The Court of Arbitration for Sport (CAS) issued a ruling on July 3, 2013, in a dispute between the European Federation of American Football (EFAF), along with several national federations, and the International Federation of American Football (IFAF). The case centered on the validity of Resolution No. 16, adopted during IFAF's 15th Congress in July 2012, which restructured IFAF's governance by replacing independent continental federations like EFAF with Continental Executive Committees directly accountable to IFAF. The appellants argued that the resolution was invalid due to procedural irregularities, including the submission of draft statutes in only one official language (English) and the lack of proper notice. They also contended that the resolution effectively excluded EFAF without following the proper revocation procedures outlined in IFAF's statutes.
The CAS panel ruled that IFAF's statutes did not explicitly require proposals to be submitted in both official languages (English and French) for validity. While the panel acknowledged the practical importance of providing translations, it found no statutory obligation mandating dual-language submissions. The panel also determined that EFAF was not a "member" under IFAF's statutes but rather an affiliated continental federation governed by Article 5, which did not grant it the same rights as full members. Consequently, the termination of EFAF's status was a result of organizational changes, not a formal expulsion, and did not violate any statutory procedures.
The panel further addressed the quorum requirements for the Congress vote, concluding that the necessary threshold was met despite the departure of some federations during the proceedings. The panel noted that the total number of voting members was correctly adjusted to 62 after accounting for Luxembourg's resignation and Kuwait's inclusion. With 31 members present during the vote, the quorum requirement of half the member associations was satisfied, and Resolution No. 16 was adopted with a two-thirds majority.
The CAS dismissed the appellants' claims, upholding the validity of the resolution and reinforcing IFAF's authority to restructure its governance. The decision clarified the distinction between full members and continental federations under IFAF's framework, emphasizing that only full members enjoy specific procedural protections. The ruling allowed IFAF to proceed with its reorganization, effectively dissolving EFAF's formal role within the international federation. The case underscored the tensions between maintaining regional autonomy and centralizing governance in international sports organizations, while highlighting the importance of adhering to statutory procedures in resolving such disputes.