X Xulu Attorneys Carpe Diem

In one of the most extraordinary decisions in African football history, the CAF Appeal Board on 17 March 2026 declared the Senegal national team to have forfeited the final match of the TotalEnergies CAF Africa Cup of Nations Morocco 2025, with the result recorded as 3-0 in favour of the Federacion Royale Marocaine de Football (FRMF), the Royal Moroccan Football Federation. This came 48 days after Senegal had won the final 1-0 on the pitch in Rabat on 18 January 2026, after extra time.

The CAF Disciplinary Board had, on 28 January 2026, just 10 days after the final, imposed disciplinary sanctions including fines and match bans on both federations and various players. Critically, it rejected Morocco's protest regarding alleged violations of Articles 82 and 84 of the AFCON Regulations. The FRMF announced on 3 February 2026 that it would appeal. The CAF Appeal Board heard that appeal and on 17 March 2026, 48 days after the final, set aside the Disciplinary Board's ruling entirely and declared Senegal to have forfeited the match 3-0.

Article 82 of the AFCON Regulations provides that if a team refuses to play or leaves the field before the end of the match without the referee's authorisation, it shall be considered the loser and definitively eliminated from the competition. Article 84 provides that such a team will lose its match 3-0. The FSF described the ruling as "unjust, unprecedented and unacceptable." FSF Secretary General Abdoulaye Seydou Sow called the decision "a travesty that rests on no legal basis."

Who is representing Senegal at CAS?

FSF President Abdoulaye Fall confirmed at a press conference: "We have given our lawyers a mandate to pursue this procedure at the level of the Court of Arbitration for Sport." According to multiple Senegalese media reports including L'Observateur and Wiwsport, the legal team is led by Seydou Diagne, who is the FSF's lawyer of record, having appeared before the CAF Disciplinary Committee on 27 January 2026 representing the federation. The reported team also includes Aly Fall, president of the Senegalese Bar Association, and Moussa Sarr, who has prior CAS experience from the ASC Ouakam dispute. The team is further reported to include foreign legal counsellors including Swiss lawyer Serge Vittoz, who is reported to have been involved in the 2017 CAS case in which the South Africa vs Senegal 2018 FIFA World Cup qualifier was ordered to be replayed after match official Joseph Lamptey manipulated the tie.

Where does Senegal appeal, and is it CAS?

Yes. CAS is the supreme appellate body for sports disputes globally. Senegal has exhausted CAF's internal processes and the path to CAS is now open.

Who will be the respondent at CAS, CAF or Morocco?

The respondent will be CAF, not Morocco. The FSF is challenging the decision of the CAF Appeal Board. It is CAF's decision that Senegal contests. The FRMF may apply to be joined as an interested party, but CAF is the primary respondent as the decision-making body. Senegal is not suing Morocco. It is challenging the legality and correctness of CAF's own appellate process.

The CAS appeal procedure and key timelines

Under Article R49 of the CAS Code of Sports-related Arbitration (2025 edition), in the absence of a time limit set by the relevant federation's statutes or regulations, the appellant must file a statement of appeal within 21 calendar days of receiving the written decision. The CAS Code clarifies that if the last day falls on an official holiday or non-business day, the time limit extends to the first subsequent business day. The CAF Appeal Board decision was notified on 17 March 2026, meaning day 21 falls on 7 April 2026, a Tuesday. This deadline is absolute. Article R32 of the CAS Code confirms that no extension is available for the statement of appeal. Missing it renders the appeal inadmissible with no recourse.

The statement of appeal, governed by Article R48 of the CAS Code, must include the appellant's nomination of an arbitrator from the CAS closed list and payment of a Court Office fee of CHF 1,000 (approximately R21,000 at current exchange rates). Within 10 days following expiry of the appeal time limit, Senegal must file its appeal brief. CAF as respondent will then have 20 days from receipt to file its answer. A panel of three arbitrators will hear the matter, with each party nominating one and the President of the CAS Appeals Division appointing the third, per Article R50 of the CAS Code.

What arguments will Senegal raise, and what does IFAB say?

Under Article R57 of the CAS Code, the panel conducts a de novo review and has full power to review the facts and the law afresh. Senegal's lawyers will likely raise several arguments. First, that the on-field referee never declared a forfeit. The match was delayed, resumed, and played to its conclusion in extra time. Second, and critically, under IFAB Law 5, the Laws of the Game as set by the International Football Association Board (IFAB), the decisions of the referee regarding facts connected with play, including the result of the match, are final. Law 5 further provides that the referee may not change a restart decision once the referee has signalled the end of the match and left the field of play. In this case, the referee completed the match, signalled its end, and left the field. Under IFAB's own Laws, that result is final. CAF's Appeal Board applied its tournament regulations, but those regulations must be read in the context of IFAB's Laws of the Game, which vest sole authority over the result in the referee, not a post-match administrative body. Third, no formal protest was lodged by Morocco at the time of the walkoff. The final CAS award is binding and subject only to limited challenge before the Swiss Federal Tribunal.

This case raises profound questions about the governance of African football and the limits of administrative regulation in the face of genuine on-field chaos. At its heart lies a fundamental tension between CAF's tournament regulations and IFAB's Laws of the Game — specifically whether an administrative body can override a result that the referee, as the sole authority under Law 5, has already determined and closed. It is one to watch closely.

Written by X Xulu Attorneys, 20 March 2026. This article is for informational purposes only and does not constitute legal advice. Sources: CAF Appeal Board Media Statement (17 March 2026); CAF Disciplinary Board Statement (28 January 2026); CAS Code of Sports-related Arbitration (2025, Articles R32, R47, R48, R49, R50, R57); IFAB Laws of the Game 2025/26 (Law 5); AFCON Regulations (Articles 82, 84); Al Jazeera, ESPN, L'Observateur, Seneweb, Wiwsport (March 2026).

A positive doping test does not automatically end a rugby player's career. World Rugby Regulation 21, which implements the 2021 World Anti-Doping Code (WADC) into rugby, establishes a detailed procedural framework that governs every step from sample collection to final sanction. Understanding that framework is critical for any player, coach, or rugby official.

The regulatory framework

World Rugby is a signatory to the WADA Code. As stated in World Rugby Regulation 21.1, World Rugby has adopted and implemented anti-doping rules in accordance with its responsibilities under the Code. Regulation 21 applies to all Players and Persons under the jurisdiction of World Rugby and its member Unions, including South African Rugby (SARU). In South Africa, SA Rugby has adopted Regulation 21 in full and works in conjunction with SAIDS (South African Institute for Drug-Free Sport) on testing and results management.

Step 1: Sample collection

A rugby player selected for doping control is notified by a Doping Control Officer (DCO) and must report immediately to the doping control station, as required by the World Rugby Doping Control Procedural Guidelines (Schedule 1 to Regulation 21). The player provides a urine and/or blood sample, divided into an A sample and a B sample. The A sample is sent to a WADA-accredited laboratory for analysis, while the B sample is sealed and held. Players are tested both in-competition and out-of-competition, including on a no-advance-notice basis, as provided in Regulation 21.5.

Step 2: Adverse Analytical Finding and notification

If the A sample returns a positive result, known as an Adverse Analytical Finding (AAF), the laboratory notifies the Anti-Doping Organisation with Results Management Authority. In most cases involving international players, this is World Rugby itself. World Rugby then notifies multiple parties: the player, the player's National Union, and WADA. Notification to the player is made in writing, typically by formal letter, setting out the AAF, the substance detected, and the player's right to request B sample analysis. This is confirmed by World Rugby's own published decisions, which record: "The player was notified by World Rugby, the Anti-Doping Organisation with Results Management Authority, of the AAF and his Provisional Suspension by letter." This multi-party notification requirement is grounded in Article 14.1 of the WADA Code and Regulation 21.7.

Step 3: B sample analysis

The player may request that their B sample be opened and tested. Under the World Rugby Procedural Guidelines, the player has the right to be present, or to have a representative present, at the B sample opening. If the B sample confirms the AAF, proceedings continue. If the B sample does not confirm the finding, the matter is closed. The player may also waive their right to B sample analysis.

Step 4: Provisional suspension

Once the B sample confirms the AAF (or is waived), a mandatory provisional suspension ordinarily applies under Regulation 21.7.9, preventing the player from training, playing, or participating in any rugby activities pending the final outcome. The player may apply to have the provisional suspension lifted in limited circumstances, including where the violation is likely to have involved a contaminated supplement.

Step 5: The hearing

The player is entitled to a fair hearing before an independent panel. As expressly stated in Regulation 21.8 and confirmed by the WADC 2021, the standard of proof applied is "comfortable satisfaction," a standard described in the Code as higher than a balance of probabilities but lower than proof beyond reasonable doubt. Critically, under the principle of strict liability in Regulation 21.2.1, once an AAF is established, it is not necessary for World Rugby to prove intent or negligence. The burden then shifts to the player to establish grounds for elimination or reduction of the standard sanction.

Step 6: Sanctions

Under Regulation 21.10 (which mirrors Article 10 of the WADC 2021), the standard period of ineligibility for a first anti-doping rule violation involving a non-specified substance is four years. Where the player can establish that the violation was not intentional, the period is reduced to two years. Further reductions are available for substantial assistance, prompt admission, or where the substance was a Specified Substance or Substance of Abuse. No period of ineligibility will run before the date of sample collection.

Step 7: Appeal to CAS

Under Regulation 21.13.6 (Appeals), the player, World Rugby, WADA, and the relevant Union each have the right to appeal a first-instance decision to CAS. The time limit for filing an appeal to CAS is set out in Regulation 21.13.6 and, in the absence of a specific provision, defaults to 21 days from receipt of the written decision under Article R49 of the CAS Code of Sports-related Arbitration. The CAS appeal is conducted de novo, meaning the CAS panel has full power to review the facts and the law under Article R57 of the CAS Code, and may replace the first-instance decision entirely.

Rugby players and their support personnel are strongly urged to understand this framework before a crisis arises. The strict liability principle, the reversed burden of proof, and the absolute nature of critical deadlines make early legal advice essential.

Written by X Xulu Attorneys, 14 March 2026. This article is for informational purposes only and does not constitute legal advice. Sources: World Rugby Regulation 21 (2021); World Anti-Doping Code 2021 (Articles 2.1, 8, 10, 13); CAS Code of Sports-related Arbitration (2025, Articles R49, R57); World Rugby Doping Control Procedural Guidelines (Schedule 1 to Regulation 21).

When José Riveiro accepted the Al Ahly head coaching job in May 2025, he was coming off a celebrated three-year stint at Orlando Pirates in South Africa. He signed a two-year contract with the Egyptian giants ahead of their participation in the FIFA Club World Cup. By late August 2025, after just 94 days and seven matches including a group-stage elimination and a 2-0 league defeat to Pyramids FC, he was gone. The club described the departure as mutual consent. Riveiro saw it differently.

What followed was a textbook example of how the FIFA dispute resolution framework operates when a coach believes he has been wrongfully dismissed and inadequately compensated.

The contractual basis for the claim

Al Ahly's position was that the termination was by mutual consent and that the club had offered Riveiro $98,000 (approximately R1.6 million at the time), which the club described as three months' salary in terms of the contract. According to multiple reports citing Al Ahly sources, Riveiro's contract stipulated that he was entitled to three months' salary upon termination by mutual agreement. Riveiro refused the offer and escalated the matter to FIFA. His argument, ultimately accepted by FIFA, was that the total contractual compensation owed to him significantly exceeded what the club had offered.

Under Article 13 of the FIFA Regulations on the Status and Transfer of Players (RSTP, January 2025 edition), a contract may only be terminated upon expiry of its term or by mutual agreement. Where a contract is terminated without just cause by the club, Article 17(1) of the RSTP provides that in all cases the party in breach shall pay compensation. Critically, where a contract contains a liquidated damages or penalty clause stipulating a predefined amount payable upon early termination, that clause governs, unless found to be disproportionate. According to Al Ahly's own official statement and multiple media reports, the contract did contain a penalty clause equivalent to three months' salary in the event of termination. The DRC found that this clause was enforceable and formed part of the total compensation payable. When combined with the remaining contractual value, the DRC arrived at a total award of $588,000 (approximately R10.3 million). The full reasoning of the DRC decision has not been made public, as is standard practice.

The FIFA Dispute Resolution Chamber

The FIFA DRC, established under Article 22 of the RSTP, has jurisdiction over employment-related disputes between clubs and coaches where the parties have not agreed to refer matters to an independent national arbitration tribunal. Riveiro's matter was heard by the Players' Status Chamber, which deals with disputes involving coaches and technical staff in addition to players. The DRC operates on written submissions and does not typically hold oral hearings. Its decisions are notified in writing and both parties retain the right to appeal.

Al Ahly's appeal to CAS

Al Ahly confirmed in an official club statement that it will appeal to CAS. Dr Abdullah Shehata, Al Ahly's legal advisor for the football sector, stated publicly: 'The club will appeal to the Court of Arbitration for Sport against the ruling issued by FIFA's Players' Status Chamber in favour of Riveiro, awarding him total compensation of $588,000, including the penalty clause stipulated in the contract for three months.' He added that the appeal would be filed within three weeks of the club receiving the full reasoning of the decision. Under Article 58 of the FIFA Statutes (2024 edition), appeals against final decisions of FIFA's legal bodies shall be lodged with CAS within 21 days of receipt of the written decision, per Article R49 of the CAS Code.

At CAS, the matter proceeds under Article R47 of the CAS Code as an appeals arbitration. Per Article R57, the CAS panel has full power to review the facts and law and may issue a new decision or refer the matter back. Both parties nominate one arbitrator from the CAS list, with the third appointed by the President of the CAS Appeals Division under Article R50.

What this tells us about coach contracts in Africa

The Riveiro matter is a reminder that coaches operating in Africa, including South Africa, are protected by the same FIFA framework that protects players. Where a club terminates a coaching contract without just cause or pays less than the contract provides, the FIFA DRC offers a credible and enforceable forum for recovery. Well-drafted penalty clauses and clear contractual records are essential for any professional coach. Clubs, equally, must understand that early termination is never cost-free under the RSTP. For South African coaches and clubs, disputes between parties affiliated to SAFA may first be referred to SAFA's internal structures before escalating to FIFA, subject to the jurisdictional provisions of Article 22 of the RSTP.

Written by X Xulu Attorneys, 7 March 2026. This article is for informational purposes only and does not constitute legal advice. Sources: FIFA Regulations on the Status and Transfer of Players (January 2025 edition, Articles 13, 17(1), 22); FIFA Statutes (2024 edition, Article 58); CAS Code of Sports-related Arbitration (2025 edition, Articles R47, R49, R50, R57).