CJEU: DFB Agent Rules May Be Justified Under EU Competition Law

CJEU, 9 July 2026, Case C-428/23, ROGON GmbH & Co. KG, MVI Management GmbH, DC c. Deutscher Fußball-Bund eV (DFB)

Date of the decision: 2026-07-09

On 9 July 2026, the CJEU clarified how Article 101.1 TFEU applies to football federation rules governing player agents. The Court held that the Wouters and Meca-Medina exception may, in principle, apply to rules adopted by a sports federation which are addressed to clubs and players but affect third-party agents. That possibility is strictly conditional: the rules must not be restrictive by object, must pursue a legitimate public interest objective and must be suitable, necessary and proportionate.

Context and Background

The judgment in ROGON and Others concerns the Reglement für Spielervermittlung (RfSV), the German Football Association’s (DFB) regulation on football agents, which entered into force on 1 April 2015. The regulation is addressed to clubs and players, who must comply with it when using the services of an agent for the conclusion of professional player contracts and transfer agreements. It also affects agents themselves, since their ability to act for clubs and players depends on compliance with the obligations laid down by the regulation.

The rules at issue include an obligation to register agents, a requirement to submit a declaration accepting various FIFA, DFB and DFL statutes and rules, including the jurisdiction of the DFB, a further registration...

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