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How crowd disorder will be governed and policed at Euro 2016

Wednesday, 20 April 2016 By Grahame Anderson, Chimi Shakohoxha

As football fans around the World will be well aware, this summer sees the UEFA European Football Championship 2016 (Euro 2016) taking place in France between 10 June and 10 July.

With crowd disorder at football games across Europe, both domestically1 and internationally,2 unfortunately being an issue again this season, it seems relevant to examine the laws and regulations governing the behaviour of crowds attending the tournament, and explain how the laws will be policed and enforced.

This analysis requires an examination of two strata of control, (i.e. laws and policing responses) that will govern and enforce any crowd disorder at Euro 2016:

  1. The control of the footballing authorities (which is to say UEFA) over UEFA members; and,
  2. The control of domestic French law over disorderly supporters.



Euro 2016 is convened under the auspices of UEFA. UEFA itself and its members (the national football associations) are bound to comply with the various sets of rules of the Union (see below). In determining disciplinary issues, UEFA’s organs are also bound by the FIFA Laws of the Game and Swiss Law as a supplement (see UEFA Disciplinary Regulations 2014, art. 5).


Main UEFA provisions for Euro 2016

In the context of crowd control, the relevant sets of rules for Euro 2016 are as follows:


Types of disorder

Unfortunately, the footballing authorities have already had cause to test the application of these provisions in the context of the qualifiers for Euro 2016. On 14 October 2014, a heated match between Albania and Serbia in Belgrade descended into violent chaos once an unmanned drone trailing a nationalistic banner exhorting the “Greater Albania” entered the stadium. The game was abandoned and the fallout finally dealt with in a CAS Award 2015/A/3874 Football Association of Albania v UEFA & Football Association of Serbia (“Albania v Serbia”).3

The sub-paragraphs of Article 16, paragraph 2 of the UEFA Disciplinary Regulations 2014 lists the following as unlawful disorder:

  1. the invasion or attempted invasion of the field of play;4
  2. the throwing of objects;5
  3. the lighting of fireworks or any other objects;6
  4. the use of laser pointers or similar electronic devices;7
  5. the use of gestures, words, objects or any other means to transmit any message that is not fit for a sports event, particularly messages that are of a political, ideological, religious, offensive or provocative nature;8
  6. acts of damage;9
  7. the disruption of national or competition anthems;10
  8. any other lack of order or discipline observed inside or around the stadium.

Further, the UEFA Disciplinary Regulations 2014 carve out, at article 14, special provision for discriminatory behaviour:

"(1) Any person … who insults the human dignity of a person or group of persons on whatever grounds, including skin colour, race, religion or ethnic origin, incurs a suspension lasting at least ten matches or a specified period of time, or any other appropriate sanction."11

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Written by

Grahame Anderson

Grahame Anderson

Grahame is a barrister at Littleton Chambers and a member of Littleton’s Sports Law Group.  In addition to sports law, he specialises in employment and commercial work.

Chimi Shakohoxha

Chimi Shakohoxha

Chimi is a Partner and Head of Development in Clarke Willmott’s. Chimi qualified in 2002 and joined Clarke Willmott LLP in March 2011. He is noted in Legal 500 and is a member of the Law Society and the Albanian Bar Association (non practising).

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