Are the FIFA Football Agent Regulations Still in Force? (2026)

Updated 2026-08-19

Short answer

Parts of the FIFA Football Agent Regulations (FFAR) have been suspended worldwide since FIFA Circular 1873 (30 December 2023), and the CJEU judgments of 9 and 16 July 2026 did not reinstate them. The exam and the licence requirement remain fully in force; the suspended parts are the service fee cap and a list of service-fee, double-representation, reporting, publication and submission rules.

The short version

Yes, the FFAR are still in force — but not in full. Since December 2023, FIFA has suspended specific contested provisions worldwide while European courts rule on them. The core of the framework, including the licence requirement and the exam, was never suspended and remains fully applicable.

How we got here

The Court of Arbitration for Sport (CAS) upheld the FFAR in July 2023, rejecting an initial legal challenge.

That wasn't the end of it: on 24 May 2023 the Landgericht Dortmund granted a preliminary injunction in case 8 O 1/23 (Kart), requiring FIFA to suspend the application and enforcement of a specific list of FFAR provisions on competition-law grounds. That injunction, and not any English or Spanish decision, is the cause FIFA itself cites.

In response, FIFA issued Circular 1873 on 30 December 2023: the Bureau of the FIFA Council approved the worldwide temporary suspension of the provisions targeted by the injunction, until the Court of Justice of the European Union (CJEU) renders a final decision. The list is wider than the fee cap. In the circular's own wording it also covers the rules concerning service fee payments (Art. 14(6), (8), (11)), the client pays rule (Art. 14(2), (10)), the timing of service fee payments (Art. 14(7), (12)), the prohibition of double representation (Art. 12(8)-(10)), the reporting obligations (Art. 16(2)(h), (j), (k) and (4)), disclosure and publication (Art. 19), the submission rule (Art. 4(2); Art. 16(2)(b); Art. 3(2)(c) and (d); Art. 20; Art. 21) and payment via the FIFA Clearing House (Art. 14(13)). The circular also recommends that member associations suspend the equivalent national provisions "unless they conflict with mandatory provisions of the law applicable in their territory" — which is why national ceilings such as the French 10% of Article L222-17 of the Code du sport keep applying.

Where the CJEU cases stand — judgments delivered in July 2026

The CJEU has now ruled, in two separate judgments a week apart. On 9 July 2026 it decided C-428/23, ROGON and Others (press release no. 99/26), on a reference from the German Federal Court of Justice; that case concerned the DFB's own 2015 agent regulations, not the FFAR. On 16 July 2026 it decided C-209/23, RRC Sports (press release no. 110/26), on a reference from the Landgericht Mainz; that is the FFAR case. The two were not joined.

Neither judgment settles anything on its own. A preliminary ruling gives the national court the criteria and sends the case back. In RRC Sports the Court held that it is ultimately for the referring court to assess whether the contested FIFA rules are contrary to the prohibition of cartels or may be justified. It singled out one rule as appearing, in any event, incompatible with that prohibition: the ban on approaching or signing a client already bound by an exclusive representation agreement outside the two-month window before expiry (Art. 16(1)(b) and (c)), because it does not bind the incumbent agent. It also held that the GDPR precludes a federation such as FIFA disclosing and publishing any sanction imposed on agents or their clients and detailed information on all transactions involving agents. It made no finding that the service fee cap is a restriction by object — which is not the same thing as validating the cap.

A judgment is not a reinstatement. FIFA welcomed the decision the same day and said it intended to invite agent representatives to a meeting in the coming weeks; it announced no reinstatement of the suspended provisions. As of 19 August 2026 we have found no FIFA circular lifting the suspension of Circular 1873 — but we were not able to consult the official register of circulars, so check inside.fifa.com before relying on that.

FFAR legal status — what's in force vs. suspended
AreaStatus
Licence requirementFully in force
FIFA agent examFully in force
Commission / fee capSuspended worldwide since FIFA Circular 1873 (30 Dec 2023)
Service-fee payment, double representation, reporting, publication, submission, Clearing HouseSuspended worldwide since Circular 1873 — not reinstated
CJEU judgmentsDelivered: C-428/23 ROGON 9 July 2026, C-209/23 RRC Sports 16 July 2026 — both send the assessment back to the national courts

What this means if you're preparing for the exam

The parts under legal dispute are commercial — fee caps and service-fee mechanics — not the licensing system itself. The exam content, the licence requirement, and the regulatory structure candidates are tested on remain applicable and aren't affected by the suspension.

The CJEU has now ruled (9 and 16 July 2026) and the suspension is still standing. This page will be updated the day FIFA issues a circular reinstating the suspended provisions — and note that where a suspended FIFA rule has a national equivalent that is mandatory law, such as the 10% ceiling of Article L222-17 of the French Code du sport, that national rule keeps applying regardless.

Sources

Frequently asked questions

Are the FIFA Football Agent Regulations still valid in 2026?

Yes, for the most part. The licence requirement and the exam are fully in force. A specific list of provisions — the service fee cap, the service-fee payment rules, the client pays rule, the ban on double representation, the reporting obligations, disclosure and publication, the submission rule and the Clearing House rule — has been suspended worldwide since FIFA Circular 1873 (30 December 2023). The CJEU judgments of July 2026 did not reinstate them; the underlying disputes are back before the national courts.

Why were parts of the FFAR suspended?

Because of a German court. On 24 May 2023 the Landgericht Dortmund granted a preliminary injunction (case 8 O 1/23 (Kart)) requiring FIFA to suspend a specific list of FFAR provisions. Rather than run two regimes, FIFA suspended them worldwide by Circular 1873. The list covers the service fee cap (Art. 15(1)-(4)), service-fee payment rules and their timing, the client pays rule, the ban on double representation, the reporting obligations, disclosure and publication, the submission rule and payment via the FIFA Clearing House.

Has the CJEU ruled yet, and does that end the suspension?

It has ruled, and no, it does not. The Court decided C-428/23 ROGON on 9 July 2026 and C-209/23 RRC Sports on 16 July 2026. Both are preliminary rulings: they give the national courts the criteria and send the cases back rather than deciding them. In RRC Sports the Court identified only one rule as appearing in any event incompatible with the prohibition of cartels — the two-month window for approaching a client under an exclusive agreement — and made no finding that the fee cap is a restriction by object. A judgment is not a reinstatement: as of 19 August 2026 we have found no FIFA circular lifting the suspension.

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