THE AUTHOR:
Mohammad Hajj, Global Partnerships and Legal Publications Intern at Jus Mundi
On 11 June 2026, the largest FIFA World Cup in history began across the United States, Mexico, and Canada. 48 teams, 16 host cities, and three host countries are now producing the most complex tournament FIFA has ever staged. While the tournament unfolds on the pitch, some of its most consequential decisions may be made off it. The Court of Arbitration for Sport (“CAS”) Ad Hoc Division stands ready to resolve urgent tournament disputes within 48 hours, ensuring that legal remedies remain meaningful in the fast-moving context of the competition.
The legal framework governing this tribunal is the CAS Arbitration Rules 2026 for the FIFA World Cup 26 Final Competition, adopted by the International Council of Arbitration for Sport (“ICAS”) on 13 April 2026. These rules apply exclusively to disputes arising between 11 June and 19 July 2026 and cease to have effect the moment the tournament ends.
The CAS Ad Hoc Division exists because ordinary litigation operates on a timeline incompatible with tournament sport. A decision that arrives after a player has missed a decisive match, or after a team has been eliminated, retains no practical value. The division ensures that arbitral relief remains meaningful within the tournament’s compressed timeframe, where legal effect and sporting effect must coincide.
A Court Built for Tournament Time
The CAS Ad Hoc Division was first created for the Atlanta Olympic Games in 1996. Its logic was simple: some sports disputes cannot wait for the ordinary pace of courts or arbitral proceedings. The model was later extended to other major sporting events, including the FIFA World Cup.
For the World Cup, CAS established a dedicated Ad Hoc Division for the first time during the 2006 tournament in Germany. Unlike the Olympic model, which traditionally works on a 24-hour deadline, the World Cup rules give the panel 48 hours from receipt of the application to issue a decision, in principle. That longer period reflects the complexity of football disputes, which may involve FIFA regulations, disciplinary rules, eligibility requirements, national associations, clubs, and tournament-specific procedures.
Unlike permanent arbitral institutions, the Ad Hoc Division is established for each tournament and ceases to exist when it ends. During that narrow window, it functions as a fast-track arbitral mechanism for urgent disputes arising in connection with the World Cup.
How the 48-Hour System Works
The 48-hour deadline defines the entire procedure. Within that period, the panel must receive the application, assess jurisdiction, consider the parties’ submissions, hold a hearing, if necessary, deliberate, and issue a binding decision. Only in exceptional circumstances may the President extend the time limit.
Applications are filed electronically with the CAS Court Office. The President appoints either a sole arbitrator or a three-member panel from the CAS football list, rather than allowing parties to nominate arbitrators, since party selection would consume the time that the procedure does not have.
Hearings may be held by videoconference or telephone. The panel may also render its decision without a hearing if it considers the record sufficiently complete. In urgent situations, interim relief may be granted, including a stay of the challenged decision. The costs of the proceedings are borne by the parties according to Article 23 of the Ad Hoc Rules, with specified exceptions.
The legal seat is Lausanne, Switzerland, with the panels applying FIFA regulations first and Swiss law additionally. The result is final and binding with immediate effect and no ordinary appeal. Tournament justice must arrive before the tournament moves on.
While the Ad Hoc Division’s core procedures have remained unchanged since its introduction, the rules governing the 2026 World Cup contain targeted refinements that shed light on FIFA’s evolving institutional priorities.
What Changed Between 2022 and 2026?
A comparison between the 2022 Arbitration Rules applicable to the CAS Ad Hoc Division for the FIFA World Cup Qatar 2022 and the 2026 Arbitration Rules applicable to the CAS Ad Hoc Division for the FIFA World Cup 2026 shows that the revision is not a redesign of the CAS Ad Hoc Division, but a targeted clarification. Three changes matter:
- Article 1 now expressly recognizes participating associations.
In 2022, the Ad Hoc Division existed to serve “the interests of the athletes and of sport.” In 2026, that purpose clause was expanded to include “the interests of the athletes, Participating FIFA Member Associations and of sport.”
Legally, this does not necessarily create new jurisdiction. Associations could already appear before CAS where the jurisdictional conditions were met. But the change is still important: it makes express that participating associations have direct legal and sporting interests in urgent World Cup disputes. - The Rules update their institutional vocabulary.
References to “National Federations” in the 2022 Rules are replaced in the 2026 Rules by terminology referring to participating associations.
This change achieves two goals: it identifies more precisely which entities can access the Ad Hoc Division, and aligns the Rules with FIFA’s official World Cup structure. “Participating associations” more accurately describes the national federations with actual stakes in the tournament, a distinction that becomes critical in an expanded 48-team competition. - Article 20 adopts more precise arbitral terminology.
The 2022 Rules allowed the panel to communicate “the holding of the award” before issuing the full reasons. The 2026 Rules replace that phrase with “the operative part of the award.”
This is a technical but useful correction. The operative part is the dispositive section of the award, the part that states what the tribunal actually decides, orders, grants, or rejects. In a tournament setting, it is the part that the parties need immediately.
In short, the 2026 Rules do not remodel the system. They refine its language, update its statutory references, and expressly recognize participating associations as stakeholders in World Cup arbitration.
Why the Addition of Participating Associations Matters?
The 2026 expansion of Article 1 to expressly recognize “Participating FIFA Member Associations” is best understood as a clarification rather than a jurisdictional expansion. Associations were already able to appear before CAS where jurisdiction existed; what changed is explicit recognition of their role.
This matters because national associations are the parties most directly affected by World Cup disputes. They select squads, register players, and face consequences when players are declared ineligible or when sanctions are imposed. Although a dispute may concern an individual athlete, its legal and sporting consequences often fall upon the relevant national association.
In an expanded 48-team World Cup with more associations and more potential conflicts, this clarification better describes the institutional reality of competition. The amendment does not transform the Ad Hoc Division into a general federation forum, but recognizes that World Cup disputes are institutional, competitive, and national in nature.
Olympic Caseloads as a Benchmark for World Cup Ad Hoc Arbitration
Olympic caseloads provide the strongest benchmark for understanding how the CAS Ad Hoc Division operates under tournament pressure. Since the model was first created for the Olympic Games and later extended to the FIFA World Cup, Olympic experience remains the clearest reference point for assessing speed, volume, and procedural intensity in major international competitions. The Olympic Games have also consistently generated the highest Ad Hoc Division caseloads: the 2016 Rio Olympics set a record with 28 cases, many involving Russian athletes challenging doping-related ineligibility rulings, while the 2022 Beijing Winter Olympics saw a combined total of 12 cases heard by the CAS Ad Hoc and Anti-Doping Divisions.
One of the earliest demonstrations of the system’s capacity for speed came at the London 2012 Olympics. In Joseph Ward v. IOC, AIBA & ANOC (CAS OG 12/002), the Ad Hoc Division resolved an eligibility dispute and delivered a binding ruling within hours of the application being filed. That same year, a sailing dispute was decided in just 3 hours and 45 minutes, the panel issuing its decision before the race could begin. Together, these cases illustrated a core principle of the system: the decision must arrive before the sporting moment it is meant to protect has passed.
At the Paris 2024 Olympics, the CAS Ad Hoc Division decided the dispute arising out of the women’s floor exercise final, Romanian Gymnastics Federation & Ana Bărbosu v. Fédération Internationale de Gymnastique & Jordan Chiles.The case centred on whether the inquiry submitted on Chiles’ behalf, which increased her score and moved her into the bronze-medal position, had been filed within FIG’s one-minute deadline. The CAS panel found that the inquiry had been submitted 4 seconds late and reinstated the original ranking, which resulted in Chiles losing the bronze medal. The Swiss Federal Supreme Court later set aside the CAS award, not because it re-assessed the scoring or the timing issue itself, but because of procedural fairness concerns in the arbitration, including whether Chiles had been given a proper opportunity to be heard and to present evidence on the decisive timing question. The case remains one of the clearest examples of what can go wrong when procedural deadlines are measured in minutes.
The Boundary: What the CAS Ad Hoc Division Does Not Do
The CAS Ad Hoc Division offers expedited dispute resolution, but its jurisdiction and powers are not without limits.
It does not review every controversy arising during a World Cup. Field-of-play decisions, including refereeing and VAR decisions, are not subject to arbitral review unless exceptional circumstances exist, such as bad faith, corruption, or a fundamental procedural violation. The France v. Tunisia VAR controversy at Qatar 2022 illustrates the point clearly. The French Football Federation filed a formal complaint with FIFA after Antoine Griezmann’s stoppage-time goal was disallowed following VAR intervention after the final whistle. FIFA ultimately dismissed the complaint and maintained the result, and the matter never reached CAS.
The threshold question is always whether the dispute arises “during and in connection with” the final competition. A dispute that falls outside that window, or outside the scope of Article 50 of the FIFA Statutes, will not be admitted. Luis Suárez, FC Barcelona & AUF v. FIFA (CAS 2014/A/3665) illustrated this boundary. Despite the bite occurring during the 2014 World Cup, the proceedings followed the regular CAS appeals process rather than the Ad Hoc route, because the FIFA disciplinary procedure was not completed within the tournament window.
World Cup-Related CAS Arbitration Beyond the Ad Hoc Division
Not every World Cup-related CAS case is a CAS Ad Hoc Division case. Some of the most important disputes around recent tournaments proceeded as ordinary CAS appeals, rather than under the 48-hour World Cup mechanism. They remain relevant because they show the types of actors and interests that World Cup arbitration often involves, especially national associations, clubs, and players whose legal positions are directly affected by FIFA decisions.
Chilean Football Federation and Peruvian Football Federation v. Ecuadorian Football Federation and FIFA –CAS 2022/A/9175 and CAS 2022/A/9176
Chile and Peru challenged Ecuador’s fielding of Byron Castillo during the Qatar 2022 qualifiers, alleging that his registration was based on irregular nationality documentation.
CAS held that Castillo was eligible to represent Ecuador under the applicable FIFA rules because his Ecuadorian nationality had been formally recognized by the competent national authorities. Ecuador, therefore, retained its place at Qatar 2022. However, CAS sanctioned the Ecuadorian Football Federation for the use of a document containing false information, imposing a CHF 100,000 fine and a three-point deduction in the next FIFA World Cup preliminary competition, which was applied to the 2026 World Cup qualifiers.
The case illustrates the institutional structure of World Cup disputes: although the eligibility issue concerned a player, the proceedings were brought and defended by national associations whose qualification interests were directly at stake.
Mexican Football Federation v. FIFA – CAS 2025/A/11268 & CAS 2025/A/11512
In a decision issued on 2 June 2026, nine days before the 2026 World Cup began, CAS reviewed two sets of FIFA disciplinary sanctions imposed on the Mexican Football Federation (“FMF”) for repeated use of a homophobic chant by Mexican supporters during international matches in 2024. FIFA had imposed cumulative fines and a partial stadium closure sanction.
CAS upheld the fines in full, confirming the FMF’s legal responsibility for supporter conduct during its matches. It overturned the stadium closure, however, finding it disproportionate in the circumstances.
The case illustrates two principles relevant to the 2026 World Cup. First, national associations bear direct legal responsibility for the conduct of their supporters, the fact that the FMF did not itself use the chant was no defence. Second, CAS will scrutinise the proportionality of FIFA sanctions even where the underlying violation is established and will modify them where they exceed what the facts justify. In a tournament co-hosted by Mexico, the ruling arrived with immediate practical relevance and a direct warning.
Together, these cases illustrate why the 2026 CAS Ad Hoc Rules now expressly refer to participating associations. In both disputes, it was not an individual athlete who bore the legal consequences, it was the national federation. Ecuador’s federation was sanctioned for a registration document it submitted. Mexico’s federation was held responsible for a chant its supporters used. World Cup disputes, as these cases show, are institutional in nature. The 2026 rules recognize that reality.
They also point to a broader principle: CAS involvement in World Cup matters extends well beyond the 48-hour window. Some of the most consequential rulings connected to the tournament are decided months before the opening match, through ordinary CAS proceedings. The Ad Hoc Division is the most expedited part of the CAS system for resolving World Cup-related disputes, but it is only one part of a broader arbitral framework.
Conclusion
The CAS Ad Hoc Division for the FIFA World Cup is temporary, compressed, and exceptional, but its decisions may carry immediate sporting consequences. Between 2022 and 2026, its core architecture remained unchanged: the 48-hour deadline, Lausanne seat, and finality of awards all remain in place. What changed is the language. By expressly recognizing participating associations, the 2026 CAS Ad Hoc Rules make clear that World Cup disputes are not only about athletes or sport in the abstract. They are also institutional, competitive, and national. In a 48-team tournament, that clarification may matter when CAS has only 48 hours to decide whether legal protection arrives in time.
ABOUT THE AUTHOR
Mohammad Hajj is an intern at Jus Mundi, working with the Global Partnerships and Legal Publication teams. He holds an LL.M. in International Economic Law from Toulouse Capitole University, as well as a double bachelor’s in Law ( Lebanese University) and International Economic Business (Lebanese International University (“LIU”)).
Mohammad served as Editor-in-Chief of Cedars Football Clue, a platform dedicated to football and sports law in the MENA region. He also gained practical legal experience across law firms in Lebanon, working on matters spanning commercial law, dispute resolution, and contract drafting. His areas of focus include international law, arbitration, legal publishing, and sports-related legal developments.
*The views and opinions expressed by authors are theirs and do not necessarily reflect those of their organizations, employers, or Daily Jus, Jus Mundi, or Jus Connect.
