Effective Judicial Protection: An Analysis of AG Spielmann’s Opinion in Case ZD & MI v. FIGC, CONI et al.

Opinion of the Advocate General in Joint Cases C-424/24 and C-425/24, ZD & MI v. FIGC, CONI et al., 18 December 2025

Date of the decision: 2025-12-18

On 18 December 2025, Advocate General Spielmann delivered his Opinion in ZD and MI (joined cases C-424/24 and C-425/24), a pair of references arising from disciplinary sanctions imposed in the aftermath of the plusvalenze affair involving Juventus F.C. The Opinion sits squarely within the Court’s recent jurisprudential trajectory reshaping the relationship between football governance and EU fundamental rights, standing alongside the Lassana Diarra judgment on FIFA’s transfer system and the Royal Football Club Seraing ruling on the judicial review of CAS awards. It confirms that sporting disciplinary sanctions remain permissible, but only within a system of effective judicial protection in which State courts - or genuinely independent sports bodies - can annul unlawful measures and issue interim relief.

Context and Facts

The reference arises out of disciplinary proceedings brought by the FIGC Federal...

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