As the Champions League season is about to begin, European soccer fans have voiced their concerns over FIFA’s proposed plans to allow domestic leagues to stage matches abroad. In a joint letter, supporters’ groups have warned that FIFA would set a “dangerous precedent” by allowing domestic leagues to relocate matches abroad. Not only would these matches alienate home fans, but the groups cite environmental concerns from traveling and that such plans would violate Articles 3 and 6 of FIFA’s Regulations Governing International Matches. [1]
To demonstrate some of FIFA’s regulations, let us imagine a scenario where FC Barcelona and Real Madrid wanted to play a match in the newly constructed Bills Stadium in Orchard Park, New York. Article 6 of FIFA’s Regulations Governing International Matches states that International Matches may only be authorized by FIFA, a confederation (like CONCACAF or UEFA), or a member (like US Soccer Federation). The approval needed depends on the “tier” of international match that is planned on being played. A match between two club teams affiliated with one member playing on the territory of another member is considered a “Tier 2” International Match. Hence, we are dealing with a Tier 2 International Match in our hypothetical. According to Article 11 (2), Tier 2 International Matches being played in the territory of another confederation first needs the authorization of the member to which it belongs (the Royal Spanish Football Federation in our example). The member would then have to request authorization from the confederation it is affiliated with (UEFA). Once the clubs have these authorizations, they must pass them on to the Member on whose territory the match is being played (US Soccer Federation). This host member must then submit final authorization containing all the relevant members and non-host confederations authorizations to the host confederation (CONCACAF). Once authorization has been granted, the host confederation must notify the host member, FIFA, and the non-host confederations.[2] Requirements for authorization depend on the host confederation and host member’s rules regarding international matches.
After undertaking such procedures, a match may still not be approved. Under current US Soccer Federation Rules, while there are requirements for an application for authorization, there are no guidelines for why authorization for an International Match would not be approved.[3] Therefore, a club or a league could have a claim that the US Soccer Federation was acting arbitrarily and capriciously in denying such authorization. US Soccer could also open itself up to antitrust violations if it denies international matches in an attempt to bolster the MLS.
FIFA previously had a rule that domestic leagues were not allowed to play regular season matches outside of their home territory unless they received approval from the host member.[4] That rule was challenged in an antitrust lawsuit brought by Relevant Sports, an events promoter owned by Miami Dolphins CEO Stephen Ross, against FIFA and the US Soccer Federation after Relevant tried to host a match between two Ecuadorian teams on US soil. FIFA was dropped from the lawsuit in 2024 after the case went to the Supreme Court[5] and the case between Relevant and US Soccer was settled earlier this year[6], but the case paved the way for FIFA to contemplate changing its rules to allow domestic league matches to be played in other countries.
The popularity of soccer in the US has grown in recent years, in part due to the upcoming 2026 FIFA World Cup tournament being held in cities across North America. European domestic leagues have benefited from this increase in viewership, with the Italian Serie A viewership growing the most, increasing 23.6% from 2022 to 2024.[7]
Spain’s La Liga is set to stage a fixture between Villareal and Barcelona in Miami in December, while Serie A is planning to stage a match between Milan and Como in Perth, Australia, in February.[8] As of September 2nd, the German Bundesliga has stated that there are no plans to stage any of the league’s matches abroad[9], but this could change if the scheme proves to be a commercial success.
The backlash from fans and leagues is in stark contrast with the NFL, whose teams are all in on its International Series. In 2025, the NFL returned to Brazil for a divisional matchup that had the Chargers beating the Chiefs.[10] The NFL will be returning to London and Germany later in the season, while visiting Ireland and Spain for the first time.[11]
[1] https://www.nytimes.com/athletic/6589302/2025/09/01/la-liga-match-abroad-serie-a/
[2] chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://digitalhub.fifa.com/m/428d57940518eef/original/p0ppt4a5mrbb0zmvbl1g-pdf.pdf
[3] https://ussoccer.app.box.com/v/international-games-procedures
[4] chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://digitalhub.fifa.com/m/3815fa68bd9f4ad8/original/FIFA_Statutes_2022-EN.pdf
[5] https://www.nytimes.com/athletic/5436431/2024/04/22/relevent-sports-us-soccer-fifa-supreme-court/
[6] https://www.nytimes.com/athletic/6302542/2025/04/25/la-liga-serie-a-premier-league-la-liga-matches-usa-fifa-relevent/
[7] https://www.samford.edu/sports-analytics/fans/2025/Americas-Soccer-Revolution-5-Viewing-Trends-Poised-to-Make-World-Cup-2026-a-True-Watershed-Moment
[8] https://www.nytimes.com/athletic/6589302/2025/09/01/la-liga-match-abroad-serie-a/
[9] https://www.nytimes.com/athletic/6594699/2025/09/03/bundesliga-match-abroad-la-liga-serie-a/
[10] https://www.nytimes.com/athletic/6610499/2025/09/08/chiefs-chargers-brazil-youtube-viewership-nfl/
[11] https://www.nfl.com/international/international-games
Stacy Walker is a third-year law student at the University at Buffalo School of Law. Her areas of interest lie at the intersection of sports and corporate transactions, with prior research done on private equity investments in youth sports and professional stadium development projects.
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