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CAS 2025/A/11723 — Real Madrid C.F. v Union Européenne de Football Association (UEFA)

"Real Madrid v UEFA" · CAS upheld UEFA's minimum sanction on Real Madrid for a supporter's Nazi salute during a 2025 Champions League match.

What happened in Real Madrid v UEFA

During the 75th minute of the Arsenal v Real Madrid UEFA Champions League quarterfinal first leg on 8 April 2025, a Real Madrid supporter performed a Nazi salute in the away sector and was immediately removed and arrested. UEFA's Control, Ethics and Disciplinary Body fined Real Madrid EUR 15,000 and imposed a suspended ban on away ticket sales for one UEFA competition match, with a one-year probationary period, for breach of Article 14.2 of the UEFA Disciplinary Regulations. The UEFA Appeals Body dismissed Real Madrid's appeal on 4 July 2025. Real Madrid accepted liability but challenged proportionality, arguing mitigating factors — including its comprehensive internal disciplinary framework, the isolated and brief nature of the gesture, absence of media coverage, and its subsequent permanent expulsion of the supporter — warranted a reduced sanction. CAS dismissed the appeal, finding the sanction lenient rather than disproportionate. The panel held that Real Madrid's internal measures qualified as 'effective preventive measures' under Article 23(3) UEFA DR and were praiseworthy, but that the fine was already very low relative to the club's financial standing and Champions League revenues, the ticket-ban was the regulatory minimum, and the probationary period was the shortest permitted. The case matters because it clarifies the standard of CAS review of UEFA discriminatory-conduct sanctions and confirms that a club's financial capacity is a legitimate proportionality factor.

Procedural history of CAS 2025/A/11723

On 8 April 2025, a Real Madrid supporter performed a Nazi salute at the Arsenal v Real Madrid UEFA Champions League quarterfinal in London. UEFA opened disciplinary proceedings on 9 April 2025. On 28 April 2025, the UEFA CEDB fined Real Madrid EUR 15,000 and imposed a suspended one-match away ticket-sale ban with a one-year probationary period for breach of Article 14.2 UEFA DR. Real Madrid appealed to the UEFA Appeals Body on 2 June 2025, seeking a significant reduction of the sanction. The UEFA Appeals Body dismissed the appeal on 4 July 2025, confirming the CEDB decision and ordering Real Madrid to pay EUR 1,000 in proceedings costs. Real Madrid filed a Statement of Appeal with CAS on 29 August 2025, within the ten-day limit under Article 62.3 UEFA Statutes. The parties agreed to proceed on written submissions only. CAS was asked to reassess proportionality and reduce the sanction.

Key holdings in CAS 2025/A/11723

• A Nazi salute by a single supporter constitutes discriminatory conduct insulting human dignity under Article 14 of the UEFA DR, and the isolated nature of the act does not reduce the inherent gravity of the offence.
• A club's comprehensive internal disciplinary framework and prompt, severe sanctioning of the offending supporter constitute 'effective preventive measures' under Article 23(3) UEFA DR and are a mitigating circumstance.
• The absence of prior disciplinary offences does not constitute a mitigating factor; under Article 25 UEFA DR, prior violations are aggravating circumstances, and their absence merely precludes aggravation.
• A CAS panel has full de novo power under Article R57 CAS Code to review the proportionality of a sanction and may reduce it if disproportionate, but should not lightly 'tinker' with a well-reasoned decision that deviates only marginally from what the panel might itself impose.
• A club's financial standing and revenues from the competition in which the offence occurred are legitimate factors in assessing whether a financial sanction is proportionate and carries sufficient deterrent effect.

How the CAS panel reasoned

The panel adopted an intermediate standard of review: full de novo power under Article R57 CAS Code, with due regard to the disciplinary body's expertise, but no inhibition on reducing a sanction found to be disproportionate. It declined to apply the stricter 'evidently and grossly disproportionate' threshold urged by UEFA, citing CAS 2017/A/5003 and endorsing the approach in CAS 2022/A/8651 and CAS 2020/A/7596. The panel identified Real Madrid's internal framework and permanent expulsion of the supporter as genuine mitigating factors under Article 23(3) UEFA DR. It rejected the argument that limited match impact was mitigating, reasoning that crowd disturbance would have been a separate aggravating offence under Article 16.2(h). It found Annex A of the UEFA DR inapplicable to Article 14.2 offences, given the fundamentally different nature of discriminatory conduct. On the financial component, the panel accepted that Real Madrid's revenues — approximately EUR 1.045 million in 2023-2024 — and its Champions League participation made EUR 15,000 a very modest fine. Comparing the sanction with cited UEFA precedents (fines of EUR 5,000–30,000), the panel found no material divergence. Ultimately, since only the fine could theoretically be reduced — the ticket ban and probationary period were already at the regulatory minimum — any reduction would constitute mere 'tinkering' with a justified decision concerning a disgracefully racist gesture.

Why Real Madrid v UEFA matters in CAS jurisprudence

The award clarifies that CAS applies a de novo but restrained standard when reviewing UEFA discriminatory-conduct sanctions, declining to 'tinker' with minimum-level penalties for Nazi salute incidents. It confirms that a club's financial capacity and competition revenues are legitimate proportionality factors, and that a club's own exemplary internal disciplinary response — including permanent membership revocation — qualifies as a mitigating 'effective preventive measure' under Article 23(3) UEFA DR, even if insufficient to reduce an already-minimum sanction.

Cases cited in this award

CAS 2022/A/9282 CAS 2021/A/8014 CAS 2018/A/6239 CAS 2016/A/4595 CAS 2022/A/8651 CAS 2017/A/5003

Frequently asked questions about Real Madrid v UEFA

Why did CAS refuse to reduce Real Madrid's fine even though the Nazi salute was by a single supporter?

The panel found that the fine of EUR 15,000 was already very low relative to Real Madrid's revenues of approximately EUR 1.045 million in 2023-2024 and its Champions League participation, making it lenient rather than disproportionate. The ticket-ban was already the regulatory minimum under Article 14.2 UEFA DR, and reducing the fine — for example to EUR 7,500 or EUR 10,000 — would constitute mere 'tinkering' with a well-reasoned decision concerning a disgracefully racist gesture.

Did Real Madrid's permanent expulsion of the supporter count as a mitigating factor in the CAS proceedings?

Yes, but only partially. The panel held that Real Madrid's internal disciplinary framework and its prompt imposition of the most severe available sanction — permanent revocation of membership — constituted 'effective preventive measures' under Article 23(3) UEFA DR and were praiseworthy mitigating circumstances. However, because the UEFA sanction was already at the minimum level, these mitigating factors were deemed to have been fully reflected in the suspended ticket-ban and minimum probationary period, leaving no room for further reduction.

What standard of review did the CAS panel apply when assessing the proportionality of the UEFA sanction in Real Madrid v UEFA?

The panel adopted an intermediate approach: it confirmed full de novo review power under Article R57 CAS Code, meaning it could reduce a sanction it found simply 'disproportionate' rather than requiring it to be 'evidently and grossly disproportionate.' However, citing CAS 2017/A/5003 and CAS 2010/A/2283, it held that it would not lightly 'tinker' with a well-reasoned sanction adopted in pursuit of a legitimate regulatory objective, particularly where any change would be only marginal.

Does Annex A of the UEFA Disciplinary Regulations apply to Nazi salute cases under Article 14.2?

No. The panel held that Annex A sets out a closed list of offences all relating to Article 16.2 UEFA DR and does not govern Article 14 offences. Article 14.2 expressly prescribes its own minimum sanction, and the fundamentally different — and more serious — nature of discriminatory conduct means Annex A provides no appropriate benchmark for proportionality assessment in such cases.

Topics: Doping, ethics & governance at CAS

Source: official award. This digest was generated by LexXi from the full award text and machine-verified against it — every figure, article and citation above appears in the source. It is an editorial summary, not legal advice. See how ElevenLex verification works.