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CAS 2025/A/11270 — Fédération Royale Marocaine de Football v. FIFA

"FRMF v. FIFA (Paris 2024 OFT)" · CAS upheld FIFA's CHF 44,500 fine on Morocco's football federation for supporter misconduct across five Paris 2024 Olympic Football Tournament matches.

What happened in FRMF v. FIFA (Paris 2024 OFT)

The Fédération Royale Marocaine de Football (FRMF) appealed a CHF 44,500 fine imposed by the FIFA Appeal Committee for supporter misconduct — including 33 pyrotechnic incidents, 6 instances of object-throwing, 1 pitch invasion, 3 instances of disorder, and 1 laser-pointer use — across five Men's Olympic Football Tournament (OFT) matches at the Paris 2024 Olympics (Ukraine, Iraq, USA, Spain, and Egypt). The FRMF argued that FIFA lacked jurisdiction because the OFT was organized by the IOC/Paris Organizing Committee, that the spectators were not its 'supporters' in the disciplinary sense, and that the fine was disproportionate given its total absence of operational control. FIFA countered that the OFT Regulations expressly incorporated the FIFA Disciplinary Code (FDC), that strict liability under Article 17(2) FDC applied regardless of fault, and that the fine was calculated per incident in line with Annex 1 of the FDC. The CAS Panel dismissed the appeal in full, confirming the Appealed Decision. The case matters because it is the first CAS award squarely holding that FIFA's strict-liability regime for supporter misconduct applies to Olympic Football Tournament matches, even where the national association had no operational control over ticketing, security, or logistics, and even where the team was formally entered by the National Olympic Committee.

Procedural history of CAS 2025/A/11270

On 5 September 2024, the FIFA Disciplinary Committee (reference FDD-19087) found the FRMF strictly liable under Article 17(2) FDC for supporter misconduct across five OFT matches and imposed a fine of CHF 49,500. The FRMF appealed on 18 October 2024, challenging both the legal basis and the quantum. On 12 December 2024, the FIFA Appeal Committee (reference FDD-19662) partially upheld the appeal, reducing the fine to CHF 44,500 and ordering the FRMF to bear CHF 1,000 in proceedings costs. The grounds were notified on 26 February 2025. On 19 March 2025, the FRMF filed its Statement of Appeal at CAS under Article R48 of the CAS Code, seeking annulment of the fine or, subsidiarily, its reduction to a warning or reprimand. A hearing was held by videoconference on 19 September 2025.

Key holdings in CAS 2025/A/11270

• FIFA possessed a valid legal basis to assert disciplinary jurisdiction over the OFT and to apply the FDC to incidents at the Paris 2024 Olympics, because the OFT Regulations expressly incorporated the FDC and the Olympic Charter's Rule 46(1) entrusts each IF with control and direction of its sport at the Games.
• By entering its qualified national team in the OFT, the FRMF automatically undertook to observe and comply with the OFT Regulations and the FDC, at least by tacit adhesion, regardless of whether the signed entry form was produced in evidence.
• Individuals wearing Moroccan colors, positioned in sections designated for Moroccan fans, and igniting flares timed to Moroccan goals and the national anthem qualify as 'supporters' of the FRMF within the meaning of Article 17(2) FDC, assessed from the standpoint of a reasonable and objective observer.
• Article 17(2) FDC imposes strict liability on all associations — not only hosts — for the inappropriate behavior of their supporters, and the FRMF's lack of operational control over the Olympic venue does not exempt it from that liability.
• The fine of CHF 44,500, calculated per incident in line with Annex 1 of the FDC, is neither excessive nor disproportionate given the recurrent and systemic nature of the misconduct across five matches, and the FRMF's failure to take any proactive preventive measures after the earlier Argentina match constitutes an aggravating factor.

How the CAS panel reasoned

The Panel conducted a de novo review under Article R57(1) of the CAS Code, applying a comfortable-satisfaction standard of proof. On jurisdiction, it read Rule 46(1) of the Olympic Charter together with Articles 1(1), 3(1), and 8(1)/(4) of the OFT Regulations and Article 2(1) of the FDC to conclude that FIFA, as the responsible IF, had both the authority and the regulatory framework to discipline OFT participants. It rejected the argument that competition-specific rules were required, holding that the FDC is integrated into the OFT Regulations by explicit cross-reference. On attribution, the Panel applied the broad, functional definition of 'supporter' from CAS 2007/A/1217 and CAS 2015/A/3874, finding that objective indicators in the undisputed Match Reports — Moroccan colors, flag displays, flares timed to Moroccan goals — were sufficient. It also invoked the doctrine of venire contra factum proprium against the FRMF, which had publicly promoted the team as its own. On strict liability, the Panel followed CAS 2013/A/3094 and CAS 2002/A/493, confirming that Article 17(2) FDC expressly removes fault from the inquiry. On proportionality, it identified the recurrence of incidents across five matches and the FRMF's complete inaction after the Argentina match as aggravating factors, and found no mitigating factors, rejecting the Olympic context as insufficient to reduce the sanction.

Why FRMF v. FIFA (Paris 2024 OFT) matters in CAS jurisprudence

This award establishes, for the first time in CAS jurisprudence, that FIFA's strict-liability regime under Article 17(2) FDC extends to supporter misconduct at Olympic Football Tournament matches, notwithstanding the IOC's overarching organizational authority. It confirms that a national football association's complete lack of operational control over an Olympic venue is irrelevant to liability, and that failure to take proactive preventive measures after earlier incidents in the same tournament constitutes an aggravating factor at the sanctioning stage.

Cases cited in this award

CAS 2007/A/1217 CAS 2009/A/1944 CAS 2011/A/2670 CAS 2012/A/2802 CAS 2013/A/3090 CAS 2013/A/3094

Frequently asked questions about FRMF v. FIFA (Paris 2024 OFT)

Did CAS uphold FIFA's fine on Morocco for fan trouble at the Paris 2024 Olympics?

Yes. In CAS 2025/A/11270, the Panel dismissed the FRMF's appeal in full and confirmed the FIFA Appeal Committee's decision imposing a fine of CHF 44,500. The fine covered 33 pyrotechnic incidents, 6 instances of object-throwing, 1 pitch invasion, 3 instances of disorder, and 1 laser-pointer use across five OFT matches.

Can FIFA sanction a national football federation for fan misconduct at Olympic Games matches it did not organize?

According to CAS 2025/A/11270, yes. The Panel held that Article 17(2) of the FIFA Disciplinary Code imposes strict liability on all associations — not only hosts — for the inappropriate behavior of their supporters, and that the FRMF's lack of operational control over the Olympic venue did not exempt it from liability. By entering its qualified national team in the OFT, the FRMF automatically undertook to comply with the FDC.

How did CAS define 'supporters' in the FRMF v. FIFA Olympic case?

The Panel applied the broad, functional definition from CAS 2007/A/1217 and CAS 2015/A/3874, holding that 'supporter' extends to any individual whose conduct, appearance, or behavior objectively demonstrates support for a particular team, regardless of formal membership or legal ties. Indicators such as wearing Moroccan colors, displaying Moroccan flags, and igniting flares timed to Moroccan goals were sufficient to establish the requisite affiliation.

Was the CHF 44,500 fine on Morocco reduced by CAS given the Olympic context?

No. The Panel found no mitigating factors capable of justifying a reduction. It noted that the FRMF had taken no proactive measures — no communications to supporters, no requests for stricter entry controls, no contact with organizers — after similar incidents had already occurred in the earlier Argentina v. Morocco match. This inaction was treated as an aggravating factor, and the fine was confirmed as proportionate and consistent with Annex 1 of the FDC.

Topics: Doping, ethics & governance at CAS

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