On 24 March 2026, Football Supporters Europe (a not-for-profit international football fan association) and Euroconsumers (an international consumer protection organisation) (the “Complainants”) filed a complaint against FIFA with the European Commission. The Complainants allege that, contrary to Article 102 TFEU, FIFA has abused its dominant market position to facilitate unfair and anti-competitive ticketing practices for the upcoming 2026 World Cup (the “Complaint”). FIFA has not publicly responded to the Complaint.
The Complaint illustrates the competing tensions between the expectations of fans and consumers and a sports governing body’s commercial interests. In this blog, we outline the background of the Complaint, consider the specific grounds raised and remedies sought, and explore the potential broader implications for fans, FIFA and the wider sports industry.
Background: FIFA’s role
FIFA is the sole organiser and primary ticket seller for the 2026 World Cup, which is to be co-hosted by the USA, Canada and Mexico. The CJEU confirmed in its recent European Super League judgment (2023) that FIFA and UEFA hold a dominant position in the organisation and marketing of interclub and international football competitions.
The 2026 World Cup has generated widespread public discourse in relation to ticket pricing. The Complainants argue that the pricing structure prioritises revenue generation over fan accessibility, drawing a contrast with UEFA’s pricing models for interclub and international competitions which are significantly cheaper.
Grounds of the Complaint
The Complainants allege that FIFA abused its dominant position in the market (i.e., the EEA) for organisation and sale of tickets for the 2026 World Cup on the following grounds:
- Opacity: FIFA is alleged to have withheld material information, including ticket availability data, seat allocation details and seat category boundaries, from consumers during the purchasing process, allegedly in breach of its obligations under EU consumer protection law.[1] It is alleged that in a normally competitive market, FIFA would not have been able to impose such commercial practices.
- Dynamic pricing: FIFA is alleged to have operated a demand-based variable pricing model without effective price caps, under which prices for certain matches increased by approximately 25% between the different sequential windows through which FIFA structured its ticket sales. Again, it is alleged that in a normally competitive market, FIFA would not have been able to impose such uncontrolled price volatility.
- Excessive pricing: FIFA’s ticket prices are allegedly excessive –that is, they bear no reasonable relation to the economic value of the product supplied, which is the established threshold for excessive pricing under the CJEU’s United Brands test (1978).By way of illustration, the cheapest ticket to the final is reportedly priced at $4,185, compared with a Category 1 projection of $1,550 in FIFA’s original bid documents. The Complainants say that FIFA is only able to engage in such abuses because of the monopoly it has enjoyed for decades.
- Bait advertising: FIFA marketed $60 tickets despite there allegedly being extremely limited availability at that price point, with the relevant inventory largely exhausted before general public sales opened. The Complainants characterise this as “bait advertising” prohibited under the UCPD.
- Dark patterns: FIFA’s consumer communications, which emphasised “exclusive” access and “extremely limited” availability, are alleged to have been designed to create artificial urgency and unduly influence purchasing decisions.
- Secondary market abuse: FIFA is alleged to have leveraged its dominant position in the primary ticketing market to extend its influence into the secondary market. It is said to have engaged in both exclusionary abuse (by engaging in a campaign using coercion and undue influence in breach of the UCPD to market its own resale platform as the only “official and secure” option for secondary sales) and exploitative abuse (by itself charging transaction fees of 15%).
Remedies sought
In the short term, the Complainants seek the immediate imposition of interim measures under Article 8 of Regulation 1/2003, calling on the Commission to: (i) make a prima facie finding of infringement against FIFA by way of abuse of dominant position; (ii) halt the use of variable pricing for all tickets sold to residents of the EEA for the remainder of the 2026 World Cup sales cycles; (iii) cap ticket prices for remaining sales at the ‘Standard Tier’ levels announced in December 2025; and (iv) require FIFA to publish the remaining number of tickets per category and exact seat locations 48 hours before the remaining ticket sales windows open.
The Complainants further seek a decision from the Commission (i) confirming that FIFA abused its dominant position by imposing excessive pricing and unfair purchasing conditions, and (ii) identifying and quantifying the damage caused to European consumers and supporters. For future editions of the tournament, the Complainants seek mandatory price transparency, caps on dynamic pricing, guaranteed minimum seat supply per category, and a prohibition on manipulative commercial practices.
Next steps
The Commission will examine the complaint but is not obliged to open an investigation and is yet to confirm whether it intends to do so. The Commission has discretion over whether to allocate its enforcement resources to a given case, applying a threshold of sufficient “EU interest” assessed by reference to factors including the cross-border effects of the alleged infringement, its gravity and impact on the internal market, whether it raises novel points of EU competition law or policy, and whether the Complainants’ rights could be adequately safeguarded by national courts or authorities.
If the Commission does take up the case, the standard procedural pathway – evidence-gathering, a statement of objections, a hearing and ultimately a decision (with the possibility of substantial fines) – could take years, which is far longer than the timeframe in which the Complainants seek relief. That is the central challenge.
The Commission aims to indicate how it intends to proceed within four months of receiving a complaint, but the interim relief the Complainants are seeking – price caps and inventory disclosure for remaining 2026 World Cup sales phases – would need to be imposed well before then to have any practical effect. The Commission does have the power to order interim measures where it identifies an infringement and a risk of serious and irreparable harm to competition, and it exercised that power in Broadcom (2019) – the first time it had done so in nearly two decades – to halt conduct causing ongoing competitive damage.[2] The critical question is whether the same threshold can be met in this case.
What happens if the Commission finds in favour of the Complainants?
A finding against FIFA would have significant consequences for fans, the broader events industry and FIFA itself.
Fans and consumers
With the tournament less than a month away and the Commission seemingly having not taken any formal action, it is now virtually impossible that the Commission will impose interim measures in time to affect ticket pricing for the 2026 World Cup. The practical significance for fans may therefore lie less in the impact on the 2026 edition itself, than in the precedent: were the Commission to find an infringement, it could establish a framework for price transparency and pricing obligations applicable to future editions of the tournament.
Events industry
A Commission decision in this case would not exist in a vacuum. Dynamic and demand-based pricing practices are attracting increasing regulatory and political attention across the sports and live entertainment sectors.[3] Depending on its outcome, the case could influence the regulatory environment for event ticketing more broadly – though much would depend on the specific legal basis and scope of any findings.
FIFA
A finding of infringement could expose FIFA to follow-on damages claims brought by consumers across the European Economic Area, and any binding behavioural remedies could constrain its ticketing practices for future tournaments. That said, there would be a number of significant challenges with bringing follow-on damages claims. The lack of opt-out antitrust collective redress mechanism at EU level would likely mean that claims would need to be fragmented by country or brought on an opt-in basis. Assuming the claims were brought outside of the US, their value is also likely to be limited, and it would be difficult to establish a credible counterfactual price without obvious market comparators. Any finding of infringement may therefore be less likely to result in lower prices or meaningful compensation for 2026 World Cup tickets than to pose longer-term challenges for FIFA’s dynamic pricing model and future commercial revenues.
More broadly, the Complaint poses strategic risks for FIFA beyond the immediate proceedings. Any formal investigation by the Commission – even one that does not result in an adverse finding – may subject FIFA’s ticketing model to sustained public and regulatory scrutiny at a time of heightened political sensitivity around ticket pricing. A finding of infringement could constrain FIFA’s commercial autonomy in structuring ticket sales for future tournaments and would likely embolden similar challenges from fan and consumer groups in respect of other FIFA-controlled revenue streams. How the Commission exercises its discretion, and whether the legal theories of harm advanced by the Complainants withstand scrutiny, will be closely watched by sports governing bodies, rights holders and the events industry alike.
For further information, please contact:
Tom Cassels, Partner, Linklaters
tom.cassels@linklaters.com
[1] The Complaint alleges that this constitutes a breach of Article 7 of the Directive 2005/29/EC of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market (the “UCPD”).
[2] Antitrust: Commission imposes interim measures on Broadcom
[3] See, for example, the UK Competition and Markets Authority’s investigation into dynamic pricing by Ticketmaster UK Ltd; and Australia’s consultation to ban dynamic and drip pricing and subscription traps.
