On June 4, 2019, the TAR Lazio upheld a decision issued by the ICA in 2018, which had fined the Italian Football Federation (“FIGC”) for an anticompetitive agreement, consisting of the FIGC’s decision to limit access to the market for professional services provided by sports directors, sport management assistants, talent scouts and match analysts.[1] The TAR Lazio agreed with the ICA that the FIGC’s decision, setting certain limitations on access to the above-mentioned professions (quantitative limitations for the attendance of courses to qualify for these professions, Italian citizenship and residence requirements, and need to be included in certain “lists”), constituted an anticompetitive agreement, as it was capable of limiting the freedom of access to those professions with no legitimate justification. The TAR Lazio also held that there was no clear link between the limitations introduced by the FIGC and the objective of ensuring the quality of the services provided. Therefore, the TAR Lazio fully upheld the ICA’s decision and the fine imposed on the FIGC.

[1]              TAR Lazio, judgment No. 7177/2019; ICA decision of June 27, 2018, No. 27249, Case I812, F.I.G.C. Regolamentazione dell’attività di direttore sportivo, collaboratore della gestione sportiva, osservatore calcistico e match analyst.