, insurance and indemnity disputes may emerge concerning the scope of policy exclusions and the extent to which participant waivers provide the legal protection administrators assume that they do.

Finally, as sport increasingly relies on “objective” impact-monitoring data, disputes are likely to arise over data interpretation, access rights, confidentiality, and the validity of consent.

The compliance mindset has to shift. Protocols are not merely safety documents; they are litigation exhibits.

Gambling, advertising, and integrity: the regulatory squeeze tightens

Few trends are reshaping sport’s commercial and integrity environment as quickly as online betting. In South Africa, regulators have publicly signalled escalating concerns about gambling advertising that appears to contravene the National Gambling Act and Regulations and have pushed for stronger enforcement and reporting of non-compliant advertisements.

For sport, these have three legal consequences in 2026.

–    Sponsorship and brand risk become compliance risk. Betting sponsorship is not only a reputational issue; it can become a compliance issue where advertising content, placement, or influencer-led promotion crosses regulatory lines. This will affect clubs, leagues, athletes, and influencers, particularly where marketing reaches minors or uses misleading messaging.

–    Integrity enforcement will increase alongside betting growth. Match-fixing and betting corruption remain persistent risks. South Africa has seen ongoing match-fixing-related criminal proceedings in cricket, reflecting how sports integrity can spill into commercial crimes enforcement and lengthy reputational damage. There are also continuing integrity concerns in domestic association football environments, including reported allegations at league level, which typically raise governance and disciplinary-law questions (investigation standards, evidentiary thresholds, sanction consistency).

–    Consumer protection and athlete conduct rules will merge. As betting activity becomes more visible, sports federations will come under increased pressure to regulate the conduct of athletes and officials more tightly, particularly in relation to inside information, social media activity, and associations with betting interests, whilst ensuring that such regulation is implemented through fair and transparent procedures.

A practical prediction is that 2026 will see disputes focused on the disciplinary process, such as who conducts investigations; the nature of the evidence relied upon; confidentiality; and appeal rights. Rather than on the moral wrongness of match-fixing.

Governance and oversight: higher expectations, harder consequences

South African sport continues to confront persistent governance stress in areas such as financial controls, procurement, leadership disputes, and stakeholder confidence. Two developments in particular sharpen the outlook for 2026.

First, governance disclosure and accountability standards continue to tighten in the broader South African governance ecosystem, with King V taking effect for financial years beginning on or after 1 January 2026 (with early adoption encouraged). Whilst sports bodies vary in legal form, the governance expectations of sponsors, public entities, and stakeholders increasingly mirror corporate governance norms, especially around transparency, decision rationality, and conflict management.

Second, sports’ public accountability is increasingly linked to government frameworks and reporting expectations, visible in official departmental reporting and compliance architecture across the sports sector.

Governance gaps are likely to give rise to a range of legal disputes. These include leadership and election challenges arising from procedural irregularities; eligibility disputes; or improperly constituted meetings; as well as procurement disputes relating to sponsorship arrangements, kit supply, and broadcasting agreements. Funding and selection decisions linked to transformation or development mandates may also become contested, particularly where criteria are unclear or inconsistently applied. In addition, misconduct proceedings against officials may generate legal challenges focused on procedural fairness, evidentiary standards, and the consistency of sanctions.

If 2025 taught sports administrators anything, it is that “internal politics” becomes “legal governance” the moment sponsors, athletes, or the state insist on accountability.

Safeguarding and safe sport: from policy to enforcement

South African sport is increasingly expected to implement safeguarding systems aligned with international norms, covering harassment, abuse, and child protection. The South African Sports Confederation and Olympic Committee (SASCOC) has long had a safeguarding policy framework, reflecting the broad commitment to protecting participants, irrespective of protected characteristics. Sports codes and federations continue to develop and update their own safeguarding instruments as well, demonstrating that safeguarding is no longer optional governance “window dressing” but an operational imperative.

In 2026, the legal pressure point is unlikely to centre on whether a safeguarding policy exists, but rather on whether it operates effectively in practice. This includes whether reporting mechanisms are accessible and understood; whether investigations are conducted promptly and impartially; whether interim protective measures are applied appropriately; whether sanctions are imposed consistently and subject to appeal; and whether minors are protected in substance rather than merely in principle.

These concerns are particularly acute in eligibility controversies and social-media-driven disputes, where risks relating to safeguarding, privacy, and harassment escalate rapidly.

Sports tech, data, and privacy: POPIA’s slow-burning litigation potential

As sport adopts more wearable tech and monitoring systems, especially in contact sports, data protection issues become increasingly live. South African commentary and legal analysis have repeatedly highlighted that wearable/physiological data is likely to be treated as sensitive (“special personal information”) requiring stronger safeguards under the Prevention of Personal Information Act 4 of 2013 (POPIA).

In 2026, these issues are likely to manifest in disputes concerning the validity of consent, particularly whether consent was genuinely voluntary within team or employment contexts, as well as disputes over athletes’ right of access to their personal data. Additional points of contention are likely to arise around the disclosure of data to third parties, including sponsors, media, selection committees, and insurers, together with security incidents that may trigger mandatory reporting obligations under data-protection law.

The practical advice may be unglamorous but remains decisive: it requires minimising data collection; documenting lawful bases for processing; ensuring secure storage; defining retention periods; and separating performance analytics from medical decision-making, wherever possible.

Conclusion: 2026 will reward procedural fairness and punish “informal” decision-making

Across eligibility, welfare, integrity, governance, safeguarding, and data protection, a single unifying theme emerges in the form of procedural fairness. The greatest legal risks do not arise from making difficult decisions, but from making them informally, inconsistently, without reasons, or without appeal mechanisms.

Eligibility disputes will intensify as international rules shift in early 2026. Welfare and concussion risk will remain a live liability frontier as standards of care evolve. Gambling advertising scrutiny will test sponsorship models and integrity systems. Governance and safeguarding expectations will continue to rise, and data-protection compliance will grow.

In 2026, South African sport will reward those organisations that treat administration as a legal discipline, anchored in transparent rules, fair processes, documented reasoning, and athlete-centred risk management, and will penalise those that do not.”

So, there are quite a few challenges awaiting sport in South Africa in this year!

Association football winter transfer window 2026

The 2026 winter transfer window closed on 2 February 2026, with the English Premier League recording its quietest deadline day with only seven deals completed.

Not a single arrival was confirmed until 19:04 Greenwich Mean Time – four minutes after the window closed – with Crystal Palace FC announcing the signing of striker Jorgen Strand Larsen from Wolves FC in a deal worth up to £ 48 million (around € 55.6 million).

Five further deals were confirmed after the deadline – amongst them, Sunderland FC brought in Ecuador winger Nilson Angulo from RSC Anderlecht in a deal worth £ 17.5 million (around € 20.2 million), whilst Wolves FC signed midfielder Angel Gomes from Marseille FC on loan and replaced Strand Larsen with Adam Armstrong from Southampton FC for £ 7 million (around € 8.1 million).

The overall spending in the English Premier League during the 2026 winter transfer window was more than £ 390 million (around € 451.9 million).

Jordan Chiles case sent back to the Court of Arbitration for Sport (“CAS”)

The Swiss Federal Supreme Court has issued the following important press release on 29 January 2026:[1]

“The Swiss Federal Supreme Court Judgments of 23 January 2026 (4A_438/2024, 4A_494/2024, 4A_510/2024, 4A_512/2024, 4A_594/2024) Awarding of the bronze medal in the women’s artistic gymnastics floor exercise at the Paris 2024 Olympic Games – Admission of requests for revision by Jordan Chiles and USA Gymnastics

The Swiss Federal Supreme Court has accepted the requests for revision lodged by American gymnast Jordan Chiles and USA Gymnastics against the arbitral award handed down in August 2024 by the Court of Arbitration for Sport (CAS).

Jordan Chiles finished third in the women’s artistic gymnastics floor exercise final at the 2024 Paris Olympic Games after successfully challenging her initial score during the competition.

The CAS, which was subsequently called upon, ruled that Jordan Chiles had filed her complaint too late during the competition. It therefore stripped Jordan Chiles of her bronze medal and awarded it to Ana Maria Bărbosu. Because of an audio-visual recording discovered after the CAS award, the Federal Supreme Court acknowledged that this new evidence may justify a modification of the contested award.

It referred the case back to the CAS for it to re-examine the situation, taking this new evidence into account.

The Federal Supreme Court dismissed the appeal and the request for revision filed by Sabrina Maneca-Voinea, who had finished fifth in the competition and also wanted to obtain the bronze medal.

The final of the women’s individual artistic gymnastics floor exercise at the Paris Olympic Games took place on 5 August 2024. Ana Maria Bărbosu scored 13.700. After her performance, Sabrina Maneca-Voinea was ranked fourth in the provisional ranking, behind Ana Maria Bărbosu. Sabrina Maneca-Voinea had 0.1 points deducted for stepping outside the boundaries of the floor, which she did not contest on site. Jordan Chiles was the last gymnast to compete. She scored a total of 13.666. Following a complaint lodged by her coach and accepted by the competition’s senior jury, her score was set at 13.766. Jordan Chiles thus relegated Ana Maria Bărbosu to fourth place and was awarded the bronze medal.

The Romanian Gymnastics Federation, Ana Maria Bărbosu and Sabrina Maneca-Voinea appealed to the ad hoc chamber of the CAS set up for the Paris 2024 Olympic Games. They argued that Jordan Chiles’ complaint had been lodged after the one-minute deadline stipulated in the applicable regulations had expired. Sabrina Maneca-Voinea contested the penalty imposed on her, arguing that she had not left the boundaries of the floor. On 10 August 2024, the CAS panel of three arbitrators ruled that the complaint filed on behalf of Jordan Chiles had been made one minute and four seconds after the American gymnast’s score was announced on the scoreboard and was thus late. It therefore ruled that Jordan Chiles’ score should remain at 13.666. The CAS also ruled that it could not review the penalty imposed on Sabrina Maneca-Voinea.

Sabrina Maneca-Voinea challenged the CAS award by filing an appeal and a request for revision with the Swiss Federal Supreme Court. In its decision of 23 January 2026, the Federal Court deemed both legal arguments inadmissible. It considered that it could not examine whether the gymnast had stepped outside the boundaries of the floor, as this question fell within the category of non-justiciable rules of the game and not within that of reviewable legal rules.

Jordan Chiles also filed an appeal with the Federal Supreme Court, challenging the independence and impartiality of one of the three CAS arbitrators, as well as a request for revision of the 10 August 2024 arbitral award. The United States Gymnastics Federation (USA Gymnastics) also submitted a request for revision. The Federal Supreme Court rejected Jordan Chiles’ appeal concerning the alleged lack of independence and impartiality of the arbitrator in question. However, it accepted both requests for revision.

In the highly exceptional circumstances of the case in question, it considers that there is a likelihood for the audio-visual recording of the final on 5 August 2024 to lead to a modification of the contested award in favour of the applicants, since the CAS could consider, in the light of this audio-visual sequence, that the verbal inquiry made on behalf of Jordan Chiles had been made before the expiry of the regulatory one-minute time limit.

The Federal Supreme Court therefore partially overturns the contested award and refers the case back to the CAS for a new ruling, taking into account the probative value of the audio-visual recording in question.”

The Vladyslav Heraskevych case

Once again, the CAS has been in session, in the form of its Ad Hoc Division (“AHD”), at the Winter Olympic Games and, on 13 February 2026, the CAS AHD dealt with a controversial case involving a Ukrainian skeleton athlete, which captured the attention of the world’s media.

The CAS AHD denied his application against the International Bobsleigh & Skeleton Federation (“IBSF”) and the International Olympic Committee (“IOC”). The Sole Arbitrator, whilst fully sympathetic to Mr Heraskevych’s commemoration, was bound by rules in the IOC Athlete Expression Guidelines. The Sole Arbitrator considered that these Guidelines provide a reasonable balance between athletes’ interests to express their views, and athletes’ interests to receive undivided attention for their sporting performance on the field of play.

The application challenged the IBSF jury decision to withdraw the athlete from the men’s skeleton event with immediate effect from the Olympic Winter Games Milano Cortina 2026 (“2026 OWG”). The IBSF decision stated that Mr Heraskevych intended to wear in competition a helmet displaying portraits of Ukrainian athletes who lost their lives in the war, which was considered as being inconsistent with the Olympic Charter and Guidelines on Athlete Expression. The IBSF decision was rendered in execution of an IOC decision of 10 February 2026, stating a violation of the Olympic Charter, which was not challenged in this application and remains in force.

The Sole Arbitrator appointed for this matter stated that she was fully sympathetic to Mr Heraskevych’s commemoration and to his attempt to raise awareness for the grief and devastation suffered by the Ukrainian people, and Ukrainian athletes because of the war.

She heard the arguments and examined the Athlete Expression Guidelines, which state that freedom of speech is a fundamental right of any athlete competing in the Olympic Games, but limit the right to express views during competitions on the field of play. The Sole Arbitrator found these limitations were reasonable and proportionate, considering that the other opportunities for athletes to raise awareness in mixed zones, in press conferences, on social networks, or in Mr Heraskevych’s case, wearing the helmet during four training runs.

The Sole Arbitrator noted that the goal of this was to maintain the focus of the Olympic Games on performances and sport, a common interest of all athletes, who have worked for years to participate in the Olympic Games, and who deserve undivided attention for their sporting performances and sporting success.

The Sole Arbitrator was bound by such proportionate rules and had no means to override them. As a consequence, the application was dismissed.

The Sole Arbitrator added that it was unfair to withdraw Mr Heraskevych’s accreditation in these circumstances and supported the decision of the IOC to return it.

The upholding by the CAS AHD of the IOC ban on the Ukrainian athlete has, unsurprisingly, met with criticism, including his legal team, who claim that the penalty was too severe, as it involved removing an athlete from the competition without any technical or safety violations.

On the other hand, the IOC had offered alternatives to the athlete, such as wearing a black armband or displaying the helmet in interview zones, but these had been rejected as insufficient by him.

A difficult balancing act!

EU investigations in the sports equipment sector

As part of a broader initiative to ensure fair competition within the sports equipment sector in the European Union (“EU”), the Directorate-General for Competition of the European Commission launched unannounced inspections (so-called “dawn raids”) of several ski equipment companies regarding possible violations of EU Competition Rules. In particular, regarding potential cartels and illegal price-fixing.

These investigations focus on potential violations of art. 101 of the Treaty on the Functioning of the European Union, which prohibits agreements that have as their object or effect the restriction, prevention or distortion of competition within the EU and which have an effect on trade between EU member states.

The investigations involve major industry players and, if found guilty, they could face fines of up to 10% of their annual world-wide turnover.

The investigations are currently at an early stage and could take several months to complete.

The British basketball case

Whilst on the subject of competition law and sport, we would also report briefly on this case, which is proceeding in the English High Court.

Background

Competition law is playing an increasingly active role in the regulation of sport at the national and the European Union levels.

An interesting and important case in point is the current litigation in the English High Court between the British Basketball Federation (“BBF”), Super League Basketball (“SLB”) and GBB League Ltd (“GBBL”).

BBF is the governing body of the sport in the United Kingdom, and is recognised, as such, by FIBA, the world governing body of the sport.

SLB, which was formed by nine of the leading clubs after the collapse, in 2024, of the British Basketball League (“the League”) operated the professional competition in 2024-2025, under an interim licence granted by the BBF, with an investment of more than £ 15 million (around € 17.25 million), to keep the League afloat.

GBBL is a United States-backed consortium, which, in March 2025, was awarded by the BBF a 15-year licence to operate the League from 2026.

The legal claims and counterclaims

SLB claims that the BBF:

–    has abused its dominant position under section 18 of the UK Competition Act 1998 (“the Act”) by refusing recognition and insisting on licensing as the only route to operate;

–    has entered into an anti-competitive agreement under section 2 of the Act by granting GBBL a 15-year licence that forecloses competition; and

–    acted irrationally and unfairly.

SLB is claiming damages of more than £ 10 million (around € 11.5 million) as well as declarations voiding the licence.

The BBF denies these claims and is arguing that licensing is essential to meet its regulatory duties and its FIBA obligations. The BBF is also counterclaiming that SLB and its clubs are themselves acting anti-competitively by boycotting the new structure.

GBBL denies any wrongdoing and claims that it competed openly and is capable of operating a sustainable league.

Legal analysis

Without wishing to prejudge, in any way, the outcome of this case, we would comment as follows.

As the sole FIBA-recognised governing body, the BBF clearly holds a dominant position in the relevant market. The key question is whether the BBF refusal to recognise SLB and the terms of the GBBL licence can, in line with the established jurisprudence, be justified as necessary and proportionate in the circumstances of the case. If not, this may amount to an abuse of a dominant position under section 18 of the Act.

Similarly, if the licence is found to restrict competition in its object or effect, it may contravene section 2 of the Act as a restrictive agreement.

An important case

Whatever happens, this case is an important one, as it raises fundamental questions about the extent to which competition law may constrain sports regulators, and whether the sport of basketball in the UK can restore its credibility to attract long-term investors, which it badly needs.

The case is in its early stages: pleadings have been filed and case management hearings are expected to take place later in the year.It will be interesting to see the outcome of the British basketball case.

Articles in this issue

We now turn our particular attention to some of the interesting articles which we publish in this issue of SLT.

On the sports law side, we would draw the attention of our readers to the article by Jennifer Norris and Jos Winstanley on Multi-club ownership – The changing approach of UEFA.

The authors introduce their subject in the following terms:

“The rise of multi-club ownership has become a defining feature of modern global football, with over 120 ownership groups now controlling more than 330 clubs worldwide. This rapid expansion has prompted significant regulatory and strategic responses across the football ecosystem. Governing bodies, such as UEFA, have been compelled to introduce new measures aimed at safeguarding the competitive integrity of their competitions, whilst clubs continue to explore and exploit the structural advantages that such ownership models can offer.

The UEFA regulations on multi-club ownership are not designed to prohibit common ownership of clubs outright, but rather to safeguard the integrity of its competitions. However, the last decade has witnessed a significant evolution in how these rules are applied. Starting with the well-known Red Bull case in 2017 and culminating, most recently, with decisions in 2023, 2024 and 2025, UEFA has shifted towards a stricter, more formalistic approach.

This tightening of the rules governing multi-club ownership is not confined to Europe: in a recent case before the Court of Arbitration for Sport (“CAS”), the exclusion of Club León from the FIFA Club World Cup 2025 was upheld, underscoring that FIFA, like UEFA, is now applying increasingly rigorous standards to common ownership in global competitions.

Looking ahead, further reforms are expected for the UEFA 2026-2027 competition cycle and beyond, with UEFA anticipated to refine its framework to balance fairness, transparency, and competitive integrity in the face of the rapid expansion of multi-club ownership.”

And they conclude their article as follows:

“The UEFA position on multi-club ownership remains in flux, and the regulatory landscape continues to present significant compliance risks for both clubs and owners/investors.

The shift away from a narrow assessment of “decisive influence” towards a broader focus on corporate and operational independence, combined with the earlier 1 March deadline and the prospect of further reform in the 2026-2027 and 2027-2028 cycles, has materially narrowed the scope for compliance whilst increasing uncertainty.

Regardless of the much-anticipated changes, clubs with shared ownership structures cannot afford to be reactive. Instead, they should be pro-active and adopt a forward-looking compliance strategy, prioritising governance reforms, structural separation, and contingency planning well in advance of potential qualification.”

We also publish Part two of the sports law articles by William Kennett on Does English football need an Independent Football Regulator?.

And by Ilmari Eskola on Evidentiary requirements in food contamination cases, the first part of which we published in the December 2025 issue of SLT.

On the sports tax side, we would mention the article by Pedro Sousa Machado and João Carneiro Gomes on Tax Residency in Portugal. In the introduction to their article, they outlines its scope as follows.

“Following a few practical situations that have arisen, we believe it would be useful to briefly explain the effects of applying the rules on tax residence in Portugal to certain taxpayers, namely professional football players and coaches, who frequently change their tax residence.

In this regard, we will begin by briefly highlighting the concepts of domicile and tax residence, which have different practical effects and implications for taxpayers.

The importance of these concepts lies in their relationship with the rules laid down in the Portuguese legislation that aims to attract tax residence to Portugal and, consequently, to tax taxpayers on a universal basis, even when the taxpayer is no longer, or has not been, a tax resident in Portugal.

After explaining the concepts and basic rules for the attribution of tax residence in Portugal, we will address the rules that are most relevant to the scope of our article, which are the rules that, in our opinion, constitute true anti-abuse rules that can have harmful tax consequences for taxpayers who transfer their tax residence to or from Portugal.

Finally, we will explore our understanding of the conflict between these rules and conventional international law when applied to this type of taxpayers who, for strictly professional reasons, frequently change their tax residence.”

And they reach the following conclusions.

“The purpose of this article was to briefly explain various tax contingencies that may be associated with changing tax residence to or from Portugal.

For this purpose, we began by recalling that a tax resident in Portugal is subject to the worldwide income taxation rule. We then explained that, in Portugal, there is partial tax residence, even if the taxpayer stays here for less than 183 days, he will be taxed on all income earned, regardless of where it is obtained. We also explained that this condition of partial tax residency applies from the first day of the taxpayer’s stay in Portugal.

We also explained the criteria required for a natural person to be considered a resident in Portugal and that, whenever a person changes their domicile to Portugal or outside this country, it is necessary to change the tax domicile in the Tax Authorities’ register in a timely manner.

Finally, the exceptions provided for in the art. 16(14) and (15) of the PITC, were addressed, explaining that a partial tax resident who remains in Portugal for more than 183 days, if he obtains income (from Portuguese or foreign sources) after leaving Portugal, he may be considered a resident of Portugal, again if he cannot prove that this income is taxed in his new country of residence. In this regard, we also discussed the rule set out in art. 16(16) of the PITC, which may give rise to situations of dual tax residence and how this problem can be resolved.

These rules, which attract tax residence to our country, must, therefore, be duly considered by players or coaches who, at a certain point in their careers, decide to come to Portugal or choose to stop working in Portugal.”

As you will see from the Table of Contents of this issue, we include, in addition to the articles highlighted above, a wide range of topical sports law and sports tax articles, which, we believe, will, once again, engage our readers’ attention and provide them with much “food for thought”.

As always, we would welcome and value our readers’ contributions in the form of articles and topical case notes and commentaries for our journal and also for posting on the SLT dedicated website https://sportslawandtaxation.com, which continues to go from strength to strength and covers important sports legal and tax developments and issues, also CAS media releases.

So, now read on and enjoy the March 2026 edition of SLT.

Dr. Rijkele Betten (Managing Editor)

Prof. Dr. Ian S. Blackshaw (Consulting Editor)

March 2026