Summary

This piece is prompted by the UN Sports for Climate Action Framework submitting a self-assessment to join a new UN Net-Zero Recognition Framework. It looks first at that self-assessment, then at the Recognition Framework itself, and what each means for football clubs and governing bodies.

It then turns to the corporate climate standards used across much of the rest of the economy but rarely in football. It looks at how they are developing, and why they, rather than the UN schemes, are where a club or governing body’s climate action is tested.

The analysis shows that signing up to the UN initiatives is worthwhile, and more clubs and governing bodies should do so. The low barrier to entry follows the framework's own stated principles: it is designed to be accessible, and it brings in organisations stricter standards would exclude. But that same low barrier means the badge signals intention rather than delivery. It demonstrates neither action nor a structured approach in line with recognised standards. Anybody reading “We have signed up to the UN Sports for Climate Action Framework” would be wrong to assume the club or body is making verifiable progress towards net zero.

Credible action means moving towards those corporate standards, cutting emissions, and pushing for the wider changes no club can make alone.

The UN Sports for Climate Action Framework

The UN Sports for Climate Action Framework (Sports for Climate Action) is a global initiative for sport, launched by the United Nations in 2018. It asks members to measure and reduce their emissions, and use the reach of sport to encourage wider climate action. Over 250 sports organisations have signed up, including 39 football clubs and governing bodies. Across sport, they range from the International Olympic Committee to much smaller federations and national committees. Football’s are mostly its largest clubs and bodies, such as Arsenal, Liverpool, FIFA and UEFA, though it also includes the likes of Forest Green Rovers and Oxford United.

In May 2026, Sports for Climate Action was one of eight initiatives that submitted a self-assessment to another part of the UN, applying to join a new “Net-Zero Recognition Framework”. Others included the Fashion Industry Charter for Climate Action and the Under2 Coalition, a coalition of regional governments. The 250-plus organisations signed up to Sports for Climate Action can also join individually until October 2026.

To apply, Sports for Climate Action assessed itself against the ten recommendations of the UN’s High-Level Expert Group on net-zero commitments. The result (here and here) is sport’s own account of its approach.

It rates itself “fully aligned” on just one recommendation: matching its lobbying and advocacy to its climate goals. On fossil fuels it rates itself “not aligned”, stating it has “no explicit fossil fuel phase-out or renewable targets”.

On the other eight recommendations, including transparency, transition planning and target-setting, Sports for Climate Action rates itself only “partially aligned”. It records that independent third-party verification of members’ emissions cuts “is not currently mandated”, and requires no published transition plan. Where the expert group looks for targets in 2025, 2030 and 2035, sport sets one for 2030 and a net-zero date of 2040, leaving a decade between its first target and last.

In submitting this self-assessment, Sports for Climate Action is not committing to close the gap between its approach and the expert group’s recommendations. It is setting out a snapshot of its approach, as required to join the Recognition Framework. Other initiatives ask for more.

The Sports for Climate Action initiative alongside others

Sports for Climate Action was one of eight very different initiatives that submitted a self-assessment to join the Recognition Framework. The others include a body representing the wine industry, a hub for small businesses, and a coalition of regional governments. Their variety is notable.

A 2026 review of the voluntary net-zero landscape by researchers at Oxford Net Zero called it a “competitive landscape” of overlapping schemes: converging on the goal of net zero, but diverging so widely on what reaching it requires that disclosure is inconsistent and organisations barely comparable.

These eight initiatives are a small instance of that wider pattern. Reading the other seven alongside Sports for Climate Action shows they cannot be scored against each other: they did not answer the same questionnaire in the same way.

Some initiatives graded themselves recommendation by recommendation; some answered against detailed sub-criteria; one replied in narrative prose. Their self-assessments cannot be lined up and compared, which is the first thing worth noticing.

Read side by side, the eight reveal how differently each has interpreted what “net zero” requires of its members.

Some initiatives require their members to undergo independent checking. The International Wineries for Climate Action requires members’ emissions inventories to be verified by an accredited third party to the ISO-14064 standard, and can downgrade or remove a winery that falls short. Planet Mark, a certification scheme, requires annual measurement and can withdraw certification from a member that stops meeting its requirements.

Others require less. The Under2 Coalition, whose members are regional and subnational governments, has “no mechanisms for the removal of non-compliant signatories.” The SME Climate Hub, built for small businesses with limited resources, asks for no third-party verification and is still deciding how to handle members that fall behind. Each has tailored its expectations to its members.

Sports for Climate Action is different. It asks for no independent verification; its own assessment says this “is not currently mandated”, and it names no standard its members must follow. But many of its members are neither small businesses nor public bodies. They include the wealthiest and most powerful organisations in world sport. The light-touch approach a small-business hub can reasonably justify is harder to account for in a body whose members often have the capacity to do far more.

Still, these eight share a minimal floor. To reach the Recognition Framework’s first level, a member needs a public pledge, “good standing”, and regular disclosure. What that means in practice is what this piece considers next.

The new net-zero recognition framework

The self-assessments were produced, submitted and published for a reason. Sports for Climate Action and others applied to join the Net-Zero Recognition Framework, a scheme the UN introduced at the COP30 summit in late 2025.

Joining it is a decision not only for these initiatives as a whole. Each of the 39 football clubs and governing bodies, and every other Sports for Climate Action signatory, now faces its own choice: whether to join individually. They have until October 2026 to decide. This makes it even more important to understand the Recognition Framework before signing up.

The Recognition Framework aims to showcase participants’ net-zero journeys. Each has five levels, from a public net-zero commitment at Level I to reaching net zero at Level V, with a transition plan, demonstrated progress and interim targets marking the stages between. The map below sets out those levels. The UN records which level an organisation has reached, and that record is the recognition: a public marker carrying the UN’s name of how far an organisation has come.

Two features of this journey deserve a closer look.

The first is direction of travel. The framework records only forward steps: no level marks whether an organisation has fallen behind, missed a target or stopped trying. So an organisation that joins, commits, then does very little stays where it is, still recognised, with nothing on the record showing the gap between promise and delivery1.

The second feature is how little the UN checks. It requires an outside check at a single point: to reach Level II, an organisation must provide “third-party reviewed data”. Every higher level is optional to verify. The framework never explains how “reviewed” differs from the stronger “verified” it offers, but does not require, higher up. Beyond that early step, an organisation can climb by saying it is making progress, with no outside confirmation.

Independent confirmation would count for most in one place in particular: proving that emissions reductions are on track and that targets and plans are being met. But here, the Recognition Framework makes it optional. Nothing in it requires that self-reporting be independently checked, or reported to a recognised standard.

This follows from how the framework came about. It grew out of an earlier UN proposal, the Net-Zero Recognition and Accountability Framework. Following consultation, it dropped the word “accountability”. The consultation’s co-chairs reported a “lack of unanimity amongst Parties” and a view that there were “quicker ways to accelerate the adoption of ambitious regulatory frameworks”2.

What has launched recognises what an organisation says about itself and leaves checking optional. It should not be mistaken for bringing order to the wider net-zero landscape. And as individual members begin joining in their own right, each bringing its own approach, the recognition badge risks making the picture harder to read.

The variety between initiatives reflects choices that can be revisited. The clubs and governing bodies in Sports for Climate Action are among those who could ask it to adopt the firmer expectations some other initiatives already set: to name a standard or require members’ reported cuts to be independently checked. What that approach should look like, and how far it should go, is not for this piece to settle. But the options are there. Members of Sports for Climate Action can press for change or accept the status quo. They cannot say they have no choice.

None of this means a club should stay out of Sports for Climate Action or the Recognition Framework. Signing up is a real, if small, first step. It is still more than most clubs have taken. But clubs and bodies should be clear, with themselves and others, about what a public commitment does and does not mean.

Making the commitment and reporting on it are the first moves in any journey to net zero, and the ones that prove the least. They show a club is willing to act. They do not show that anything is actually happening.

This raises the question any club or governing body serious about its emissions must answer next: if UN recognition does not show delivery is under way and emissions are falling, what would?

The role of corporate climate standards

This is where corporate climate standards come in: the internationally recognised rulebooks that companies across sectors increasingly follow to show their climate action stands up. They cover the core questions: how you count your emissions, what counts as a credible target and plan, and how you check whether emissions are actually falling.

Showing that a net-zero position is real rests on three things: measuring emissions properly; setting targets and a plan against a recognised external standard; and having an independent party check figures and progress against them. Measurement, targeting, verification. The standards ask for more than this, but without these three, none of it can be checked.

Football has done the first, measurement, in many cases. A number of clubs now count their emissions using the Greenhouse Gas Protocol, the same accounting framework used by companies across the economy. But only a handful of the biggest clubs and bodies break emissions down across the full range of categories the Protocol sets out. And the way clubs present figures and wider sustainability plans varies so widely that comparing one to another to assess progress is close to impossible. The foundation is being laid, unevenly and in formats that do not line up.

On the second, targeting, a small number of clubs and bodies across world football have set targets, including all those in Sports for Climate Action, but few beyond it. Those with targets are the exception, and almost none are validated against a recognised standard. And on the third, independent verification, the picture is murkiest of all. A few clubs and bodies publish emissions figures that appear to carry some external check, but the overwhelming majority do not. It is often unclear from what a club publishes whether its numbers have been checked at all.

The standards are closing the gap

The standards themselves are now closing that third gap from two directions. The most widely recognised standard for net-zero targets is set by the Science Based Targets initiative (SBTi), which checks a company’s targets against 1.5°C. Over 11,500 companies worldwide had validated targets at the start of 2026. Across world football, only a handful of clubs have joined them: Arsenal and Borussia Dortmund among them, though with different approaches - Arsenal sets an intensity target for its Scope 3 emissions, and BVB an absolute one3.

That validation examines a target’s design: its scope, baseline, timeframe and ambition. It does not look at the emissions data behind the target; that responsibility stays with the company. What the new version of the standard, published in June 2026, adds is a requirement that companies get that data checked. Larger companies must now obtain independent third-party assurance of their starting emissions, and again when they report progress at the end of each five-year target period. On the standard’s own size thresholds, every Premier League club, were it to apply, would count as one of those larger companies.

Alongside this development, a draft ISO standard for net-zero organisations is out for consultation until September 2026. It moves the same way on checking but differently on independence. It requires a net-zero claim to be checked at every stage, from first aspiration to reaching net zero. But it lets the organisation making the claim decide who checks it: an accredited outsider, a business partner, or itself. It acknowledges in its own words that “third party validation and verification reflects best practice and provides greater credibility.”

So the standards agree that net-zero claims must be checked. Both scale what they ask by the organisation's size. Every organisation still has to show it did what it said. They differ on who checks: SBTi requires independent assurance for larger companies, while ISO's consultation draft leaves the choice of checker to the organisation.

They also differ on what happens if a target is missed. The Recognition Framework takes the organisation's own statement of progress. SBTi allows it to continue only if it can show it "applied available levers within [its] control." Whether that is enough is contested. ISO goes furthest: an organisation must publish the size of its miss and loses the right to refer to the standard if it does not get back on track.

Taken together, the picture in football is one of uneven measurement, few targets or plans, and minimal validation or verification of emissions. It would not be fair to say football’s emissions are rising, or that they are on track for 2030 targets, because either claim would imply a clear public picture of where things stand. There isn’t one. And in 2026, while growing numbers of businesses in other sectors set climate targets, put plans in place, and sign up to rigorous standards, football has still not got its boots on.

Measurement and its limits

A club can sign up to Sports for Climate Action, and then to the Recognition Framework layered on top. Both are worth doing, and both are more than most clubs in a laggard sector have managed. But neither is delivery, and neither requires anyone to check that a club’s targets and plans are fit for purpose, or that its emissions are falling. The real work sits beyond joining. And, to be clear, a club or body could clear that floor without the UN at all, by going straight to a recognised standard like the Science Based Targets initiative.

Measuring is the only way a club learns what it can cut, and how much it can cut. Importantly, it also shows how much of its footprint the club can address on its own, and how much can only shift through collective action. Until football measures consistently, there is no clear picture of either.

Once a club measures to the standards, it will understand the scale of its challenge, and find that important parts of its footprint are not, in fact, its to fix alone. A stadium’s electricity can be cut through things such as efficient lighting and on-site solar, but how clean the rest is depends on how fast the national grid decarbonises. Recycled kits and longer kit cycles help, but most emissions in kit and merchandise sit in supply chains and the churn of frequent new releases, which a club shapes only in part.

The biggest source for most clubs, the travel of supporters, is partly football’s own to decide, partly within its influence, and partly beyond it. A club chooses whether to play a friendly locally or on the other side of the world; a governing body sets how many games a tournament runs and when they kick off. A club can influence how they travel, for instance through incentives for low-carbon transport. But how fans then reach the match also turns on the public transport that exists, the infrastructure for walking and cycling, and the pace of the shift to electric vehicles. Proper measurement produces not just a number but a plan, showing where a club’s own efforts are best placed, and where they run out and the problem passes beyond any single club.

Beyond the club

That plan should make clear why club action is necessary but not sufficient. What lies past the club’s own reach is not all of one kind. Some is measurable but belongs to others to fix. Some requires systemic change that is not easily reduced to numbers. A plan’s first use is for the club itself: it identifies a club’s own unique circumstances, and shows which emissions are the club’s to cut and how much can be saved. That work pays off for the club directly.

The same metrics have a second use. They become evidence for where policy has to change, and by how much. That second benefit comes about especially if football measures widely and then acts together. Whether a sport so marked by governance failures will do so is an open question. None of this is a reason to wait: a club can act on its own emissions now. But the wider case is best built on evidence that exists, and right now it barely does.

There is a further issue, touched on earlier, and it may matter more. Emissions measurement identifies and targets what an organisation can affect in and around its own operations. It says little about the wider influence a club or body can have, for good or ill, beyond them. This matters especially in football, given how much of the world’s attention the game commands. What football promotes, whose money it takes, and what it lobbies for shape what its audience treats as normal, and no emissions ledger records any of it. A growing body of work is trying to bring this influence into view more clearly, the very thing the counting frameworks were never built to capture4.

Clubs must do more, but that doesn’t let policy-makers off the hook. And “policy-makers” here means more than governments. Essential parts of football’s footprint turn on public decisions about the grid, transport and planning, and on the choices football’s own governing bodies make. So the pace of decarbonisation is set as much by policy as by any club’s work. Clubs produce the evidence and cut what is theirs to cut; the bodies that set the conditions decide how much further the sport can go.

The real test

So the real question a club serious about climate change should ask is not “have we joined the right things?” It is whether it can show what it is actually doing, and prove it. You would be hard-pressed to find a club or body in the world that can yet do so.

And for the rest of us, the supporters, campaigners and anyone who wants football to take this seriously, the response to a new badge should be to treat it as a welcome start, then ask what has actually changed. To return to the development that prompted this piece: a UN badge is worth having. It tells us almost nothing about whether anything is happening underneath it.

Three things, finally, sit outside everything above, each deserving a piece of its own. The first, as touched on above, is football’s wider influence. The second is the role of regulation in shaping football’s actions and how it relates to voluntary initiatives. The third is the one the whole focus on initiatives, frameworks and standards still ignores. All of that is about cutting emissions, football’s effect on the climate. It says nothing about the reverse: preparing the game for a climate that is already changing around it through adaptation and resilience work. That reckoning is needed, and football has barely begun it.

Endnote

The analysis is put together from primary sources, but experts and practitioners may read the same documents differently, or take a different view.

I actively welcome responses from practitioners, fans, and researchers who can identify errors, supply additional evidence, or offer alternative readings. The aim is a proper debate, rather than the last word.

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Introduction

Europe is the fastest-warming continent on Earth, according to the new Copernicus State of the European Climate report, published last week - a year of records, from marine heatwaves to wildfires to the second-most-severe heatwave on record. It follows on from a European Union assessment that recently identified 36 climate risks posing a serious threat to the continent, several at critical levels.

The case for responding is strong, as is the will to do so. Research shows that adapting to climate change - through better planning, smarter investment, and more resilient infrastructure - delivers a triple dividend: preventing losses, stimulating economic activity, and generating social and environmental co-benefits. The benefit-cost ratio of adaptation investment is put at around 4:1. At the same time, 85% of Europeans agree that action to adapt is required urgently to avoid even higher costs in the future.

The architecture for further action is already being built nationally and internationally. At a European level, the European Commission has been preparing a European Framework for Climate Resilience, with full proposals due later this year. Those proposals will include a key role and new requirements for the private sector.

And in football? UEFA published a refreshed sustainability strategy in February 2026. It contains no plans for climate adaptation or resilience.

This post examines that European-level gap: what it consists of, why it matters environmentally and financially, and what closing it would need to look like.

Sections:

• First of all, some context

• UEFA action

• A key question

• Why it matters financially

• What a UEFA climate resilience strategy could look like

• Closing points

First of all, some context

The plans for a European Framework for Climate Resilience (EFCR) do not arrive out of nowhere. They are the outcome of a visible policy build-up from the EU’s 2021 Adaptation Strategy and draw directly on the European Climate Risk Assessment published in 2024.

That assessment identified 36 climate risks across five clusters - ecosystems, food, health, infrastructure, and economy and finance. Eight are already assessed as particularly urgent. Three map directly onto football: heat stress - to players, fans and calendars; flooding - of grounds and training facilities; and wildfires affecting southern European - and its competitions and air quality at outdoor venues. A January 2026 Commission study confirms these are among the most documented risks across EU member states - infrastructure damage identified across 26 of 27, flooding across all 27, heat stress rated critical or substantial by almost every member state. Other identified climate risks also map indirectly.

The outline of what the EFCR means for private sector actors - including those in sport - is already clear from the Commission’s open public consultation and from the February 2026 recommendations of the European Scientific Advisory Board on Climate Change, the EU’s independent scientific body. Both are looked at in further detail below.

Independent of this work, financial institutions in Europe and the UK are already integrating physical climate risk into expectations for lenders and insurers. In the UK, the Prudential Regulation Authority’s December 2025 supervisory statement on climate risk means banks are expected to assess whether borrowers’ climate risk exposure and insurance adequacy affect credit quality.

On insurance specifically, the scale of the problem is stark: only around 25% of natural catastrophe losses in Europe have been insured historically. EIOPA, Europe’s Insurance Regulator, published proposals in April 2026 for a European natural catastrophe insurance pool, complemented by a loan-based financial backstop -proposing to reduce the protection gap to around 10% of losses across participating member states.

Alongside this, a synthesis published by the LSE Grantham Institute in April 2026 found a benefit-cost ratio for adaptation investment of around 4:1 with average payback periods of three years. Adaptation is not expensive relative to inaction.

Governments are already acting on this. In the UK, the Climate Change Committee will publish a new Independent Assessment of UK Climate Risk in the coming days, with the government required to respond by January 2027. France has a National Climate Change Adaptation Plan specific to sport, setting out 30 measures to be implemented by 2030 across all sports at all levels.

The question is not whether to address climate resilience but how to ensure the approach is coherent, well-targeted and integrated into decision-making across sectors. The incoming European framework, and the national policy actions building alongside it, will reach football through its host countries, its commercial partners, its broadcasters and sponsors, and the financial institutions that fund it - whether or not football itself engages with the process.

UEFA action

UEFA is not ignoring climate change. Its Football Sustainability Strategy 2030, updated in February 2026, has a whole section on ‘Respect the Environment’. This includes several targets and key performance indicators.

But it is only one half of the work that is needed. The February 2026 strategy update frames climate consistently as a carbon footprint and advocacy issue, not a physical risk and resilience one. The words “adaptation,” “resilience,” and “climate risk” do not appear anywhere in connection with physical climate hazards. There is no policy area for heat protocols, flood contingency, drought and water management, schedule resilience, or physical risk assessment of infrastructure.

The same pattern runs through UEFA’s operational documents. Its Stadium Infrastructure Regulations 2025 contain a single oblique reference to climate - pitch heating and covers “depending on the location and climate” - and nothing else on physical climate risk. Its Sustainable Infrastructure Guidelines acknowledge climate change as causing “intense droughts, floods, fires, hurricanes” and describe physical risks to football infrastructure, but do not develop the point. Adaptation appears as one of four labels in a diagram, not as a discipline with requirements attached.

In early 2024, UEFA committed to developing regulations to safeguard players and fans from extreme weather. Against that commitment, what has been delivered is partial: cooling break thresholds for players in the Medical Regulations, and tournament-specific basic advice for fans, produced by the German Government with WHO and ECDC.

Separately, UEFA does have a route through which to provide natural disaster grants. This is not specifically tied to climate or extreme weather impacts - it covers earthquakes and other events too - but has in the past been used to fund responses to extreme weather. The fund’s scale and the projects supported are unclear and it operates as emergency relief rather than as a climate resilience instrument.

UEFA also publishes no corporate risk register and no principal risks disclosure. Under Swiss law, which governs UEFA as a non-profit association, no such disclosure is required. This means there is no equivalent to the obligations that apply to UK, EU or US-regulated entities. UEFA could choose to adopt equivalent standards voluntarily given its stated commitment to the importance of addressing climate issues. It has not done so. This matters because UEFA’s own Sustainability Reporting Playbook actively encourages member associations to identify and assess climate as a material risk in their own reporting. The organisation asking others to take climate risk seriously has no equivalent public process of its own.

UEFA also did not respond to the European Commission’s open public consultation on the EFCR, which attracted over 600 responses from organisations across all sectors. Sport falls squarely within its scope - arts, sports and recreation is among the listed fields of activity for respondents - yet no organised football body responded. Sport chose to be absent from the process designing the framework it will operate under.

The French Government has a national sport adaptation plan. The Football Association of Wales is trialling a revised grassroots calendar in response to winter weather disruption. Romania’s player union has negotiated revised kick-off times due to extreme heat. These are real responses to a real problem - but they are fragmented and uncoordinated. UEFA’s silence in the European Commission process means the sport with the largest participation base in Europe has no voice in shaping the framework it will live under.

A key question

The absence is so consistent it raises a question UEFA has not answered publicly: does it believe climate resilience is its responsibility at all?

UEFA’s approach may reflect a genuine view that host federations, member associations, host countries and clubs bear primary responsibility for managing physical climate risk and it is not for UEFA to get involved. That is a defensible position only if the responsibility is held coherently somewhere else - and the evidence is that it is not.

Why it matters financially

The adaptation gap is not only a governance issue. It is a financial one - and the consequences of climate change are beginning to show up in places football has not yet fully mapped.

The most immediate is insurance. Three entities examined in preparing this piece - Manchester United, Juventus, and Tottenham Hotspur - have each independently flagged in their own climate disclosures that extreme weather is already affecting or could affect their insurance costs or coverage. Manchester United’s annual filing is the most explicit, stating that the club “cannot assure you that we will be able to fully insure such losses” from extreme weather and climate change. None of these entities discloses what it is actually paying, how terms have changed, or what proportion of potential losses falls outside coverage.

As only a handful of clubs and football bodies are required to produce these climate disclosures, the number of other clubs more broadly facing this issue is unclear. But it is clear that the European protection gap is not theoretical for organisations with major fixed assets - only around 25% of natural catastrophe losses in Europe have been insured historically, according to the leading European regulatory body EIOPA.

Beyond insurance, the financial system more broadly is beginning to price climate physical risk into lending and investment decisions. In the UK, the Prudential Regulation Authority’s December 2025 supervisory statement on climate risk means banks are now expected to assess whether borrowers’ climate risk exposure and insurance adequacy affect credit quality. Financing expenses for Europe’s top division clubs have increased by more than 50% since the pandemic and continue to rise, with net debt across English football at £7.6 billion. The growing exposure of heavily indebted clubs to climate-related lending scrutiny is a risk the sector has not yet begun to assess.

The mandatory climate disclosures that leading English clubs and the English FA are required to produce are a first step toward meeting that expectation. That said, the Financial Reporting Council has found that across UK corporate reporting generally, the connection between climate risk identification and financial statement effects remains weak. Football reflects that wider picture. No club discloses whether its insurance terms have changed because of climate exposure. None sets out what capital investment in climate resilience would cost.

Much further work is needed on quantifying the size of the financial issue for football, and on analysing and reporting on financial impacts at club and national association levels in line with evolving best practice and guidance. Also in the UK, the Independent Football Regulator has recently said it will “consider this further as part of our assessment of systemic resilience” - the “this” being climate impacts including fixture cancellations, infrastructure damage and insurance issues. Further detail on the scope and depth of this work is not yet available.

There is also a further important issue that applies to governing bodies across football. National associations typically have financial relationships with the grassroots game - through grant funding, facility investment, and dependence on participation income - that create real climate financial exposure. The FA illustrates the point: it contributes £15–20 million annually to the Football Foundation, deploying capital into grassroots infrastructure; and it provides grants to local County FAs that can represent between 35% and 60% of their total income. Research commissioned by DCMS puts the annual cost of climate disruption to grassroots football in England alone at around £320 million, a figure that appears to sit outside of the FA’s climate risk assessment. The FA is highly unlikely to be alone in that gap across European football’s national associations. Financial exposure falls disproportionately on grassroots clubs and participants - those with the least capacity to absorb it - not on the institutions currently carrying out the risk assessments. This shows that important equity and fairness considerations must be brought into the picture too.

What a UEFA climate resilience strategy could look like

None of this is impossibly complicated. France has demonstrated that a national sport adaptation plan - covering all sports, amateur and professional, with 30 measures, defined governance, a two-year stakeholder process, and integration with the national climate trajectory - can be built and published. The FA has demonstrated that iterative annual review of a climate risk framework, updated when new scientific evidence arrives, produces genuine analytical improvement over time. Juventus has demonstrated that engaging seriously with a rigorous assessment process can surface risks and gaps that less structured approaches would miss, and that acknowledging those gaps publicly builds more credibility than concealing them. The technical capacity exists in the football community, though it needs developing and supporting.

What is missing is the governance layer, and the consistency of approach for clubs, bodies, fans, investors and institutions that delivers efficiencies and transparency. Instead, we have the same fragmentation that the European Scientific Advisory Board has identified at government level, when finding that current climate risk assessment requirements across Europe “vary widely in scope, methodology, time horizon and update cycles” and that this “undermines coherence, limits comparability and weakens EU-wide adaptation planning”.

A UEFA climate resilience strategy would not need to be built from scratch. It could adopt the four principles the EFCR is moving toward and add a fifth specific to football.

The first and most fundamental is resilience by design. This is the direction the EFCR is heading: football investment decisions vulnerable to climate change should be assessed against the risks that will materialise over their operational lifetime. UEFA’s role is to set the framework and standards; national associations would be responsible for implementation within their territories; clubs could demonstrate action through disclosure and/or licensing. For football this could include stadium developments, training facilities, grassroots infrastructure funded through national associations, and tournament infrastructure committed to host countries.

The second is common scenarios. Scenarios define the physical conditions European football is planning against - temperature trajectories, precipitation changes, water stress, wildfire risk - across the lifetime of its assets. No club in Europe, and not UEFA itself, is currently using scenario frameworks consistent with where best practice now sits1.

The third is harmonised risk assessment - identifying, against those common scenarios, which physical hazards affect which football assets and operations, with what severity and probability. The research behind this piece examined climate risk disclosures across eight major European football entities. The finding is not that clubs are doing nothing - it is that genuine efforts are producing incoherent results. City Football Group assigns identical risk ratings to clubs in Manchester, Salvador, Melbourne and Mumbai. Chelsea has identified sixteen climate risks, but conducted no scenario analysis. Spurs produced scenario analysis under four climate futures, but the output was purely qualitative with no financial quantification and a three-year review cadence that will miss the scientific and regulatory updates already under way. Liverpool anchors its risk assessment to a 50-year time horizon - the right principle - but its entire climate risk section is reproduced word-for-word from the previous year’s annual report, with no updates to scenarios, methodology or findings. That means there is no mention of the December 2024 postponement of the Merseyside derby due to Storm Darragh, which directly illustrated the club’s own top identified physical risk. The FA identifies heatwave as high-risk at long-term horizons but not significant enough for board-level action. These are not failures of individual entities. They are the predictable outcome of a sector conducting risk assessments in silos without a common methodology.

UEFA’s Sustainability Reporting Playbook already encourages member associations to treat climate as a material risk. The next step is to specify what that assessment should look like, which hazards it should cover - building on the European Climate Risk Assessment taxonomy - and what the outputs should enable.

The fourth is linkage to capital, insurance, and financing. Climate risk assessment that does not connect to investment decisions, insurance purchasing, or financial planning is not risk management - it is reporting. UEFA already has the tools to build on: UEFA’s HatTrick fund distributes €935 million across UEFA’s 55 member associations over 2024-28, including investment funding for infrastructure; UEFA operates a natural disaster grants line and a tournament-linked Climate Fund that has already invested in grassroots mitigation and sustainability projects. What is missing is the climate adaptation orientation - conditioning HatTrick allocations on climate risk assessment, reforming the disaster grants line from reactive repair to resilient rebuilding, and expanding the Climate Fund into a standing grassroots adaptation facility.

A necessary prerequisite to this would be a baseline quantification of climate financial exposure across major clubs and competitions - giving partners, insurers and investors a common reference point, and allowing UEFA to calibrate the scale of the financial response needed.

To these four UEFA would need to add a fifth specific to football: governance with real accountability, operating at two levels. The first level is internal to clubs and associations - providing advice and guidance on integrating climate resilience into the governance structures that make decisions about capital investment, operations, and financial planning, rather than leaving it in an environmental or sustainability function disconnected from those decisions. That guidance should also extend to advocacy - clubs and associations depend on climate-resilient public infrastructure, from transport networks to energy and water systems, and have legitimate standing to engage with the bodies responsible for it.

The second level is the allocation of responsibilities across the football community: what UEFA sets and monitors, what national associations implement within their territories, what clubs must demonstrate on a proportionate basis, and where grassroots football fits. That accountability should extend beyond infrastructure to the health and safety of players and fans under conditions of extreme heat, poor air quality, or other climate-related hazards for which no comprehensive cross-hazard framework currently exists.

Much of this work could be anchored in a single practical first step: a UEFA Climate Resilience Methodology, equivalent to the UEFA Carbon Calculator Methodology that already exists for emissions measurement. It would give the whole sector a common reference point, demonstrate that UEFA is engaging seriously with the policy process it has so far been absent from, and create the foundation for everything else in this section.

UEFA does not need to wait for the European Commission’s formal proposals later in 2026. A Climate Resilience Methodology would be an entry point - one practical action that demonstrates seriousness, requires no external mandate, and positions UEFA in the policy conversation before the window closes. Expectations for climate risk management are already moving through the financial institutions, commercial partners, and host countries that sustain European football. UEFA can help shape what football-specific developments under the EFCR look like, or it can follow. The window is open. It will not stay that way.

Closing points

The question is not whether European football faces physical climate risk - the Copernicus report answers that. It is not whether the economic case for adaptation is sound - the Grantham Institute answers that. It is not even whether UEFA has done nothing - it has built a mitigation strategy that is real and matters. The question is whether UEFA believes climate resilience is its job.

That silence may reflect a considered view that host federations, member associations, host countries and clubs bear primary responsibility for physical climate risk, and UEFA’s role is to set standards for carbon reduction and advocate for climate action. If that is the position, it deserves to be stated and defended.

But it is only defensible if the responsibility is held coherently somewhere else. The bottom-up activity is real - France, Wales, Romania, individual clubs doing serious work within the limits of their own frameworks. None of it adds up to a co-ordinated or effective European response from the football community.

The EFCR is reshaping the terms of this debate. It is a framework with regulatory intent whose proposals will reach European football through the institutions and commercial relationships that sustain it - whether or not UEFA engages. The clubs and associations that have already begun aligning their risk assessment, their capital planning, and their insurance arrangements with its direction will be better placed financially and competitively when it lands. UEFA’s role, if it exercises it, is to ensure European football arrives at that moment with a coherent position and plan rather many fragmented and incomplete ones.

UEFA has built something real on climate mitigation. But a structure cannot stand on one pillar. The missing one - climate resilience, the capacity to assess risk, protect assets, and adapt to what is coming - is not beyond UEFA’s reach. It is a choice about whether to build it.

END

Endnote

This piece has wrestled with complex and in places very technical and unresolved questions. The analysis is built in good faith from primary sources, but reasonable experts and practitioners may read the same documents differently.

Responses from practitioners, fans, and researchers who can identify errors, supply additional evidence, or offer alternative readings are actively welcomed. As ever, the goal is a debate conducted with precision - not a verdict delivered without challenge.

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Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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Introduction

Fan travel - the emissions produced by millions of people getting to and from matches - is typically the largest source of emissions in the sport. For most clubs it accounts for more than half their total footprint. Yet in clubs’ and governing bodies’ climate commitments it is mostly excluded, unaddressed, or left ambiguous - including by some of the biggest names. These are among football’s least known but most consequential climate choices.

The approach has surface plausibility: clubs have limited control over how fans travel, so fan travel shouldn’t sit inside their targets. But scratch the surface and the arguments weaken. The methodology most commonly cited as justification addresses reporting, not targeting - and on fan travel it specifically recommends inclusion in order to influence and drive reductions. The control argument is also weaker than it first looks.

Targets drive priorities, resources and actions. When fan travel sits outside targets, consequences flow. Decisions that could decrease emissions are not incentivised, and decisions that increase them carry no internal climate cost. Engagement, not outcomes, can become the target.

These are not purely accounting judgements. They are choices about what football is prepared to be held accountable for. This exclusion is becoming increasingly institutionalised - but the case is not settled. Some do include fan travel in their targets. At least three key processes will reach decision points in the next two years - each with the potential to clarify or entrench the ambiguities this piece examines.

This piece assumes a basic knowledge of emissions scopes and categories - see this introduction (p.21) for more on them. It is a contribution to a live methodological debate, not a final verdict. Responses identifying errors in this piece or offering alternative readings are welcome.

Section 1 documents the pattern across English football and beyond. Section 2 examines what the cited frameworks say. Section 3 tests the control and influence arguments. Section 4 sets out consequences and asks.

SECTION 1 - Football’s targeting gap

Two different terms matter throughout: reporting - which is the counting of emissions; and targeting - which is committing to reduce them. Football lags behind the wider business community in setting net-zero targets. Those clubs and governing bodies that have made pledges represent a real progressive minority within the sport - and their efforts deserve recognition. At the same time, even among them, few go beyond their headline commitment in providing granular numbers, meaning there is only a small set to examine in detail. Among those, the picture is one of considerable ambiguity and diversity in approaches.

The FA reports fan travel only for FA-owned Wembley events, classifying all other fan travel as 'not measured.' It excludes what it does report from its 50% reduction target, citing limited control and measurement difficulty. This likely excludes from both measurement and targeting UEFA and FIFA games at Wembley, England fans travelling to away internationals, and matches at other English stadiums.

Arsenal is the only football club globally with SBTi-validated targets1. Its climate disclosure, citing SBTi and UEFA guidance, states that fan travel to ‘our matches’ has been excluded from targets and categorised as Outside of Scope. What ‘our matches’ covers is unstated, though emissions from Arsenal fans travelling to away matches appear to remain in Scope 3 Category 9 (known as ‘downstream transportation and distribution’) and by implication within Arsenal’s Scope 3 target boundary.

Tottenham Hotspur previously included fan travel within its Scope 3 target boundary. It has since removed it, restating its baseline accordingly, citing UEFA guidance that spectator mobility is out of scope for clubs though it should still be reported. Spurs’ statement specifically references home games; the treatment of away fan travel is left unclear. Fan travel now sits in a separate ‘Additional Scope 3 emissions’ category, outside the club’s targets and Net Zero trajectory. In effect, North London rivals Arsenal and Spurs are using the same UEFA guidance and arriving at different approaches.

Liverpool’s reporting is also unclear. Its sustainability report shows spectator travel on an uncategorised separate line from the three standard scope categories, without stating whether it is included in the baseline against which its 50% emissions reduction by 2030 target is tracked - a question that may reflect unclear public disclosure as much as an unclear internal position.

Not all clubs with net-zero targets have excluded fan travel. Manchester City includes it within its target boundary, though a planned baseline reset in 2026 means the current position may not be settled2. Wolves’ commitment to net zero explicitly includes fan travel within its target. In Germany, Borussia Mönchengladbach also includes fan travel in its target. VfL Wolfsburg includes fan travel in its carbon footprint and has a reduction target, but does not clearly state that fan travel is part of it. Other clubs currently without net-zero targets do report fan travel in Scope 3 - Juventus in Category 11 (Use of Sold Products), Brentford in Category 9.

Elsewhere, the DFL’s licensing framework requires clubs to collect greenhouse gas emissions data, set a reduction target, and actively support sustainable fan mobility - but is silent on whether fan travel should be included in reduction targets. Other governing bodies are taking a variety of approaches. UEFA’s 2026 Strategy Upgrade and its Carbon Reduction Plan are both silent on whether spectator travel sits within or outside UEFA's own 50% reduction target. FIFA included fan travel in its men’s World Cup 2022 greenhouse gas report but excluded it from its women’s World Cup 2023 report and has not published full and updated estimates for its upcoming tournaments. The Premier League also organises the overseas Premier League Summer Series, though it is not clear whether the fan travel consequences should be accounted for by the Premier League or by clubs.

The approach to both reporting and targeting of fan travel emissions varies, but among those who have made an explicit targeting decision, exclusion is more common than inclusion. What gets measured also varies significantly - sometimes between consecutive reports from the same organisation. Understanding why requires examining the frameworks these decisions are made under.

SECTION 2 - What the frameworks say

The decisions documented above share a common feature: each is taken by reference to external frameworks or methodologies. Testing whether they say what they are claimed to say is where the analysis turns next.

The GHG Protocol and the unresolved classification question

The GHG Protocol Corporate Standard underpins every other framework in this section. It has fifteen Scope 3 categories. Football organisations have most commonly sought to fit fan travel into Category 9 (downstream transportation and distribution), and occasionally Category 6 (business travel) or Category 11 (use of sold products). None of these categories was designed with spectator travel in mind - Category 9 mentions customer travel to retail stores as an optional item, the only sector the standard references3. UEFA’s own methodology, examined below, aims to address this gap.

Where customer travel to consume services - such as attending a sporting event - should sit was raised in the GHG Protocol’s Technical Working Group in September 2025. The Secretariat suggested optional inclusion in Category 9; a member immediately challenged this, noting that Category 9 is defined around transport of products, not customers travelling to consume services. No resolution was adopted. The public consultation expected in the second half of 2026 is an opportunity to address it. The pattern is not confined to football - the same unresolved gap in standard-setting architecture runs across sectors.

The UEFA Calculator Methodology

UEFA’s Carbon Footprint Calculator Methodology is now reportedly used by 176 organisations4, and is built on the GHG Protocol Corporate Standard.

The calculator methodology states that fan travel doesn’t fit standard categories - ‘as it is not under organisation control’ - and presents two options for handling it: inclusion within Scope 3 under an event-related “other” category, or placement entirely outside all three scopes. The document’s routing language points in different directions to these two options, and the varied practice across clubs using it reflects that5.

Chapter 5 states that even under the Out of Scope option, inclusion in reporting is advisable “in order to influence and drive emission reduction efforts,” and that fan travel emissions are “likely material.” In its own events reporting, UEFA Euro 2024 and Women’s Euro 2025 explicitly included spectator travel - though its seasonal Respect Report presents event emissions as a single aggregate figure with no fan travel breakdown.

Importantly, the methodology makes no target-setting recommendation whatsoever. Clubs and governing bodies citing it as recommending exclusion from targets are extending it to a decision it does not address.

The Race to Zero gap

Most clubs and governing bodies discussed here are signatories to the UN Sports for Climate Action Framework (UNS4CA), operating within the UN-backed Race to Zero campaign. Race to Zero’s Interpretation Guide states that net zero targets shall cover on average 90% of emissions including material Scope 3, and that any exclusion above that threshold should be ‘motivated and explained’. For clubs where fan travel represents the majority of total emissions, exclusion puts them above that threshold. None of the explanations reviewed for this piece meets that standard.

UNS4CA has never addressed fan travel specifically, leaving boundary decisions to signatory judgement - its silence is a mechanism through which clubs can avoid the coverage expectation. The IOC explicitly includes spectator travel in Paris 2024’s reduction target under the same framework; the International Surfing Association excludes it. Same framework, opposite decisions, both claiming alignment. Several clubs signed up to UNS4CA publish nothing on their emissions beyond what company law requires - for those clubs, the framework produces a target commitment with no disclosure to underpin it.

Think Beyond

Think Beyond, a sports sustainability consultancy, published a Carbon Methodology for Sport in June 2025. It provides an analysis that directly addresses target-setting: “Including fan travel in your 50% reduction target is optional, due to limited control and difficulties in measurement.” The challenges the report identifies are real: fan travel patterns are complex and variable; primary data can be difficult to obtain; and understanding of influence over individual travel decisions is incomplete. Think Beyond’s own resolution is to propose an engagement target as a substitute for an absolute reduction commitment.

Think Beyond’s core principles - grounded in the GHG Protocol - state that organisations should “disclose and justify any exclusions clearly” and provide “clear disclosure of assumptions, methods and data sources.” The few organisations that provide any explanation have already been noted. None fully meets the standard the guidance proposes.

SBTi and the validation gap

SBTi is the leading external validation mechanism for corporate net zero targets, and the body Arsenal cites as recommending excluding fan travel from its target (no further information is available detailing this). Under its current standard, fan travel’s GHG Protocol categorisation determines whether it falls within mandatory coverage thresholds for SBTi targets - and that categorisation remains unresolved. Even where emissions fall outside the mandatory minimum, SBTi encourages organisations to set targets on them if they are significant.

The forthcoming v2.0 of the standard moves in a more inclusive direction, proposing to require companies to account for all emissions even where they fall outside the GHG Protocol’s relevance principle, and recommending targets on optional emissions where significant. Whether that accounting requirement applies to emissions classified entirely outside the standard architecture - and whether v2.0’s new assurance requirement covers them - are questions football needs answered before v2.0 is published.

What every applicable framework does establish - and what none of the exclusion justifications address - is that relevant criteria for Scope 3 inclusion are materiality and relevance. Fan travel satisfies both at every club and governing body discussed in this piece.

What the frameworks say about influence over fan travel, and what clubs and governing bodies can actually do, are two different questions - and Section 3 examines both.

SECTION 3 - Control, influence and accountability

Whether football organisations have control over fan travel, and whether they have influence over it, are distinct questions. The control argument is widely cited as a reason to exclude fan travel from targets entirely - but it rests on a category error when applied to Scope 3 inclusion. The GHG Protocol defines Scope 3 emissions as those that by definition occur at sources not owned or controlled by the reporting company. Limited control is the normal condition of Scope 3, not a basis for exemption from it. The relevant inclusion criteria are materiality and relevance - not control. Fan travel satisfies both at each club and governing body examined in this piece.

The control argument does, however, raise a legitimate question about target design: if influence over fan travel is genuinely limited, what kind of target is appropriate? That is the question this section addresses - and the evidence is more complex than the low-influence ratings suggest.

Both UEFA's Calculator Methodology and Think Beyond rate organisational influence over fan travel as limited. UEFA scores it 'low to medium' for clubs and 'low' for national associations and leagues; Think Beyond treats inclusion in absolute reduction targets as optional 'due to limited control and difficulties in measurement’. These assessments are real and the challenges they identify are genuine: fan travel patterns are complex and variable; primary data can be difficult to obtain; individual travel decisions are shaped by factors well beyond any club’s reach.

But limited influence is not the same as no influence. And crucially, neither framework draws the conclusion that limited influence justifies excluding fan travel from accountability entirely - UEFA recommends inclusion in reporting anyway; the other permits an engagement target as a substitute. The question is whether an engagement target is an adequate response to emissions of this materiality. Think Beyond’s own appendix answers that directly: an engagement target carries no guarantee that emissions to the atmosphere will be reduced.

The sector’s own choices complicate the low-influence claim further. Clubs and governing bodies run fan travel surveys, incentivise low-carbon transport, work with local authorities to improve public transport options, and implement mobility measures at major events. UEFA’s own Euro 2024 mobility programme measurably shifted fan behaviour toward lower-carbon transport. Organisations do not invest resources in influencing behaviour they believe they cannot affect. The UK Climate Change Committee says that behaviour change can deliver “a 7% change in behaviour away from cars to public transport or active travel”.

A further significant question is what clubs and governing bodies structurally determine, as distinct from what individual fans decide. The structural decisions that most directly shape aggregate fan travel volumes sit primarily with governing bodies. Since the Paris Climate Agreement, UEFA has increased the total number of matches in its men’s European club competitions from 330 to 531 - a 61% increase - with directly foreseeable emissions consequences. The FA chooses to now stage FA Cup semi-finals at Wembley regardless of where competing clubs’ supporters need to travel from. Hosting the FIFA World Cup across three countries in 2026 and three continents in 2030 will have predictable impacts on fan travel emissions. Scheduling decisions by all governing bodies - kick-off times, fixture congestion, midweek European ties - shape fan travel patterns in ways clubs cannot control.

At club level, clubs cannot unilaterally determine how many competitive matches they play or where European away fixtures are held. But they exercise complete discretion over pre- and post-season friendlies - decisions with no governing body requirement attached and whose fan travel consequences are entirely foreseeable.

This summer, Tottenham Hotspur and Chelsea will play a match in Sydney - a decision entirely within both clubs’ discretion. Liverpool acknowledges that expanding Anfield’s capacity will increase fan travel emissions; Liverpool chairman Tom Werner has gone further - proposing overseas Premier League fixtures and committing to subsidise fan travel to them, describing this as making it ‘an attractive thing for the fans.’ Clubs can, on this account, actively engineer fan travel demand rather than merely respond to it. At match level, clubs have direct control over venue infrastructure, parking provision and pricing, ticket allocation, and transport partnerships - levers that directly affect modal choice and attendance patterns.

Each actor in football’s ecosystem can point to another as having important influence on fan travel volumes that they themselves do not - governing bodies to clubs’ commercial decisions, clubs to governing bodies’ structural choices. Individually, this provides a route through which low-influence claims can be constructed. Collectively, however, the system has substantial influence over fan travel - and no single organisation within it is required to account for it. That gap is not a technical inevitability - it reflects choices made, and not made, by every actor: about how to operate within the system, and about whether to push for a different one.

The positions stating low influence are not false - they are incomplete. The fuller picture is of organisations that actively shape fan travel through structural decisions, invest in influencing modal choice, and can demonstrably shift behaviour when they choose to. That is not the profile of organisations with no meaningful accountability for these emissions - nor one where engagement alone is a sufficient response to them.

SECTION 4 - Consequences and asks

The most direct consequence is that emissions which could be reduced are not. When the largest single source of a club or governing body’s footprint sits outside the accountability structure, no internal mechanism connects decisions to emissions performance. Competition expansion, venue selection, scheduling choices, overseas commercial tours - all these and more are made without any internal climate consequence.

The substitution of activity for outcome is incentivised. A club can meet every engagement target - surveys conducted, awareness content published, partners engaged - while its fan travel footprint grows.

Three upcoming processes will shape whether fan travel continues to fall outside football’s accountability structures. The Premier League has committed to a common greenhouse gas emissions dataset by end of season 2025/266. The GHG Protocol’s public consultation on the revised Scope 3 Standard is expected in the second half of 2026. SBTi’s Corporate Net-Zero Standard v2.0 is expected to be published in 2026 and mandatory from 2028.

Recommendations

One recommendation stands apart. This piece treats fan travel as an analytical category - emissions to be counted, excluded, or targeted. The fans producing those emissions have largely not been part of the conversation. What they are doing, willing to do, the barriers they face, and what structural changes they would support are questions that fans have not been engaged on beyond survey questionnaires. Deeper, structured engagement and co-design can have a much bigger role to play.

The Premier League

The upcoming dataset should require fan travel as a named, separately reported line in every club’s submissions, with estimation methodology stated. Unresolved questions elsewhere about how to classify fan travel emissions are not a reason to defer committing to reduce them - categorisation can be revisited as standards develop; the accountability commitment should not wait for it. Any exclusion should require a motivated explanation and an outcome metric.

UEFA

UEFA should state publicly that its Carbon Footprint Calculator Methodology makes no target-setting recommendation, and that clubs citing it as recommending exclusion from targets are extending it to a decision it does not address. It should clarify whether the Out of Scope classifications are consistent with GHG Protocol principles and whether spectator travel to UEFA events sits within its own 50% reduction target.

The FA

The FA’s planned fan engagement target should include at least one outcome metric with a defined baseline and reduction commitment - as a minimum. An engagement target without an outcome measure is not a climate commitment; but an outcome metric alone is not a substitute for an absolute reduction commitment on fan travel. Through its cross-football working group with the Premier League, other UK football bodies and the Government, The FA should ensure a common and proportionate approach to fan travel accountability applies across the football pyramid.

FIFA

The 2026 World Cup will generate fan travel emissions on a scale that dwarfs every club-level figure in this piece. FIFA’s 2021 Climate Strategy commits to developing a standardised greenhouse gas accounting methodology for its tournaments, but addresses fan travel only through an awareness and offsetting programme. FIFA should confirm fan travel is included in its net-zero by 2040 target; apply that methodology consistently and with independent verification across all tournaments; publish tournament-level fan travel emissions data as part of its planned bi-annual Climate Reports; require bidding host nations for tournaments to submit quantified emissions projections that are then assessed, including specifically on fan travel; and make a formal submission to the GHG Protocol’s 2026 public consultation on the classification of spectator travel.

GHG Protocol

The public consultation expected in the second half of 2026 is the opportunity to resolve the classification of spectator travel directly. Football stakeholders - clubs, governing bodies, supporter groups, and independent researchers - should make formal submissions.

SBTi

SBTi should clarify, before v2.0 is published, whether the exclusion justification requirement applies to emissions placed entirely outside all three scope boundaries - not just to exclusions within named Scope 3 categories.

Individual clubs

Clubs do not need to wait. Where there is genuine uncertainty about measurement, that uncertainty should inform target design - not serve as a reason to exclude the largest emissions source from accountability. A target set against an estimated baseline, with commitment to improve data quality over time, is more credible than no target (see ‘Endnote’ below) - and is what the GHG Protocol’s own guidance recommends.

Most clubs have not yet set an emissions reduction commitment of any kind. Among those that have, fan travel is typically excluded or left ambiguous. The governance framework examined here has made each position easy to sustain - no binding requirement, no common methodology that rules out exclusion, no accountability mechanism that distinguishes a justified boundary decision from an unjustified one. That is what needs to change. The burden of justification should sit with exclusion, not inclusion. The hardest recommendation, and the most necessary: all major clubs should set an emissions reduction commitment that includes fan travel.

END

Endnote on this analysis

Setting targets is necessary but not sufficient. What credible delivery of those targets requires — including football's dependence on decarbonisation happening elsewhere, particularly in the transport sector — is the subject of a separate piece in this newsletter available here.

This piece has grappled with complex and in places unresolved questions. The analysis is built in good faith from primary sources, but reasonable experts may read the same documents differently.

Responses from practitioners, fans, and researchers who can identify errors, supply additional evidence, or offer alternative readings are actively welcomed. The goal is a debate conducted with precision - not a verdict delivered without challenge.

Subscribe now

Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
LinkedIn | Bluesky | X

Over three years on, a lot has followed from that question. What began as a way of helping me and others make sense of a scattered landscape has become something I didn't anticipate - analysis that's been cited in Parliament, picked up by specialist media, and read by people inside the organisations being scrutinised.

And it's still free.

But it isn't free to produce. There's no funding from organisations - just my time. The research, the reading, the drafting (and, oh, the endless redrafting!) takes real time. And the independence that time brings, is what makes it worth anything. To be upfront, it's not something I can sustain indefinitely. That's why your support matters.

If the newsletter has been useful to you - if a post made you think differently, gave you something to share, or helped you make a case - I'd be grateful if you'd consider making a contribution.

You can do that here: ko-fi.com/footballandclimate

Any amount helps. And if now isn't the right time, the best thing you can do is share the newsletter with someone who should be reading it.

Either way, a big thanks for being here.

Fran

Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
LinkedIn | Bluesky | X

All of this left a bigger question open - one touched on in other posts here:

What would a credible decarbonisation pathway for European football actually look like - who develops it, on what evidence, and who takes responsibility for it? UEFA’s repositioning from collaborative net-zero leader to advocate makes the question more urgent, not less.

This piece doesn’t attempt to develop that pathway. It makes the case that one needs to exist, examines what it would have to grapple with, and asks - openly - who should develop it.

1. What a sectoral pathway is, and what it isn’t

You may have come across the words “pathway” and “roadmap” used in different contexts in climate discourse - and often interchangeably. It’s worth being precise about the distinction.

Put simply, a sectoral decarbonisation pathway is an analytical foundation. It maps where a sector needs to get to, in line with limiting global warming to 1.5°C, the central goal of the Paris Agreement, and what the terrain looks like: the timelines, conditions, dependencies and constraints. It is not a plan, a strategy, or a commitment. It is the evidence base that makes credible plans possible.

Built on top of a pathway sits a roadmap: the implementation layer that translates analytical findings into high-level sector-wide actions, timelines and responsibilities. In practice, the two are often developed as a package rather than in strict sequence, with the labels frequently conflated even where the underlying concepts are distinct. This piece focuses on the pathway, though there is a strong case for the two to be developed together. The roadmap deserves its own detailed treatment - this piece sets that aside deliberately, but it is the necessary next question once the pathway case is made.

Individual organisations then develop their own “transition plans”1, the organisation-level commitments, targets and strategies required under recognised frameworks, grounded in what the sector-level analysis says is necessary.

Football currently lacks all three layers. While some clubs and bodies are developing transition plans, the numbers are small and approaches inconsistent. And critically, without either pathway or roadmap beneath them, those commitments - however well-intentioned - are developed without an external reference point that would make them collectively meaningful. Without a pathway, roadmaps are built on sand, and there is no way to ensure individual transition plans are either sufficient or effective at sector level.

It is worth being clear about where UEFA’s documents sit in this hierarchy. Its Sustainability Strategy and its Carbon Reduction Plan, which together represent UEFA’s most substantive climate commitments, both sit at the third tier, the level at which genuine transition plans should operate. But neither meets the standards set by recognised external frameworks2. The sustainability strategy sets direction without the analytical foundation to make it credible, and the Carbon Reduction Plan lists operational measures without the milestones, governance or scenario analysis that a transition plan requires. UEFA has some of the architecture of the third tier. It does not yet have its substance.

Other sectors have done this work - with instructive results. The World Resources Institute’s apparel roadmap and the World Travel and Tourism Council’s net-zero roadmap offer some methodological parallels: consumer-facing, multi-actor sectors with fragmented governance, where the pathway and roadmap work created both a shared analytical foundation and an accountability infrastructure. Neither is a perfect template - the approaches are not lift-and-shift methodologies, and neither sector is on track for 1.5°C. But in apparel, for instance, the number of companies with approved science-based targets has grown from a dozen in 2019 to over 600 today, and the annual progress tracking means the gap between ambition and delivery is visible, attributable, and contested. That is what accountability looks like. Football is not near that stage.

2. Why other sectors have pathways and football doesn’t

The sectors that have done this work share some common features. They are large enough to matter to investors and policymakers. Their emissions are distributed across many actors rather than concentrated in a few producers. And they face genuine governance complexity: no single body can simply mandate a solution.

That description fits apparel, tourism, food and retail, and events. These are not easy sectors to decarbonise. But they have made the analytical investment.

Football has not - and nor, it should be said, have most other sports. Football is economically significant, of unparalleled cultural importance, and governed through a layered web of clubs, leagues, national associations and international bodies where no single actor controls the whole. If anything, that complexity makes the analytical foundation more important, not less.

Relatedly, UEFA provides a common carbon accounting tool which, as adoption grows, could contribute to the evidence base a pathway would need. But the calculator is voluntary and focused on organisations competing at European level. Its guidance on fan travel - the largest source for most clubs and events - explicitly allows spectator travel emissions to be excluded from reported metrics and targets entirely. It also references the Paris Agreement as motivation, but does not define what a 1.5°C-consistent outcome for the sector would look like. Each actor can claim progress while the aggregate picture remains unmapped.

At the same time, there is a growing body of baselining work - the Wilby meta-analysis, the WEF/Oliver Wyman Sports for People and Planet report’s estimate of 400-450 million tonnes of CO₂e annually for sport as a whole, and others - though gaps remain. Alongside this, specific emissions hotspots, such as fan travel, embodied emissions and merchandise, are increasingly well understood. What does not yet exist is the next analytical step.

A full understanding of why football has not taken this step is beyond the scope of this piece, but part of the answer lies in governance. Football’s governing structures have been characterised in European Commission and UK Government analysis as layered, with often competing authorities, misaligned incentives, and a long record of failed self-regulation. This makes collective analytical investment structurally difficult. No single body has both the authority and the incentive to commission work that maps what the sector needs to do. That shift in UEFA’s position - from collaborative net-zero leader to advocate for voluntary action - is less a cause of that gap than a symptom of those deeper structural issues.

3. What makes football’s analytical challenge distinctive

Even setting aside governance, building a pathway for European football involves a particular set of analytical challenges - some shared with comparable sectors, others more specific to how football operates. This piece does not attempt to catalogue them all; that is work for the pathway itself. But three are worth examining here.

The most significant is dependency. Fan travel is football’s largest source of emissions for many clubs and events. Facility energy is a significant source too, though the picture beyond that is less clear - stadium construction and refurbishment, merchandise, and capital goods all compete for relevance depending on which emissions reporting boundary is chosen. What many of these sources share is that they depend heavily on decarbonisation happening elsewhere: in the wider transport system, in the electricity grid, in supply chains football does not control.

A football pathway cannot simply assume those transitions happen on schedule. It has to engage with them. For example, on aviation, the challenge is not just timing but credibility. The main European aviation industry roadmaps, such as Destination 2050, rely heavily on sustainable aviation fuel scaling at a pace and cost that some respected independent analysts consider optimistic, and treat continued passenger demand growth as essentially given. More analytically rigorous frameworks are more transparent about uncertainty - including analysing demand management as a lever. On road transport, even if EV adoption proceeds as projected, it does not translate automatically into sufficient reductions in emissions from fan travel - electric cars still fill car parks, shifting mode share is a further dependency too.

This is the pathway of pathways problem: a credible football pathway is partly an exercise in understanding how football sits within, and depends upon, other sectors’ decarbonisation trajectories - and what happens when those trajectories fall short.

A second challenge is scope. What emissions does a pathway for European football actually cover? For example, fan travel is the largest source for many clubs and events, yet the dominant accounting framework - UEFA’s Carbon Footprint Calculator - explicitly recommends that spectator travel emissions be reported ‘separately, if at all, and not added together with other Scope 3 categories.’ This has provided the basis for some clubs and bodies to exclude fan travel from their targets. A pathway analysis would need to look rigorously, expertly and independently at what boundaries should be set - and to justify that position transparently.

This matters because rigorous climate accounting has a clear hierarchy: organisations should reduce emissions across all scopes as far as possible - including addressing the difficult decisions - before addressing residual emissions: those that remain after all practical reductions have been made. Those decisions, on fan travel, competition format, calendar design, are precisely what a pathway needs to interrogate first, and what a roadmap built on top of it would then need to translate into action. Resolving the scope question is therefore not a technical preliminary; it is part of the pathway’s core analytical purpose. A pathway has to take a position. Leaving things open replicates current issues rather than solving them.

A third dimension is easy to understate. Football is watched, followed and loved by billions of people. The choices it makes, about where matches are played, how fans travel, which sponsors it accepts, are visible in ways that most sectors’ choices are not. When football makes choices such as flying to overseas pre-season tours, expanding already demanding competition schedules, or hosting finals in locations that require long travel distances, it normalises those choices at scale. When it does the opposite, the signal travels further than the direct emissions saving. That cuts both ways for a pathway: it is an argument for taking the work seriously, and a reason the pathway needs to be analytically credible rather than merely presentable.

4. What a football pathway would need to address

With those challenges in view, what would a pathway actually need to do?

A pathway for European football would not start from scratch. There is now a sufficient body of baselining work - on emissions sources, hotspots, and sector comparisons - to review and build on. What it would need to do is take that foundation further in directions that existing work has not.

It would need to model alternative futures, not just describe the present: what do European football’s emissions look like in 2030 and 2040 under different assumptions on issues such as competition formats, the number of games played, travel patterns and venue energy, among others? What does a 1.5°C-consistent trajectory actually require the sector to do, and by when?

It would need to stress-test decarbonisation scenarios in sectors such as transport, aviation and energy, rather than assuming them as given - football cannot build its pathway on the assumption that hard-to-decarbonise sectors will simply stay on track - or that their decarbonisation will automatically resolve football’s.

It would need to address the demand-side questions that current football climate strategies fail to address - such as what competition format means for emissions, and what the implications of changing the number of games may be. These are not peripheral - they may be among the most consequential climate decisions football makes3. A sector pathway that tries to detour around its hardest terrain is not a roadmap to net zero - it is a road to nowhere.

It would need to establish a sector-wide emissions baseline that takes a clear and defensible position on scope - being explicit, for instance, on how fan travel emissions are treated rather than leaving that to the discretion of individual organisations.

It would need to engage with how the challenge is distributed across the pyramid. The emissions profile of a Champions League club is very different from a lower-league or grassroots club. Women’s football is growing rapidly and represents a planning opportunity that a pathway built only around the elite men’s game would miss. Any serious analytical exercise needs to address the full pyramid, and to ask honestly who bears the costs of transition and whether that is fair. It would also create a shared basis for understanding which actions are delivering genuine emissions impact - and which are not.

And it would need to grapple with a football-specific governance dependency that sits alongside the transport and energy dependencies discussed in the previous section: the relationship with FIFA4. European clubs and national teams operate within a calendar and ruleset that UEFA does not fully control. FIFA sets the international match calendar, determines World Cup formats and host nations, and runs the expanded Club World Cup. A European pathway that models competition format and calendar emissions cannot treat these as purely UEFA decisions - some significant emission-related decisions in European football cannot be addressed without FIFA’s involvement.

It must therefore also be explicit about where the limits of European governance lie, and what that means for the ambition and scope of the work.

A pathway cannot resolve the key debates. Nor does this list exhaust the terrain it would need to cover. But it needs to confront the hard questions honestly rather than design them out.

5. Who should develop it

If the case for a European football sector pathway is accepted, the next question is who should develop it. There are at least three broad options, each with different implications for credibility, feasibility and speed.

The strongest option, institutionally, would be a joint commission involving the European Union and UEFA, with independent analytical support. The EU has established precedent for this kind of work: its Transition Pathways process has produced co-created, multi-stakeholder decarbonisation frameworks across more than a dozen sectors, with Commission officials and sector bodies co-chairing the analytical process.

Importantly, a 2022 voluntary cooperation agreement between the Commission and UEFA explicitly includes climate action as a shared objective - and with that agreement now being actively renewed, there is an imminent institutional moment where climate ambition could be written into the formal relationship rather than left as a voluntary aspiration. The EU Work Plan for Sport 2024-2027 and its following cycle, and the EU’s Green Sport Expert Group, provide further existing infrastructure. This option is not institutionally narrow, and it is not football marking its own homework.

The second option is a UEFA and European Club Association-led exercise. This would be faster to convene and more directly connected to the decision-makers who control competition formats, calendars and commercial relationships. But it raises a credibility flag. The ECA represents clubs whose governance structures are oriented toward short-term commercial cycles - the very conditions that make long-term analytical work on these questions difficult to commission, and harder still to act on. A process led jointly by UEFA and ECA would need to demonstrate that independence, in particular, through its governance.

The third option is a broad coalition - independent, multi-stakeholder, drawing in independent expertise (academic, environmental and civil society) alongside football governance. No single convener is named here deliberately. This piece is itself an argument for that work to happen. But the case has been made. If institutions exist with the capability, the credibility and the appetite to lead this work, the question is no longer whether it is needed - it is whether they will step forward.

Whichever route is pursued, the process would need to be designed with clear eyes about the pressures bearing on all participants - commercial, sporting, political, regulatory and reputational - engaging with them honestly in the analytical work, while remaining free to follow the evidence wherever it leads. The analytical work could encompass pathway and roadmap together - the case for developing both as a package is strong, and the precedent from comparable sectors supports it. Any process would also need to engage external stakeholders - including FIFA, whose jurisdiction over significant areas of European football means some emission-related decisions fall outside UEFA's control. Engaging FIFA would strengthen the work; the absence of that engagement would need to be explicit about what a European pathway can and cannot address.

6. Close

The argument of this piece is simple, even if the work it calls for is not. European football is a sector of significant emissions, unparalleled cultural influence, and profound governance complexity. It has targets. It has frameworks. It has many initiatives. It has a growing body of baseline analysis. What it does not have - as the framework above makes plain - is a Paris-aligned, system-wide decarbonisation pathway - the analytical foundation that would make everything else coherent.

That gap has real consequences. Without it, individual organisations develop plans and set targets against unmapped terrain, draw scope boundaries that reflect the discretion current frameworks allow, and point to progress that may not add up to anything at sector level. The gap left by UEFA's repositioning away from collaboration makes the underlying issue more visible, but it did not create it.

Building the pathway will require grappling with questions that football’s leaders have not yet fully faced: about what emissions the sector is genuinely accountable for, about the decisions that drive its largest footprints, about what a fair distribution of the transition effort looks like across the pyramid. None of that is straightforward. But other sectors - with comparable complexity, comparable governance challenges, and no fewer commercial pressures - have done it.

As set out in the opening of this piece, a pathway is the foundation - the analytical work that makes a credible roadmap possible, and credible transition plans possible after that. The two could credibly be developed together, but the pathway has to come first - and European football currently has neither. That is where the work has to begin.

The question this piece leaves open is not whether European football needs one. It does. The question is who steps forward to deliver it - and whether they do so with the independence, the analytical rigour, and the genuine climate leadership the task requires.

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Fran James (he/him)
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UEFA’s Sustainability Strategy “2026 upgrade” marks a shift in how it approaches sustainability in European football. It strengthens measurement and the management of activity, but weakens ambition by removing a crucial long-term net-zero target, without replacing it with an equivalent quantified end-point.

Beneath the language of “impact performance”, the strategy repositions UEFA from setting clear a decarbonisation destination to providing guidance, coordination and advocacy within a more club-centred model.

The result is a strategy that is more operationally structured, but less clearly aligned with delivering emissions reductions at the scale required. Without a defined end-state, a gap emerges between improved measurement and the system-level direction needed to drive meaningful climate outcomes.

Introduction

UEFA has published an update to its 2021 Sustainability Strategy, described as a “2026 Upgrade”. In practice, it incrementally improves how sustainability is operationally tracked and delivered, but weakens what it is ultimately trying to achieve.

The clearest illustration of this shift is the change to its core emissions target. The analysis below first examines that change, before placing it in the context of UEFA’s broader strategic repositioning and governance context, and then considers alternative approaches and their implications.

Net zero target

While the strategy makes no explicit reference to a change in target or its rationale, a consequential shift has taken place. The 2021 strategy committed UEFA to:

“Cut greenhouse gas emissions by 50% by 2030 – in view of achieving net zero carbon by 2040 within UEFA, across UEFA events, and collaboratively across European football.”

The 2026 version now states UEFA will:

“Accelerate action on the road to reducing greenhouse gas emissions by 50% within UEFA and across UEFA events, and advocate action across European football.”

The removal of the 2040 net-zero target from the strategy is a material shift. It removes a clear defined outcome and replaces it with process, weakening alignment with wider transitions, including the EU’s 2050 climate neutrality goal and its proposed 2040 trajectory.

Without a clearly articulated destination, this risks becoming a rolling programme of initiatives - activity without a defined end-point or accountability. Even if UEFA were to restate or locate such a target elsewhere, its absence from the core strategy would still raise questions about how it informs priorities, decisions and accountability in practice.

This is a prime example of what Net Zero Tracker has described as a “Schrödinger’s Net Zero Target”, where commitments appear intact from the outside but, on closer inspection, no longer operate in their original form. It also runs counter to a broader trend of organisations strengthening, rather than diluting, net-zero commitments - making UEFA’s shift more conspicuous, not less. (see here and here).

The absence of the target in the strategy also creates tension with its position in the UN Sports for Climate Action Framework, which includes a net-zero-by-2040 commitment. UEFA may remain a signatory and argue that this commitment still stands at a framework level. However, strategies are the primary mechanism through which such commitments are operationalised. Omitting the target from the strategy therefore raises legitimate questions about how that ambition translates into UEFA’s priorities and decisions1.

This signal is likely to be interpreted differently across clubs and national associations. Clubs leading on net-zero may continue on their current trajectory. However, for others - particularly those at earlier stages or without a net-zero target - it removes a source of central direction and weakens the collective signal. In a system shaped by norms as well as regulation, such shifts can influence the pace and consistency of progress.

To understand how this position has emerged - and how it might have been handled differently - it is first necessary to place the strategy in the context of wider developments within UEFA.

UEFA’s Strategic Repositioning

UEFA frames the strategy as a shift from “ambition to impact…[and] an accelerated move from aims to outcomes, designed to maximise positive impact”. At its core, this reflects a repositioning of UEFA’s role within a football ecosystem of clubs, national associations, commercial partners and other stakeholders.

In practice, this marks a move away from UEFA acting as a body that sets direction and holds the system to account, toward one that convenes, supports and influences.

From authority to advocacy

The language shift is telling: the original strategy’s emphasis on “working collaboratively” to UEFA-set targets gives way to “advocating action”. Progress is no longer anchored in clear, centrally defined end-points, but in alignment across a diverse set of actors. UEFA is moving from transition architect to transition facilitator - focusing on coordination rather than direction. This may reflect the practical limits of its authority as it sees it within a more club-centric system, including evolving legal and governance constraints. However, it also leaves a gap: facilitation can enable progress, but does not by itself define the level or pace of change required.

This shift is also reflected in the October 2025 Sustainability Cooperation Plan agreed between UEFA and European Football Clubs (EFC), the body representing leading clubs. The plan formalises co-delivery and shared agenda-setting, focusing on supporting clubs, scaling practices and sharing knowledge. The emphasis is on enabling existing actions rather than defining system-wide limits, requirements or targets.

While EFC’s sustainability work is evolving, it has so far focused more on implementation of existing commitments and sharing practice than on defining impact targets for clubs - reinforcing the shift away from centrally defined outcomes.

At one level, this shift by UEFA reflects a pragmatic recognition of where operational control and influence over emissions largely sit: with clubs. But it also reflects a broader evolution in governance, in which EFC has assumed an increasingly central role alongside UEFA through long-term agreements, joint commercial structures and co-decision-making on key aspects of European club competitions.

Limits of the current model

The implication is clear: advocacy is not the same as authority. It places greater reliance on voluntary alignment in a system where incentives are not always aligned with emissions reduction, and where mechanisms to shift those incentives remain limited. Authority sets direction and can enforce accountability; advocacy relies more on alignment and voluntary action.

This is reflected in UEFA’s commitment to “develop guidelines to help member associations, other football organisations and clubs develop, implement and communicate their own sustainability approach”.

While UEFA retains the lever of club licensing criteria, these have so far been applied in a relatively light-touch, process-focused way on sustainability, emphasising the establishment of organisational sustainability roles and strategies across national associations and clubs. This represents a meaningful step in embedding sustainability within football’s structures. However, the updated strategy shows limited indication of how this approach might now evolve toward more outcome-driven requirements. In a more club-centric system, utilising this licensing mechanism remains one of the few routes to translate strategy into binding expectations aligned with emissions reduction.

The result is a strategy that reflects what is perceived by UEFA as achievable within football’s governance and commercial realities: more operationally structured, but constrained by the distribution of power and incentives within the game.

Alternative approaches to net-zero

The removal of the net-zero target sits within this broader strategic reset. Alternative approaches to a net-zero target were available.

An organisational net-zero target

The removal of the net-zero target is especially notable given UEFA’s narrow emissions boundary - focused on its own operations and selected events, and excluding major sources such as spectator travel from club tournament finals.

In that context, maintaining an organisational net-zero target would not have required system-wide transformation. While delivery would still involve complexity and reputational risk, particularly around major events, it would have remained within UEFA’s control and influence and provided a clear directional signal within its limited emissions boundary.

For example, UEFA could have committed to aligning its operations and events with a 1.5°C-consistent pathway, reaching organisational net zero by 2040, while making clear that wider decarbonisation requires additional commitments from clubs, leagues and associations.

Removing an end-target does not simplify delivery so much as reduce accountability. UEFA may argue that improved data and tools justify a shift toward implementation over target-setting. However, these advances also make it more feasible - not less - to define and track progress against a clear destination.

Reinstate a net-zero target for football

The simplest approach would be to reinstate the target, either in its original form or reworded to reflect UEFA’s shift toward advocacy. However, reinstating the 2040 target or tweaking its wording would not be sufficient on its own.

I have previously suggested in this newsletter that the UN Sports for Climate Action Framework target was based more on ambition than detailed sectoral analysis, reflecting the period in which it was set. In that respect, UEFA is right to move beyond aspiration and take stock four years on from its original target and strategy.

A credible alternative could have been to retain 2040 as a guiding reference point for UEFA’s own footprint, while committing - by a fixed date - to develop a quantified, football-wide decarbonisation pathway clarifying roles, milestones and trade-offs.

An evidence-based pathway for football

UEFA’s approach has included stakeholder consultation. This is necessary but not sufficient. A critical stage appears to have been skipped: a clearly articulated, evidence-based analysis of where European football stands and where it needs to get to. While such analysis may exist internally, its absence from the strategy makes it difficult to assess whether current actions align with the scale of change required.

I have previously argued for a robust, system-wide quantified analysis to underpin a clear decarbonisation pathway for football. This could include defining the scale of the challenge, the roles of different actors, dependencies, the distribution of power and incentives across the system, including beyond it, and the trade-offs required.

That step - turning fragmented progress into a coherent, system-wide pathway grounded in analysis - is absent, but critical. It would align with a broader trend of recalibrating net-zero commitments through greater rigour rather than retreat. Given its convening role, data access and regulatory influence, UEFA is a natural candidate to lead or commission this work. If UEFA’s absence in this space continues the question becomes who if anyone will assume that role?

Summary

Taken together, these shifts point to a strategy that is more managerial in how change is organised, but less clear - and less demanding - on the scale required. By moving away from collaborative targets toward shared advocacy, UEFA is, in effect, stepping back from setting system-wide direction at precisely the moment greater alignment with science is needed.

The removal of the net zero target makes this clear: not simply as a technical adjustment, but as a signal. In a sector with global visibility and cultural influence, targets do not just guide internal action - they shape expectations, norms and ambition across the game and beyond. Without that signal, the risk is weaker accountability and a broader softening of what football understands as its responsibility in the transition to a low-carbon future.

In the absence of clear outcome targets, UEFA’s vision of “impact performance” risks becoming a measure of activity rather than outcomes, particularly where no quantified end-state defines success. Measurement is most effective when anchored to defined end-points; without that anchor, it risks becoming self-referential rather than directional.

If UEFA is no longer prepared to define what a Paris-aligned pathway for European football looks like, the question is who will - and whether they will have the legitimacy, tools and urgency to do so. If UEFA or no other actor steps forward with both authority and ambition, the risk is not just slower progress, but a transition shaped by fragmented and ultimately insufficient action in football.

A further section below takes a look at additional points in relation to the revised strategy.

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Additional considerations

2030 Target

The weakening of ambition is not limited to the removal of the net zero target. The 2030 framing has also shifted - from a clear commitment to a more open-ended call to “accelerate action on the road to”. While subtle, this reduces precision and accountability. Taken together, the softened 2030 and 2040 framings mark a step back from time-bound, outcome-based governance toward a looser, activity-based model.

KPIs

Many of the new ‘impact performance’ metrics represent incremental evolution rather than step-change. In several cases, they formalise processes already adopted by leading clubs and competitions. This reinforces the sense that the strategy is catching up operationally rather than setting ambition. At the same time, the metrics are evolving faster than the underlying ambition - a marker of a strategy optimising what is easiest to count rather than what is hardest, but most necessary, to change.

Partners

Many of UEFA’s major commercial partners position themselves as climate leaders, with net-zero targets, science-based 2030 pathways and roles in global climate alliances. Against that backdrop, UEFA’s decision to drop its own net-zero framing creates an awkward contrast: sponsors are tightening and progressing their trajectories while UEFA is softening its long-term signal. This risks diluting the credibility of joint campaigns and creating tension with partners whose strategies depend on clear defined outcomes UEFA no longer provides.

In addition, the strategy does not engage with growing scrutiny of high-carbon sponsorships, including calls from the UN Secretary-General to restrict or ban fossil fuel advertising. This highlights a wider gap between UEFA’s climate positioning and the commercial structures that underpin the game.

Adaptation

The strategy remains focused primarily on mitigation, with limited attention to adaptation and resilience. Given the increasing physical risks facing football - from extreme heat to flooding - this is a notable gap. Recent European analysis highlights the urgency of coordinated adaptation planning. A future-proof strategy would pair mitigation with a clear adaptation standard for competitions and infrastructure, including extreme heat protocols, facility resilience and climate-related disruption to calendars.

A bottom-up approach and capital allocation

The strategy introduces concepts such as a more “bottom-up” approach and targeted capital allocation, but provides limited detail on how these will operate or be measured. Without clearer mechanisms and criteria for prioritisation against climate outcomes, these risk remaining high-level principles rather than actionable levers - more narrative than genuine drivers of change.

Mitigation hierarchy

A further gap is the absence of a clear mitigation hierarchy - how reductions are prioritised between cutting emissions at source, substituting activities, and only then considering compensation. This matters in practice. UEFA has already pointed to solutions such as Sustainable Aviation Fuel, which may play a role in aviation emissions. However, without a defined hierarchy, there is a risk of prioritising high-profile or technologically appealing options over demand reduction or structural change.

A credible approach would also clarify how residual emissions - those that cannot be eliminated - are minimised and addressed. The new strategy emphasises measurement, but not how actions are prioritised. The result is a framework in which visible interventions risk being treated as equivalent to deeper emissions cuts - reinforcing a shift from outcomes to activity.

Final note

This analysis focuses on the climate dimension of UEFA’s sustainability strategy and does not address other important areas that warrant equal attention, including anti-racism, football for all abilities, and solidarity and rights.

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Football and Climate Change Newsletter
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This post focuses on English men’s professional football and on a key part of the new Independent Football Regulator’s (IFR) work: assessing the state of the game.

At the same time, the core point is transferable across all of football - climate risks have important financial impacts, and the game has barely started to understand, quantify, and respond to them.

Context

English football is about to get its first ever State of the Game report, produced by the new IFR set up by the UK Government. The report is intended to take a hard look at the main pressures on the game and ask whether any of them threaten the regulator’s core objectives: financially sustainable clubs, a resilient pyramid, and protection of football’s heritage.

The Chair of the IFR says that “The game has never been examined like this before … [and the report] … will give football the clarity it deserves, so decisions by the IFR can be made with confidence and for the long-term.” The IFR’s chief executive adds that it “will be the most in-depth assessment of the football industry ever conducted” to “scrutinise decisions, challenge existing practices, and ensure clubs meet expected standards.”

This makes it critically important that the State of the Game report is fit for purpose in its focus. The IFR is taking a staged approach: a draft report later this year, a final report in 2027, and then new reports every five years. They are currently consulting on the terms of reference for this work (closing 17th February 2026), and I’ve submitted a response.

Consultation response

In summary, my response makes five key points:

• Inclusion of climate risk: The State of the Game report should directly analyse climate-related financial risks to English football. Climate change poses material threats to both football’s systemic resilience and individual clubs.

• Macroeconomic context: UK authorities recognise climate change as a major macroeconomic and financial stability risk. For instance, the Bank of England says “climate and transition shocks increasingly shape the macroeconomic outlook and financial risks”. The IFR’s State of the Game report Terms of Reference explicitly includes “resilience to macroeconomic shocks”. Omitting climate factors would therefore be inconsistent with that focus.

• Sectoral linkages: Climate risks compound football’s economic vulnerabilities (e.g. broadcast revenue, debt, reliance on outdoor matches). Research for the UK Government’s Department for Culture, Media and Sport estimates that weather‑related disruption already costs UK grassroots sport over £320 million a year. Recent analysis by the World Economic Forum suggests over 90% of media rights and most sponsorship revenue in professional sport depend on outdoor activities, putting these income streams at direct risk from environmental disruption. My consultation response also looks in-depth at one of these vulnerabilities as an example: debt and credit vulnerabilities.

• Club disclosures: Several top Premier League clubs and The FA already report climate-related risks in their financial statements, albeit inconsistently. This shows climate factors are financially relevant, creating a need for IFR analysis of them and of clubs’ climate-related financial controls.

• Distributional impacts: Climate impacts vary across the football pyramid. Wealthier clubs can invest in resilience and access favourable financing. Lower‑league clubs already see more postponements and face higher relative costs, with less capacity to adapt. Given the IFR’s remit on financial soundness and revenue distribution, the State of the Game report should examine how climate risks and adaptation capacity are distributed across the pyramid.

These points are explained in more detail in my consultation response, each linked to the IFR’s statutory objectives and Terms of Reference.

Following on from them the response concludes with five key recommendations. The IFR should:

• Explicitly include climate risk in its macroeconomic analysis

• Commission an independent analysis of climate impacts on football finances

• Integrate climate risk into financial soundness assessments and licensing (proportionally, reflecting club sizes and resources)

• Address distributional concerns through monitoring and dialogue

• Engage with relevant financial regulators to understand how climate-related lending and insurance practices could affect club financing

To ignore climate risks would be out of step with how financial risk is already understood elsewhere in the economy, and would leave football detached from economic realities. This is not about regulator scope creep. It’s about examining these issues through the strictly financial lens that proponents of the IFR have called for. From the macro to the match level, the case is clear.

You can read my full response to the State of the Game Terms of Reference consultation here.

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WEF reports are written particularly for senior leaders and policy people. Oddly, sport-and-sustainability analysis targeted for this audience has been largely absent until now. It means that this report matters both in its own right and also because it is important to understand the latest thinking being targeted to global leaders.

The sports economy: scale and structure

The report’s headline focus is on the long-term growth of the sports economy, and how rising physical inactivity and escalating environmental pressures could undermine it. The “sports economy” is defined in the report as having four core industries. Three of the industries stand out in terms of their current size by revenue: sports tourism ($672bn), sporting goods ($614bn), and participatory sport and physical activity ($560bn). The fourth, “professional and elite sport”, is relatively small, at $140bn, which was a bit of a surprise to me, but maybe shouldn’t have been. Other connected industries contribute a further $0.3tn in annual revenue.

While the report describes these industries and their interdependencies, a minor but relevant gap for me is that it does not clearly quantify overlaps - for instance, how much of sports tourism or sporting goods spend is directly driven by elite sport? More importantly, it would have been valuable to include quantified environmental impacts by core industry segment too, to show how revenue and footprint align.

That said, the report cites an aggregate emissions estimate of 400-450M tCO₂e a year for sport’s core industries, which it says are “comparable to the national emissions of major industrialized economies.” The source and method for the aggregate emissions are not clearly set out to my eyes, though this is in the ballpark of a previous estimate. Even so, further data and research in this area would be good to see.

Growth forecast - and a major risk warning

The report forecasts the sports economy growing from $2.3tn today to $3.7tn in 2030 and $8.8tn by 2050, led by rapidly expanding sports tourism, which is expected to grow from $672bn to $1.5tn in 2030 (sports tourism in particular is receiving growing attention, as can be seen by an EU Parliament briefing published on the same day). Other growth drivers usefully highlighted in the report are: the emergence of sport as an asset class; the mainstreaming of women’s sport; and a rebalancing of sports growth towards emerging economies.

However, the report argues, the sector is at an inflection point: rising physical inactivity, climate change and nature loss “could erode up to $1.6tn in annual revenue” by mid-century and undermine the sector’s broader impact. This is one of the standout figures - and it hits home. It places sustainability not as a “nice-to-have”, but as a material business risk. And putting that figure another way, I’d say this works out to around 18% of the projected 2050 sports economy that could be at risk.

Given the focus placed on the $1.6tn figure, it would be helpful to see further detail in the future than is provided on it at this time. For instance: How much of the revenue at risk is about physical inactivity, versus climate and nature-related factors? Is the $1.6tn “at risk” already reflected in $8.8tn growth projection, or is extra on top of that? Is the estimate an expected outcome, a worst-case projection, or something else? What climate models / pathways are being used? And is both climate mitigation and adaptation accounted for, and if so, what does that show?

A short technical annex or methodology note would make these headline numbers more useful for leaders and other readers alike.

Even so, the bigger point stands. This is an important contribution to a nascent and essential area of understanding: the financial impacts of insufficient action on physical inactivity and environmental degradation. It helps move sustainability beyond the “nice-to-have” category for some and into core business thinking - something that has not always been reflected in sport governance debates (including, for instance, in debates on the scope of the Independent Football Regulator in the UK).

A vision and three pathways - but bigger questions remain

The report aims to set out:

“a new vision for sport that aligns financial performance with planetary boundaries and societal well-being”.

It identifies three pathways: championing resource stewardship, placing sport at the heart of cities, and catalysing purpose-driven capital flows. The report includes innovative examples that make the pathways feel real. The pathways themselves are also novel and an interesting way to look at the issues that deserves further attention.

Importantly, the report does not suggest these steps alone will deliver the vision. Instead, it puts collaboration at its heart, arguing the challenge demands “urgent, systemic, multistakeholder collaboration”, alongside bold leadership and strengthened governance. As a next step, WEF says it intends to convene decision-makers across the sports economy to facilitate partnerships and support joint initiatives with measurable shared impact.

The focus on collaboration, leadership, and governance is welcome - and are themes covered here in this newsletter previously. That said, it would also be valuable to see greater recognition of the role that policy, regulation, and the full range of institutional tools can play in addressing environmental challenges, particularly given their scale and urgency.

Perhaps more fundamentally, the report invites bigger questions about the vision being put forward for the sports economy. For instance: is it clear? Is it fair? Is it achievable? And perhaps the biggest question - is it the right one?

A deeper tension? growth and climate compatibility

Within those questions, there’s an awkward question sitting at the heart of things. Much of the projected expansion - particularly through sports tourism - is built on patterns of mobility and consumption that are still structurally high-carbon. In a world of shrinking carbon budgets and increasing climate risks, the question is not only how sport reduces emissions at the margin, but whether this sports economy growth model is compatible with the international Paris Climate Agreement at all.

This matters because the biggest chunks of sport’s footprint aren’t easy wins. Aviation travel for sport, embodied carbon in construction of stadiums, and global supply chains for merchandise are all areas where incremental carbon efficiencies may well be outpaced by emissions from growth in demand. Without facing that head-on, there is a risk that sustainability becomes a parallel track - while the core growth model keeps driving emissions up.

This is an issue that has been touched on in a 2025 report prepared for the French Football Federation and other French sports bodies. The report sets out decarbonisation scenarios for football and rugby consistent with France’s national climate‑neutrality trajectory. However, it notes that none of these “reconcile climate goals with an increase in spectator numbers and/or international matches; at best, these numbers will need to stabilise”.

If sport is serious about aligning with planetary limits, it seems it will have to consider not just cleaner operations, but the need for, and extent of, hard structural choices. This includes things like rethinking calendars and competition formats to reduce long-haul travel; balancing local participation over ever-more distant spectatorship; designing hosting decision-making processes that elevate environmental criteria in decisions and delivery; and using policy and regulation - not only voluntary collaboration - to change incentives.

These are bigger issues than this post can address. More scrutiny of the vision is hopefully something that will come out in the collaborative efforts WEF intends to take forward.

What next?

For those not directly involved in the further planned discussions, this could nonetheless represent — to use the WEF’s own language — an inflection point. It feels like there is a need to consider both:

1. How to engage with, and influence, the next stage of WEF’s work, and

2. What other deeper collaborative approaches are needed aside from WEF’s work - including potentially different visions, pathways, and plans for the future of sport.

Final points

A few final points that jumped out for me:

• The scale of the challenge. WEF’s 2026 Global Risks analysis identifies both multilateralism under strain and also environmental concerns being deprioritised in the short term. The data in the report also reinforces how pessimistic many leaders are about the environmental outlook over the next decade. These add to the challenge set out in this report.
  

• “Planetary boundaries” needs sharper definition. The report uses the language of planetary boundaries but it does not translate this into quantified carbon and nature budgets or a practical programme. Alongside this, while it gives nods towards frameworks such as the UN Sports for Nature Framework further work must make clear what alignment would require in practice.
  

• Do we need a sport sector roadmap? Relatedly, I’ve previously argued that football lacks a sector roadmap and, where it has them, has targets based more on ambition than analysis. The WEF report sketches useful pathways but a roadmap would go further, setting out a high-levels emissions reduction path, time-bound milestones, resources, tools, dependencies and more. WEF’s next phase could be well placed to convene stakeholders around developing that kind of roadmap.
  

• Spectator travel: strong on land transport, weaker on aviation. The report provides useful, quantified analysis of fan travel emissions and how these could be cut through shifts to public transport and active mobility. It also flags aviation as a major contributor to sport-related travel emissions. The gap is that it does not offer comparably detailed and concrete quantification and scenarios for aviation to the ones it offers on land transport.
  

• An emerging elephant in the room? Sports tourism growth. Relatedly, the report says it expects major expansion in sports tourism - and notes it could account for the lion’s share of total sports economy revenue growth to 2030. Yet this is also the segment where aviation dependence, climate exposure, and emissions intensity are hardest to ignore. This could become one of the defining challenges for sport and sustainability in the next decade, and should be a key area for further work.
  

• Who is in the room? The report says it draws on consultations with 125+ organisations, which adds a sense of breadth of the perspectives behind it. It is not clear from the published report whether fan representative bodies were among them, or if/how fan perspectives will be taken into account in the next phase. Fans can be key to co-design of strategy, not just delivery.

Summary

In conclusion, this is an important and must-read contribution, with a lot riding on what happens next. With further work planned - and some difficult questions still unresolved - it’s clearly a milestone rather than an endpoint.

I’d be particularly keen to hear people’s views. Whether you agree with what I’ve said above, vehemently disagree, or have other points to make, or perhaps a post of your own on the report, do get in touch. Feel free to comment below, or drop me a line if you’d like to discuss directly. And as ever, clarifications and corrections are more than welcome too.

Further reading:

Breaking down the $2.3trillion global sports economy - 10 of the most arresting numbers in the document by Matt Slater for The Athletic.

Sport and the Planet: Why the $8.8 Trillion Sports Economy Depends on Nature in Global Sustainable Sport.

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Fran James (he/him)
Football and Climate Change Newsletter
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UEFA’s fifth annual Respect Report, reviewing progress on its football sustainability strategy, has just been published. It includes updates on a range of issues including anti-racism, child and youth protection, and equality and inclusion. This post focuses on one aspect of the environmental sustainability section of the report: how emissions are defined and reported, including what is counted and what is left out.

The report’s introduction opens with a strong statement: “The need to stand firm on sustainability has never been greater, as social and environmental challenges continue to affect and impact on our societies and the sport we love.” Alongside this are updates on a number of welcome positive actions taken during the year, and their contribution towards the overall strategy.

Set against this, a number of important questions arise from the report. These are not side issues, but are core to understanding what progress on reducing emissions in European football is actually being made, and what more needs to be done. In this post I’ll focus on one of those questions, and hope to turn to others in the future. The question here is what does UEFA’s Respect Report include in its emissions reporting, and what does it leave out?

The report identifies four environmental themes: circular economy; climate and advocacy; event sustainability; and infrastructure sustainability. However, when examined more closely, the scope of the report is less clear than it should be in relation to UEFA’s emissions reporting.

In layperson’s terms, UEFA chooses to count some things and not others that it could reasonably be expected to include. In more technical terms, its chosen organisational and event boundaries appear to understate system-level climate impacts arising from competition design and mandated match conditions. Practically, this includes things like decisions on the number of matches in club tournaments, minimum away-ticket allocations, the determination of kick-off times and dates, and more.

To understand this more clearly, it is necessary to look at how UEFA defines the boundaries of its environmental reporting.

In line with established greenhouse gas accounting practice, UEFA reports emissions associated with its own organisational operations and with those events it directly delivers, such as major international tournaments and the trophy-lifting final game of each of its club competitions.

Regular matches in UEFA club tournaments, which are staged by clubs at their own venues, fall outside this event boundary. For instance, all of the league-stage matches and all knockout stages of Champions League matches are not included in its emissions reporting other than the final itself, which UEFA treats as a centrally delivered event for reporting purposes. This is the same for its other club tournaments too.

This boundary choice is defensible in narrow accounting terms, but it is increasingly difficult to reconcile with UEFA’s actual influence over the drivers of emissions in European club football. UEFA determines the competition formats that dictate the number of matches played, mandates minimum allocations of tickets to away supporters, centralises media rights and broadcast production standards, and decides the match calendars and kick-off times. These decisions have predictable and material consequences for travel, energy use and associated emissions, regardless of who formally “hosts” an individual match.

This is not to suggest that minimum away-ticket allocations should be reduced, but to illustrate how UEFA’s regulatory decisions shape patterns of travel and associated emissions that are currently outside the report’s stated boundaries. Rather than clubs alone bearing responsibility for reporting these emissions and considering how to reduce them, this points to a role for UEFA as well — for instance, in designing, encouraging or incentivising lower-carbon travel options for supporters attending its club competition matches.

While UEFA may not exercise operational control over every matchday decision at club level, it designs and mandates the framework within which those decisions are made. A sustainability assessment that excludes the emissions consequences of that framework provides an incomplete picture of progress on reducing football’s climate footprint.

As a result, the emissions reporting in this annual Respect Report risks understating the climate impacts over which UEFA has important system-level influence.

Relatedly, the Respect Report also notes that 176 football organisations are now using the UEFA carbon footprint calculator. This is a positive development, and it demonstrates that UEFA recognises both the importance and the feasibility of standardised emissions measurement across its football ecosystem.

However, this raises further questions about the scope of UEFA’s own reporting. If clubs and national associations are already being supported to measure their carbon footprints using UEFA tools, any argument that emissions from all of UEFA’s club competition matches cannot be meaningfully assessed becomes less persuasive.

While such data may not support highly detailed, independently verified accounting for individual matches, it should be sufficient to inform aggregated analysis and transparent disclosure of the emissions impacts arising from UEFA’s club competition formats.

This would have the benefit of helping inform more targeted interventions. It would also be an important contribution towards UEFA’s target stated in the Respect Report of “Greenhouse gas emissions cut by 50% by 2030 (compared to baseline year 2024/25) in view of achieving net zero carbon emissions by 2040 within UEFA, across UEFA events, and collaboratively across European football”.

The Respect Report also says that “We are currently upgrading our strategy, ensuring targets remain ambitious but realistic as well as relevant and evidence-based considering real data and stakeholder feedback”. As part of this upgrading of its strategy, it is essential for UEFA to modernise its reporting boundaries.

In another section, it notes that “Due to this significant methodological change … UEFA has decided to reset its carbon footprint baseline to the 2024/25 season”. It appears that a further reset of reporting boundaries, not just baselines, will be needed.

This is not about attributing full responsibility for emissions from individual club matches. It is about acknowledging and incorporating the system-level climate impacts of competition structures into emissions analysis and decision-making.

One final point concerns reporting practices. Juventus is an example of an organisation in football that has recently issued a report it says is compliant with the EU’s Corporate Sustainability Reporting Directive (CSRD).

If UEFA were also reporting under an EU CSRD-aligned framework, its boundary choices would be much harder to leave implicit. CSRD aligned-reporting requires organisations to assess and disclose material environmental impacts across their value chains, including those arising from strategic design decisions, even where operational control sits elsewhere.

While this would not require UEFA to quantify emissions for every club match, it would require clearer justification of exclusions and greater transparency about the climate impacts arising from competition formats and mandated match conditions.

CSRD reporting is not mandatory for UEFA. However, PwC report that around 40% of companies plan to continue sustainability reporting on a CSRD-aligned (or equivalent, such as ISSB or GRI) basis even without a legal requirement, driven by stakeholder expectations and the decision-making value of the information. This suggests UEFA must seriously consider doing the same.

The value in UEFA clarifying and modernising its emissions reporting lies not in more accounting for its own sake, but in improving the quality of key decisions such as on competition formats, scheduling and travel-related policies.

In summary, without a shift in its approach, there is a risk that future sustainability reporting will continue to measure improvement against a boundary that no longer reflects UEFA’s real influence over the climate impacts of European football.

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As a newly established organisation, it is now asking for views on various aspects of how it should work, including a proposed licensing regime. This regime will require all clubs within scope to meet mandatory standards to obtain, and continue to hold, a licence to compete.

The consultation document explains the proposed regime and sets out 27 questions where the IFR is seeking views. The response I submitted focused on one of those questions - in relation to corporate governance - and is set out below.

As ever, all comments, corrections and clarifications on any aspects of this post are super welcome. Feel free to dive in - just not two-footed or studs-up!

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Q 19. Do you have any other comments on the IFR’s proposals for corporate governance?

This response relates to governance and risk oversight within the licensing regime, and is not intended to advocate for environmental regulation by the Independent Football Regulator (IFR). The IFR’s remit is not to set environmental standards. Rather, the objective here is to ensure that material financial and operational risks arising from climate-related disruption are properly recognised within clubs’ governance and risk-management frameworks.

During passage of the Football Governance Bill, the Minister explained that statutory intervention should be reserved for issues that football has been unable to resolve through self-regulation. Recent developments illustrate the limitations of voluntary approaches in this area. In 2024, the Premier League pledged to introduce a minimum environmental standard and to ensure that every club had a “robust environmental sustainability policy” by the end of the 2024/25 season. During the passage of the Bill in the House of Lords, the responsible Minister said this was a “good example” of effective self-regulation. However, despite now being in the 2025/26 season, there is no published evidence or reporting showing that this has been delivered consistently by Premier League clubs. Elsewhere in the football pyramid, only 32 of 72 clubs participate in the voluntary EFL Green Clubs/Green Code scheme.

These examples underline a wider challenge: voluntary standards can be unevenly implemented, particularly where they require sustained governance attention and long-term financial planning. This variability demonstrates the value of the IFR’s corporate-governance role, ensuring a consistent baseline of risk oversight across all clubs.

Government-commissioned research on the financial implications of climate change for grassroots sport was published by DCMS after the Football Governance Bill received Royal Assent. It provides new evidence that the IFR must now take into account when interpreting its governance responsibilities. The research confirms that climate-related disruption creates clear operational and financial risks through facility damage, match cancellations, increased maintenance and rising insurance costs.

Although the research focuses on community facilities, these financial pathways clearly scale with the size and complexity of elite football operations and therefore represent foreseeable impacts and shocks to club finances.

The IFR should ensure that clubs’ governance and planning frameworks are capable of identifying and managing any material risk to financial or operational sustainability, including climate-related risks where relevant. These foreseeable risks underline the need for a single Club Code that sets a common governance baseline across all licensed clubs, ensuring that material risks are identified and managed consistently throughout the football pyramid.

Although the IFR is not an environmental regulator, the financial and operational consequences of climate and environmental risks are now sufficiently clear that they warrant explicit recognition within the licensing regime. The IFR should therefore make clear in its Corporate Governance Code and licensing guidance that clubs are expected to maintain appropriate environmental or sustainability policies as part of risk management. These policies should be proportionate and relevant to each club’s circumstances, and linked to financial resilience.

Embedding this expectation within governance standards - supported by proportionate IFR guidance - would help ensure that clubs address significant long-term risks systematically, rather than relying on voluntary measures that are not delivered uniformly. To support consistent practice, the IFR should issue proportionate guidance to help clubs identify material operational and financial risks, including where climate-related disruption has business implications, while making clear that such guidance does not prescribe environmental policy or performance standards.

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More of the same while expecting different results would be, as the saying goes, madness. This slow progress also means mounting risks. A change in approach and pace is needed.

UEFA previously committed to review its 2021 sustainability strategy during 2025. Four years after its publication, the world has changed, making such a review both timely and urgent. It is a chance for UEFA to adopt a more ambitious, outcome-focused delivery-driven approach. This will also sit well with fans, sponsors and investors who expect an approach reviewed and updated to current circumstances and expectations.

At the time of writing, there is no sign that UEFA has begun this review. In the meantime, below are 3 themes with 10 actions and approaches that could be in a revised strategy. Most focus on those clubs at the top of the tree, though a few apply more widely. None are rocket science to deliver; further progress is mainly a question of leadership, intent, and recognising the benefits. They are:

Theme 1 - Raising the Floor: standards, compliance and accountability

1. A differentiated, proportionate approach for clubs of different sizes

2. More clubs setting net-zero targets

3. Greater transparency and comparability of progress

4. Enforcing and modernising regulatory requirements

Theme 2 - System transformation: strategy, calendar and commercial reform

5. A new climate ‘sector roadmap’ for football

6. A(nother) review of business relationships, including procurement and sponsorship

7. Incorporating environmental factors into UEFA’s scheduling of club matches

Theme 3 - Collective action and influence across the football community

8. A more collaborative approach between supporters, clubs, governing bodies and partners

9. A structured approach to clubs’ and bodies’ spheres of influence

10. Increased support for grassroots football, especially from those with the broadest shoulders

What follows is a long read covering each of these points. A heads-up - it’s perhaps the longest read yet in this newsletter. So, if it’s your kind of thing, strap in and let’s go. And if you have comments, clarifications, corrections, or further suggestions, please get in touch.

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Theme 1 - Raising the floor: standards, compliance and accountability

1. A differentiated, proportionate approach for clubs of different sizes

A differentiated, proportionate approach to clubs of varying sizes would align with broader sustainability practices in business. At present, UEFA and other organising bodies apply a “one-size-fits-all” model.

For UEFA licensing, all clubs competing in its tournament, whatever their size, must meet the same licensing requirements, such as appointing a sustainability manager and producing a sustainability strategy. Likewise, UEFA’s sustainable infrastructure and circular economy guidelines offer no clear differentiation for clubs of different scales.

A proportionate model also reduces compliance burden for smaller clubs while giving larger clubs a clarity that partners and investors increasingly expect on sustainability.

In simple terms, larger clubs should do more. They have greater impact, face higher risks from inaction, and possess greater capacity to deliver change at scale. This does not mean smaller clubs have no responsibilities; rather, a proportionate model would help tailor expectations and support across all levels.

This prompts two questions: how should clubs be segmented, and what actions should each segment be expected to take? Further analysis is needed. Still, some existing classifications could provide a starting point for segmenting clubs. For example, European Football Clubs (EFC) identified roughly 150 major European clubs that were expected to fall into CSRD reporting requirements1. At the highest level, UEFA publishes annual financial data for the top 20 clubs by revenue2.

2. More clubs setting net-zero targets

All major clubs should be setting net-zero targets — that should be a no-brainer. And for clubs that already have targets, the priority must be pushing ahead with implementation.

However, a purely voluntary approach, leaving clubs to act independently, has kept football in the slow lane. What could an alternative look like? At least three options stand out.

First, an enhanced voluntary approach: regularly publishing how many major clubs have set targets and what those targets are. UEFA or the ECA should lead this, though an independent expert body might offer greater authority and credibility and also assess their integrity.

Second, an orchestrated campaign. The UN Sports for Climate Action Framework is one such effort, yet only 8 of the 29 biggest clubs have joined. Something isn’t resonating with the very top-tier clubs. A football-specific net-zero campaign may also be needed — potentially led by UEFA, or by clubs already committed to net-zero, or integrated into the EFC’s Football Clubs Alliance for Climate initiative.

Third, a regulatory approach. UEFA could incorporate climate-target requirements into its club licensing system. This could follow the pattern of other UEFA environmental criteria: introduced first as non-binding and later becoming a condition for participation. It could also be designed proportionately. Germany’s DFL already includes climate-target setting in its licensing rules, so the concept is not new to football.

3. Greater transparency and comparability on progress

Transparency and accountability are essential for assessing progress and driving better climate action. Yet, little meaningful reporting is happening. Where major clubs do report, understanding is often hindered by glossy, bulky, inconsistent, and no doubt costly, documents filled with cherry-picked data and headlines.

Although clubs may well have good intentions with these, their current individualised reporting practices obscure the bigger picture. Which actions by major clubs most effectively cut emissions? It’s almost impossible to tell. A few giant trees are blocking the view of the wood. Four developments here could help.

Voluntary CSRD-aligned reporting

The EU’s Corporate Sustainability Reporting Directive (CSRD) aims to ensure transparent, comparable sustainability reporting. As noted above, EFC previously identified 150 major European clubs that would have fallen under the CSRD and provided them with training.

Recent threshold changes mean these clubs are no longer required to comply—yet nothing prevents them from adopting CSRD voluntarily.

Across the business world, PwC reports that 40% of companies plan to continue with CSRD-aligned reporting even without a legal requirement, driven by stakeholder expectations and the decision-making value of the information. How many football clubs plan to follow suit?

So far, Juventus is a rare example of a major club voluntarily adopting CSRD reporting. Others are conspicuously absent. As the terrace chant goes: “This is embarrassing.” There is clearly scope for major clubs to step up and align with a recognised standard.

Given its experience with training of clubs, EFC is well positioned to publish an annual list of member clubs voluntarily aligned with CSRD. To measure its own impact, EFC could also set short-, medium- and long-term targets for increasing uptake.

The UEFA Carbon Calculator: White Elephant or Opportunity?

Launched with fanfare last March, the calculator was promoted as a tool to “improve consistency, provide clarity of reported information and support comparability over time.” Nearly two years on, what’s the uptake? And what does the data show?

We cannot say - there is no public information. Is it a dud? The intent is sound, but implementation by clubs appears weak to this outsider. There is an opportunity for UEFA to review the tool, improve and tailor it where needed, and strongly encourage and support wider use. A further step could be making it mandatory for the biggest clubs.

An annual net-zero report

UEFA already publishes its annual European Club Finance and Investment Landscape Report, which focuses on data from the top 20 revenue-generating clubs. A similar approach could be applied to sustainability.

This could be integrated into the existing report or published as a standalone document. Alternatively, an independent annual assessment by a specialist organisation—potentially funded by UEFA or the EU—would add credibility.

Standardising an Intensity Metric

One additional point: the need to standardise emissions-intensity metrics. Two issues stand out. Firstly, clubs often use different units of measurement, making comparisons difficult. Many appear to cherry-pick metrics that best suit their narrative. Secondly, revenue-based intensity metrics seem poorly suited to football. Large year-on-year revenue jumps - common among major clubs - can suggest improved emissions intensity when they simply reflect higher TV income or commercial deals. A standardised approach would improve comparability and reduce the risk of misinterpretation.

4. Enforcing and modernising regulatory requirements

Clearer rules can help reduce long-term compliance costs for clubs by providing predictability and avoiding abrupt regulatory shifts. Given the slow progress in reducing emissions and taking action, UEFA must review its regulatory approach, including looking to:

1. Enforce existing sustainability requirements. Clubs are required to establish and implement a sustainability strategy, yet many appear not to have not done so, despite it now being a licensing condition.

2. Strengthen environmental sustainability criteria. This should include:

   • Ensuring regulations are proportionate to club size.

   • Reviewing and updating voluntary guidelines and tools, and considering if any need to be formalised to drive progress.

   • Learning from national football licensing schemes, including those with sustainability criteria, and adopting best practices.

   • Clarifying existing rules. While clubs must have a sustainability strategy, the required content is currently somewhat unclear.

   • Considering further targeted regulations where evidence of a lack of progress in an important area is compelling - for instance, mandating climate targets for the largest clubs.

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Theme 2 - System transformation: strategy, calendar and commercial reform

5. A new climate ‘sector roadmap’ for football

This might sound technocratic, but it represents a major open goal for football. At present, the sport is dotted with disconnected sustainability strategies.

Where clubs have strategies at all, they vary widely. The same is true for national and international governing bodies, whose plans often fail to link to those of clubs or to each other. Even within countries, different bodies take divergent approaches that barely acknowledge one another—for example, the FA and the Premier League, or the RFEF and LaLiga. In short, the landscape is a strategic dog’s dinner.

A sector roadmap is a multi-year strategic pathway to decarbonisation, built on rigorous analysis. It sets out how an entire sector must evolve to meet net-zero goals: the milestones and targets needed, the changes required, the resources involved, and the dependencies on progress elsewhere.

Football has unique characteristics and challenges that do not fit neatly into other sectoral plans. The sport spans complex areas—energy, travel, infrastructure, apparel, and more—that need to be viewed together.

A football-specific roadmap could address these issues holistically, provide a shared context for club-level ambitions and actions, reduce reputational risks to clubs, embed climate justice principles, and articulate expectations for clubs of different sizes.

The UN Sports for Climate Action Framework offers useful elements but is not designed to deliver a comprehensive, football-specific plan. It is rooted in (welcome) ambition and largely generic business principles rather than the detailed analysis required for a true football roadmap.

A roadmap could be created at the global level, but FIFA currently shows minimal leadership on sustainability. Given that most major clubs are in Europe, a European-level roadmap is a logical starting point—while acknowledging it would not cover the entire ecosystem.

This should be led by UEFA or commissioned independently by the EU in collaboration with UEFA. Clubs, supporters, broadcasters, commercial partners, players and other stakeholders should all be part of developing it, with innovation playing a key role in identifying new solutions and accelerating practical delivery.

6. A(nother) review of business relationships

UEFA’s sustainability strategy set a 2024 target to align its business-relationship codes of conduct with its environmental commitments. The 2022–23 Respect Report lists this target as “in progress,” while the 2023–24 report marks it as “achieved,” suggesting the review has recently been completed. However, no public information appears to explain what, if anything, has changed. Many issues fall under a review of business relationships, but two stand out.

Procurement

Based on limited available data, procurement-related emissions appear to outweigh fan-travel emissions for some of the biggest clubs3. For example, Spurs report Scope 3 Categories 1 and 2 as nearly 45% of total emissions (fan travel accounts for 42%). Liverpool reports supply chain and capital expenditure at a combined 37% of total emissions with merchandise at a further 25% and fan travel at 20%. Manchester City reports retail and merchandise at 46% of total emissions with fan travel at 12.5%.

Procurement policies sit with clubs, not governing bodies, but there appears to be a gap in shared knowledge on sustainability best practice. UEFA could help by developing sustainable procurement guidelines for clubs.

UEFA’s own procurement also shows limited attention to sustainability. Its Supplier Code has not been updated since 2019 - before it adopted its net-zero target and sustainability strategy - indicating an overdue need for revision.

Sponsorship and advertising

In 2024, the UN Secretary-General called for restrictions or bans on fossil-fuel advertising. At the COP30 international climate talks this year, a UN-backed blueprint for phasing out such advertising was launched. A recent House of Commons Research Briefing also notes that several countries and cities have introduced or are planning bans. These developments follow on from impactful ongoing sport-focussed campaigns by Fossil Free Football, Cool Down and others.

A ban in football is a matter of when, not if. UEFA sets its own sponsorship and advertising regulations. The biggest clubs, which rely most heavily on commercial revenue, will be most affected by changes. This makes it vital for UEFA to begin planning now on a structured phase-out.

7. Including Environmental Factors in UEFA’s Scheduling of Club Matches

A recent report by Scientists for Global Responsibility confirms what is increasingly evident: an expanding international match calendar leads to higher emissions. More matches and greater travel distances put additional pressure on clubs’ ability to reduce their environmental impact.

This aligns with a report released earlier this year by the French think tank The Shift Project, supported by the French Football Federation, the Ligue de Football Professionnel and others. It concluded:

“Despite our attempts, none of our scenarios reconcile climate goals with an increase in spectator numbers and/or international matches; at best, these numbers will need to stabilise.

The safest path requires rethinking the scheduling of international events around two principles: proximity (a more local audience and reduced travel between teams) and moderation (adjusting the number of matches and/or international spectators).”

UEFA has already acknowledged the link between fixture volume and emissions, saying: “The carbon footprint of UEFA events depends on the number of events organised each season.” However, it has yet to take concrete steps to look at the European club football calendar with environmental factors in mind. Alongside this is a strong argument for reforming the football calendar to protect player welfare.

The current UEFA club competition cycle runs from 2024–2027, meaning planning for formats beyond 2027 is likely already underway or will begin by 2026. Environmental sustainability must be a core criterion in designing the next cycle of club tournaments. It should also guide other UEFA calendar-related decisions, such as proposals for domestic games played overseas, UEFA’s stance on FIFA’s expanding club competitions, and the growing schedule of pre- and post-season friendlies.

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Theme 3 - Collective action and influence across the football community

8. A more collaborative approach between supporters, clubs, governing bodies and partners

Effective climate action is well known to require extensive collaboration among all stakeholders. Yet, most club and governing-body sustainability plans, where they exist, are still developed with minimal supporter involvement (notable exceptions aside).

For example, Premier League clubs’ Fan Engagement Plans contain almost no references to sustainability, while their sustainability strategies rarely mention involving supporters in their development (with a few exceptions).

The same applies to governance structures. UEFA’s Environmental Steering Group includes partner and player representation but no supporter representation, and its Social and Environmental Sustainability Committee has just one supporter representative among 26 members - despite covering a wide range of issues. Similarly, the new UEFA–EFC sustainability co-operation plan appears to overlook collaboration with supporters and others stakeholders entirely (and largely adopts a ‘more of the same’ approach).

Where engagement with supporters does occur, it is usually limited to informative or consultative methods - surveys, focus groups, and one-way communication - rather than deeper collaboration. As a result, opportunities for more hands-on partnership are being missed, along with a substantial reservoir of supporter interest, expertise, and willingness to act.

A wide range of participatory and deliberative approaches could be used instead or in addition - from co-designing initiatives to fan assemblies modelled on citizens’ assemblies.

At the same time, the capacity of supporter groups to engage on environmental issues is still somewhat nascent. This is not due to a lack of interest. Surveys consistently show strong supporter demand for greater climate action in football. But more work is needed to understand how to build capability and support meaningful involvement.

As a first step, UEFA should work with all key stakeholders, including supporters, to develop a climate-engagement strategy and/or guidelines for clubs. This links to the next approach, which is …

9. A structured approach to clubs’ and bodies’ spheres of influence

One of the most repeated phrases in sport and sustainability is that “sport, with its massive global reach, has a unique ability to inspire climate action.” It’s a bit of cliché that raises important questions: What change does sport actually aim to achieve? Who is football trying to influence? Who is best delivering the message? And what’s the most effective way to do it?

A new, more targeted way of thinking is emerging, encouraging organisations to consider their full ‘spheres of influence’. This framework looks beyond supply chains to the wider role organisations can play in advancing decarbonisation more broadly. While not yet adopted in football, Munster Rugby Club offers an early adopter example from elsewhere in sport.

This approach is especially relevant for football, given its unmatched global audience. It also broadens the focus beyond fan engagement to other influential levers - such as product and service design, financial and investment decisions, and public or policy engagement.

Take policy, for example. Transport emissions are a major issue for football. How might clubs, governing bodies, supporters and other partners influence transport policy at their national and/or local levels to reduce club-related emissions and improve public transport - a win-win for both clubs and fans?

A related side note here on communications: Several articles and studies call for a shift in climate communications to emphasise everyday benefits for people, and also the commercial advantages for businesses. How can these approaches be best taken on board in future influencing strategies too?

10. Support for grassroots football, particularly from those with the broadest shoulders

The financial impact of climate change on grasroots sport is becoming clearer. A UK Government commissioned estimate puts annual adaptation costs at around £320 million. It also notes that this figure does not capture all impacts and that additional costs are “likely to be large.” This figure also excludes the investment required for climate mitigation.

At the same time, the heavily oversubscribed EURO 2024 Climate Fund shows the significant demand for climate support within grassroots football - far beyond what the fund was able to provide or grassroots football can afford.

Investment in the grassroots will deliver long-term return on investment, whereas a delay will increase the investment needed over time to achieve similar results. Just as national governments and the EU fund a range of climate projects, there is a strong case for both national football bodies and UEFA to offer dedicated funding for grassroots climate initiatives to safeguard the game’s long-term future.

UEFA can play two key roles: first, by developing guidelines for national associations on providing climate funding for grassroots football; and second by creating an annual European climate fund that complements national climate funds, and also extends beyond its current approach which focuses on the men’s and women’s national team tournaments held every four years.

Further consideration is needed on how much funding is required, which projects should be supported at European versus national levels, and how to balance investment between mitigation and adaptation. Another crucial question is what constitutes a fair contribution from governing bodies, clubs, and especially the largest clubs?

These are issues football’s leaders must address. A core principle should be that clubs and bodies with the broadest shoulders - and the largest carbon footprints - should contribute the most. Notably, the biggest clubs are not short of a bob or two: the top 20 generated €11.2 billion in revenue in 2023/24, a 6% increase on the previous year. Revenues, particularly for the largest clubs, are set to rise further with, for instance, the next cycle of UEFA club competition broadcasting rights and participation in the FIFA Club World Cup. Alongside this profitability is rising amidst growing financial stability.

And finally - A need for a more radical thinking too

That’s your 10 for starters. But is it all that’s needed? Clearly not, more collaboration will spur more innovation in thinking, learning and action. Alongside this it is also important to explore more radical scenarios of how football is organised in the future and what these could mean for environmental sustainability. While a detailed analysis is beyond the scope of this note, some examples illustrate the potential for change:

• FootBiz highlights the tension in governing bodies acting as both regulators and tournament organisers. Legal pressures suggest this dual role may not be sustainable.

• Academic experts from LSE, Oxford, and Prague universities have proposed a European Sports Act to formalise rules on governance and social responsibility.

• FIFA is expanding its role in club football.

• Independent football regulators on financial issues have recently been set up in England and Brazil, which may lead to other countries following suit.

• A shifting political and economic context. It’s fair to say this post has not had detailed attention here, it’s a biggie, and will inform future action.

These developments suggest football’s future could look very different, raising important questions about how climate action might evolve under different scenarios.

Addressing this requires further research, scenario-planning, and expertise that are beyond the scope of this note - but give us a shout if that’s your bag as I’d be happy to shoot the breeze.

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Fran James (he/him)
Football and Climate Change Newsletter
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As the world’s most popular sport, football has a unique opportunity to inspire climate action. The biggest football clubs in the world have a massive global reach. This makes their role and influence particularly important. The more that clubs do to take climate action themselves, the more credibility they have when encouraging others to take action too.

This post looks at the biggest 29 clubs in Europe by revenue to assess their action on net-zero. These 29 clubs are also the biggest 29 clubs in the world by revenue (the 30th, Flamengo, is Brazilian).

It finds that progress overall by European clubs is poor and more action is needed. A further post, coming soon, will look at what further actions could be considered.

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Findings

A look at the top 29 clubs in Europe by revenue shows that:

• Of the 5 biggest clubs in Europe only 2 (40%) have a net zero target. 60% do not, including the biggest club Real Madrid

• Of the 20 biggest clubs featured in the latest UEFA European Club Finance and Investment Landscape only 9 (45%) have a net zero target

• Of the 29 biggest clubs in Europe by revenue, only 13 (45%) have a net zero target

It is good to see some clubs setting net-zero targets, and all clubs have some positive environment-related stories to tell. At the same time the overall picture and outcomes matter, and which this post focuses on.

As a comparator, we can look at action by the wider business community in Europe. Within that wider community in general, from Net Zero Tracker data, we see that:

• 84% of the largest publicly-listed EU companies have a net zero target

• 75% of the largest private companies headquartered in Europe have net zero targets1

This means 45% of the biggest clubs in Europe have a net zero target compared to 75% of biggest private companies in the wider European business community. That’s some gap. Those companies in the wider business community will be bigger fish financially. Even so, the biggest clubs are not small fry, with revenues ranging from €1045.5m to €206.9m. They can reasonably be expected to be setting net zero targets too. So this analysis suggests that collectively the biggest football clubs are lagging behind in setting net zero targets.

It is also important not to leave an analysis there. Simply catching up with the wider European business community, or even all clubs setting a net-zero target, would not mean job done. As also noted by the Net Zero Tracker initiative:

“While net zero targets signal corporate support, they are not, on their own, a reliable proxy for climate ambition. A growing number of studies highlight that companies’ headline targets may be undermined by omissions, caveats and distortions, making them less ambitious in practice than on paper ... Therefore, a deeper dive into the target structure and planning for implementation is essential”.

This post does not propose to carry out a detailed analysis of the robustness of the net zero targets of football clubs. On this front, a full, independent, expert analysis would be really welcome to see. Get in touch if you have already done this, or have any plans to do so!

However, as a starting point we can take a further statement from Net Zero Tracker that: “Emission reduction plans should — at a minimum — be specific, measurable, time-bound and cover the largest emitting areas of a company’s value chain”.

With this starting point in mind, the spreadsheet of the top 29 clubs also provides a link to their main page on environmental sustainability. An initial look at what clubs say suggests it is as plain as the nose on your face that:

• there is considerable variability in the information being provided by clubs - in structure, coverage, level of detail, timeliness and more

• much of what is published would struggle to be called a ‘strategy’ or ‘plan’

• there is a huge lack of quantified data, and where there is it is not presented in a way that is comparable between clubs

• where targets exist, there is variation and ambiguity in the targets being set, and it’s not possible to tell if any clubs are on track to meet their targets

• while a number of initiatives are reported on by clubs, their impact is unclear. Outputs not outcomes are being prioritised and publicised

Discussion

We see that the biggest and most important football clubs are lagging well behind the wider European business community in the basics of even setting a net zero target. Among those that do, there are questions about the robustness and implementation of these targets. Many of these clubs do not appear to have what could reasonably be expected to be in a sustainability strategy - which is now a UEFA licensing requirement.

On implementation plans to reduce emissions, and reporting on them, progress is microscopic. We have no idea if any big club is on track to reduce its emissions in line with its targets. This fits with a European Commission assessment that there is limited data but the wide sports sector “should be assumed to be significantly off track in delivering Green Deal objectives”.

All this said, I’d welcome readers to provide any further analysis or interpretations of the available evidence that provides further and/or different findings.

This is also against a background of leading global businesses across all sectors continuing to push forward with sustainability actions despite choppy political waters (see for instance, recent business surveys by Deloitte and PWC).

In addition, a September 2025 survey showed that 68% of European business leaders want the EU and European companies to show global leadership on business sustainability standards, and 59% believe that becoming more environmentally sustainable is good for their company’s reputation and profitability.

While business leaders in other sectors continue to press on and take advantage of the benefits sustainability action brings, there is a risk of a growing gap opening up between the football world and wider business world on sustainability.

The COP30 climate talks are starting in Brazil this week. This will have a focus on moving from pledges and plans to implementation. While COP30 focuses on implementation, in 2025 a lot of football at the biggest levels still has a lot to do to get basic building blocks in place. This should be of considerable concern to all those who care deeply about the game.

Why is this happening? This newsletter has previously covered research by the European Commission on challenges to Green Sport, and the work of the UK Government on wider governance issues in football. These provide us with several sport-specific barriers that need to be overcome including: short-termism, governance challenges, methodological issues, and more.

At the same time, this analysis suggests the biggest clubs have an opportunity to move from being a laggard to a leader on net zero with the right actions. So what needs to happen next?

A further post coming shortly will set out some proposals on what this might include.

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Fran James (he/him)
Football and Climate Change Newsletter
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In the UK the independent Climate Change Committee (CCC) has just written to the Government saying it needs to prepare for a 2°C temperature rise by 2050. Preparing for a 4°C increase by the end of the century should also be considered as part of effective adaptation planning. It calls for the UK to take a materially different approach to the one taken so far on climate adaptation. It says we are already experiencing the impacts of climate change and there is a need to prepare for more heatwaves, drought, flooding, fire weather and storms.

These are not some far off concerns for football. We are already seeing the effects of extreme weather, from the grassroots to the global. For instance, the English FA has estimated 120,000 games being postponed each year. Elsewhere, Sport England shows 4 in 10 organisations being affected by weather-related interruptions. Globally, we have recently seen devastating impacts of floods on clubs and their communities, for instance in Brazil, Spain, Central Europe and Argentina.

Without more action, further temperature rises will mean more of the above. More of your child’s grassroots matches being called off. More of the matches you play or watch being postponed. Less watchable games when they do go ahead. Disruptions to your football-related plans and routines. Fan-bases and their local communities being more affected.

Inaction now will lead to escalating costs from physical climate risks, while early adaptation investments can deliver high value for money. Collaboration and innovation on these challenges can help deliver a better future experience for football’s fans and players. This leads to the questions - what is football doing now to adapt to temperature rises? And what needs to happen next?1

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A pitiful level of attention so far in football

Globally

FIFA promised in 2021 to “Review [its] concepts, requirements, agreements and regulations for FIFA tournaments and events to adapt them to climate change impacts”. Fast forward four years, and no review has taken place or is known to be planned.

In recent days the FIFA President has floated the idea that domestic football calendars are shifted to finish in June. The suggestion appears focussed on allowing FIFA to organise its own World Cup tournaments to be played out of summertime due to the heat at this time of year: “We are discussing it and we will see when we come to some conclusions. We just have to have an open mind.”

These are the first signals of behind-closed-doors discussions about the impacts of heat on football - but with no clear objectives, process, timescale, governance, transparency, or engagement with them.

Alongside this, FIFA as a tournament organiser could have potential conflicts of interest. Will it seek to prioritise adaptations to football that benefit the increasing tournaments itself organises, over what’s best for football globally?

For instance, on the idea of moving the annual football calendar to finish in June, this could help create a space elsewhere in the calendar for both club and country FIFA World Cups that are less affected by heat. The FIFA President cited October and March as “the months you can play everywhere”.

But is it helpful for the future of domestic club football to move games to June? Experts say heatwaves this year contributed to the warmest June on record in western Europe, and in June “Much of Europe experienced strong or very strong heat stress”.

A further point of note is that FIFA’s upcoming World Cup will be sponsored by one of the “oil giants directly linked to dozens of deadly heatwaves” that is leading to the need for football to adapt.

Europe

Europe is warming twice as fast as the global average. This makes it the fastest-warming continent on Earth. When it comes to the continental federations, UEFA, unlike others, does have a sustainability strategy. However, this strategy has nothing to say on any plans, objectives or initiatives in relation to climate adaptation.

This is reflected, for instance, in UEFA’s infrastructure guidelines. These appear to need a major rewrite to take climate adaptation into account. Alongside this, UEFA previously mentioned it was working on regulations to safeguard players and fans from extreme weather. This work has seemingly disappeared without a trace. As a further example of a yawning strategic gap, UEFA and European Football Clubs, have just announced they will ”unite to accelerate sustainability in European football”. This is an important missed opportunity to kick-start (let alone accelerate) European-level action on climate adaptation in football.

UEFA has previously committed to a review of its sustainability strategy’s effectiveness and architecture in 2025. This would be an ideal opportunity to integrate climate adaptation work into its overall approach. But with two months of the year left, and no indication of work underway, we should not hold our breath for it.

This all comes as the European Parliament passed a motion on the European Sport Model which calls “on the Commission and the Member States to encourage environmental responsibility and climate adaptation in sport”. This clearly identifies a need for a more active role by Governments, as well as sport itself, on climate adaptation.

National

At a national football governing body level, the picture of little or no strategic planning is much the same. Here in the UK, both the Premier League and the FA environmental strategies contain some vague words on climate adaptation. However, there are no clear objectives, plans, or actions in relation to it. The FA includes a statement on climate risks in its annual accounts. It sees extreme weather as an important risk only in the long-term and under a 4°C scenario. This seems at odds with the CCC view of planning now for 2°C. The FA statement also mentions a proposal for “a data-driven project on the impact of weather”. No further details are yet available on this.

At a club level in England we are seeing a handful of clubs beginning to disclose climate risks. These are part of mandatory climate-related reporting for the UK’s biggest businesses. This shows some welcome attention now being given to these risks. At the same time it also highlights hugely divergent approaches. This includes on methodology, timescales, the types of risks being considered, and the findings coming out of them. It demonstrates a gap for best practice guidance, and a need for much more consistency, clarity and action within football on climate risks more generally.

The above factors arguably highlight a key governance failure already identified by the UK Government in its consultation on football governance - a reckless short-term focus by owners and directors.

Despite this, the Government waved away cross-party calls for the Football Governance Act to recognise climate issues in legislation. Backed by voices in the industry, it argued that the football regulator should focus narrowly on financial issues for football. Looking at climate change would be ‘scope creep’.

Yet shortly after the football regulator was approved, the Government published an analysis showing the financial implications of climate change on grassroots sport. This identifies a £320 million annual financial impact on grassroots sport in the UK due to extreme weather. It also says that other further financial impacts beyond this could not be quantified but are “likely to be large”.

This means there is every reason to believe that large annual financial impacts on grassroots football will be mirrored elsewhere in the world. In addition, there will be countries and areas in the world that have done little or nothing to contribute to climate change and/or have little, if any, resources to respond to the adaptation challenges ahead for football. However, no assessments yet exist, for grassroots or elite football.

How, by who, and to what extent the financial impacts of climate change are to be addressed has not been looked into - let alone what a fair distribution should like both within and across countries.

In England, there is already an inability of football bodies to find an agreement on a fair distribution of funding in football more generally. This suggests it’s going to be a considerable but necessary challenge to address on climate adaptation too.

Summary sitrep

In summary, this analysis suggests there is:

• already climate impacts on football and these will grow;

• an existing absence of strategic planning in football on climate adaptation;

• a lack of evidence that football has any clear plans to get its house in order at both international and national levels;

• research identifying financial impacts of climate on sport;

• a need to allocate appropriate resources to address this challenge, and for this be done fairly;

• a recognised short-termism in football governance that acts as a barrier;

• a stated need for Governments to play an active role too; and

• a need for a materially different approach.

Next steps

Much of what needs to happen next is clear. It can, for instance, be adapted for football from the approach proposed by the CCC for the UK Government in its letter this week. At international, confederation and national levels, new frameworks are needed. These should outline clear, long-term adaptation objectives for football. These objectives need to be drawn from further research that is required urgently. This should also include reviewing - as FIFA previously proposed to do - the concepts, requirements, agreements, infrastructure, and regulations of football to future-proof them for future warming.

Longer-term objectives need to be driven through a set of interim milestones, with shorter-term targets. This should be underpinned by clear accountabilities, a plan to deliver them, and a regular review of objectives. These clear accountabilities need to set out the roles of different stakeholders in, and beyond, football. A focus on collaboration and innovation will be key. This must include local and national public bodies, as this is clearly not something football can deliver by itself.

The Leadership Elephant

So far, so logical. None of these suggestions is ground-breaking or rocket science, but will be challenging. The elephant in the room is where the leadership is going to come from to deliver this? Many leaders of football’s governing bodies have provided introductory remarks to strategies where they mention the impacts of climate change. But beyond these remarks, as we have seen, nothing of substance or scale is to be found.

A further example on leadership issues is the recent Leaders Summit in London. This brought together global leaders in the sports business, but did not include climate on its agenda. Look at the upcoming FT Business of Football Summit, and you’ll see a similar gap. This all seems quite staggering when you consider that global business leaders, surveyed by the WEF, say that “Environmental risks dominate the 10-year horizon, led by extreme weather events, biodiversity loss and ecosystem collapse.”

It suggests that business leaders outside of football are more tuned in to the issues than those within the football industry. This also again appears to align with the governance failures and short-termism in sport identified by the European Commission, UK Government and others.

Drawing on another section of the CCC letter and adapting it for a football context - Players and fans from the grassroots to the global are already experiencing the impacts of a changing climate, and want more action. The football community owes it to them to prepare for what we know is ahead. What needs to be done is challenging but clear and can help deliver a better future for football. Will football’s leaders step up?

Note: This post is written from a non-expert perspective from outside the professional climate and football worlds. Comments, corrections and clarifications would be welcome from experts and non-experts alike - and offers to write a guest post more than welcome too. Either drop a line direct, or post a comment below.

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FIFPRO is the global union for professional football players. It has just published its annual player workload monitoring report for men’s professional football. You can find it here.

This post takes a look at key climate-related points in the report1. It shows that ahead of World Cup 2026, there are important issues to be addressed. This includes on extreme weather and its impacts on players’ safety and health, the timing and location of games, and also the updating of heat guidelines.

It also shows that governing bodies, clubs and others need more consideration and collaboration on issues that affect both player workloads and the climate. This includes the overall football calendar, international travel, overseas tours by clubs, impacts of extreme weather on fans, and more.

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About the report

FIFPRO is the representative organisation for 65,000 professional footballers across the world. This annual workload report is one aspect of its wider work on behalf of players. That work includes an advisory role on UEFA’s Executive Committee, expert research and campaigning. This makes FIFPRO reports key contributions to discussions on football’s future direction.

Many of the points made on extreme weather in this report are similar to those already made by academics, campaigners and other organisations (see bottom of page). That said, its importance lies in the organisation making the points and its approach. The report looks at key data of 1,500 top footballers across the 2024-25 season. It also has had over 60 experts contributing to it. Several quotes from world-leading players and managers bring it to life. There are also several real-life stories and a lot of striking statistics.

For the first time this annual analysis from FIFPRO also includes a section on extreme heat. In addition, other sections have important points in relation to the climate. Taking these in turn …

Extreme Heat

Section 6 of the report looks at extreme heat and is split into two main parts. Firstly, an explainer on the issues and policies related to extreme heat. Secondly, an analysis of the extreme weather at the recent Club World Cup in the US. This is also used to inform a look at implications for the men’s World Cup 2026 in the US, Canada and Mexico.

The report says that extreme heat alongside physical demands mean players face unique challenges. It also means the management and mitigation of extreme weather conditions are key. This applies to both matchday operations and the overall management of competitions.

It also recognises that climate change will have growing impacts on the participation and spectatorship of football. This requires competition organisers and player unions to strengthen extreme weather protocols.

Guidelines

FIFPRO’s report considers the existing protocols of governing bodies. In doing so, it recognises that FIFA guidelines [on extreme heat] are the guiding principles for the professional football industry. However, these have not been updated in nearly 20 years. Also “these seem less protective than guidelines in other sports or from countries traditionally exposed to extreme hot conditions.” In the report, FIFPRO also presents its own proposed heat mitigation standards to better protect players. FIFPRO’s findings lead it to say that:

“the existing FIFA standards for the upcoming competitions such as the FIFA Club World Cup 2026 and 2030 (as well as other competitions at national or international level), are a current concern that requires attention as competition policies need to adapt to a warming planet.”

As things stand, there are no known plans for FIFA to update its guidelines. Elsewhere, UEFA said in February 2024 it was “working on having regulations in place to safeguard players and fans”. No further update has since been provided by UEFA. Elsewhere, Conmebol provided medical recommendations specifically for Copa America 2024. Despite this, several concerns were reported.

Overall, this suggests there are important questions for FIFA and other governing bodies to address on their guidelines. These particularly focus on what work is happening to review and update heat guidelines. This is particularly timely for FIFA with the men’s World Cup 2026 fast approaching.

Implications for the locations and timings of matches

To inform its approach, FIFPRO focuses on the 2025 Club World Cup held in the USA. It notes there were “numerous incidents of extreme climate conditions”. It says that “Both players and coaches have voiced concerns”. To highlight these, it includes quotes from several leading players and managers. Relatedly, The Athletic reports that FIFA received 145 reports relating to human rights concerns at this year’s Club World Cup. The second-most of these came from “fans who suffered from extreme heat”. Separately, FIFPRO’s Director of Policy has said that the extreme heat at the tournament is “probably a wake-up call in this regard”.

FIFPRO’s analysis identifies 4 matches that “should ideally have been cancelled or rescheduled to avoid jeopardising player safety” due to heat. It also identifies 17 matches with heat close to its cancellation/rescheduling threshold. In addition, 6 matches had delays of up to two hours due to thunderstorms and heavy rainfall.

Looking forward, the report says 6 of the 16 host cities for World Cup 2026 face conditions classified as ‘extreme risk’ for heat-related illness. This heightens “safety concerns not only for players, but also for fans”. It leads FIFPRO to say that for World Cup 2026:

“the existing schedule and venue selections may need to be reassessed to better safeguard player health, protect fan well-being, and support optimal performance”

FIFPRO also adds that “competition location and timing should be given greater consideration by competition organisers”. Drilling down from this point suggests two areas of focus. Firstly, more consideration should be given in the bidding processes for decisions on who will host tournaments. Secondly, more consideration on detailed location and timing issues is needed after hosting decisions.

Tournament expansion

The report goes on to say that the expanded World Cup 2026 48-team format amplifies the issues. With matches spread over a vast area and a compressed tournament format, extreme weather may have significant knock-on effects on the entire tournament schedule. For instance, a need to postpone a match early in the tournament may have knock-on effects on the timings of further games.

This FIFPRO report comes as proposals are being put forward for a 64-team World Cup in 2030. This would take place across 6 countries and 3 continents and is being actively considered by FIFA. This FIFPRO analysis raises critical questions about these proposals. For a start: what consideration has been given to player safety and climate issues in the proposals?

Elsewhere In The Report

It is not within the scope of FIFPRO’s report to consider the carbon emissions related to football. That said, a number of points that it identifies as major concerns for players’ are also concerns from a climate perspective. Here is a whistle-stop tour of some of them …

Calendar and Travel

A major focus of the report is the increasingly crowded calendar of football matches. Strongly related to this is the increasing international travel required for players. The report lays these issues bare, with a welter of stories and statistics.

FIFPRO provides compelling evidence of the need for urgent reforms to the calendar due to the impacts on players’ health and safety. It says there is a relentless expansion of overlapping competitions. This also leads to escalating international travel, adding to unprecedented demands on players’ health. While not part of this report it also links to an important climate issue for football. More games and more international travel for players (and fans) means more emissions, particularly from flights.

Pre- and Post-Season Tours

FIFPRO notes these tours are becoming more regular and extensive. Unlike most of the football calendar, which is determined by governing bodies, these tours are club-led decisions. FIFPRO says these tours are driven by ever-increasing commercial demands. “Where pre-season was once primarily about fitness, tactical preparation, and team cohesion, it has now become heavily shaped by brand expansion, sponsorship commitments, and revenue generation”. It says there is “a potential conflict between commercial imperatives and sporting priorities.” Finding the right balance “is becoming one of the sport’s most pressing challenges.” This again has links to climate issues. More and longer tours overseas by clubs lead to more travel-related emissions.

Domestic Matches Overseas

The climate concerns with proposals for domestic matches to be played overseas were looked at in a recent newsletter post. This includes more travel emissions, a lack of environmental governance in the decisions, and challenging changes in the climate for these matches. FIFPRO notes further concerns too, saying players will inevitably face increased fatigue. This raises injury risks and could compromise on-pitch performance.

Regional Analysis - Africa

Alongside a global analysis, FIFPRO also provides a region-by-region analysis. In regards to Africa one of the seven key trends it identifies is that a variety of extreme weather events in many regions are placing additional strain on players and “To safeguard player health, it’s essential to consider these unique environmental challenges.”

Collaboration

The report says “there is a growing need for collaboration” to address these heat-related risks. This feels like an essential part of the next steps on these issues2. While FIFPRO (understandably) focuses on players, the report has also touched on impacts on fans. In moving forward with a collaborative approach, it will be essential for football fans to be a key part of that conversation too.

In Summary

This report is an important contribution to raising awareness of the need for further action on extreme weather in football.

It also comes at a timely moment with several key decisions coming up. This includes UEFA considering domestic games being played overseas at its December meeting. Elsewhere, FIFA is considering expanding the World Cup in 2030 to 64 teams, with a FIFA Council meeting coming up imminently which may address it. In addition, FIFA is also finalising planning for the World Cup 2026, including the kick-off times of games (which are still to be confirmed).

The report also highlights that climate issues are inter-connected with other big issues for football. This includes the impacts of extreme weather on players and fans, a growing calendar of games, more international travel, and a need for updated guidance to reflect a changing climate and latest understandings. These are important issues for player safety and health, and important issues for the climate. In identifying these issues, the report provides important ground for considering future communication and collaborations on these issues.

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An incomplete list of writing on extreme weather and football (by release date)

• Pitches in Peril: How Climate Change Is Threatening Football — From World Cup Stadiums to Grassroots Pitches. Football for Future and Common Goal (2025)

• ‘Fifa should consider playing World Cup final at 9am’. BBC (2025)

• Dangerous heat is a real threat for the 2026 World Cup. Are teams ready? The Guardian (2025)

• Rethink kick-off times during 2026 FIFA World Cup to protect footballers from extreme heat. Queen’s University Belfast (2025)

• Extreme heat risk and the potential implications for the scheduling of football matches at the 2026 FIFA World Cup. International Journal of Biometeorology. (2025)

• Warming Up: How Climate Change is Changing Sport. Madeleine Orr (2024)

• Game Changer II: The impact of climate change on sports in the UK. BASIS (British Association for Sustainable Sport). (2023)

• See also this page of further resources

By FIFPRO

• Extreme Weather in Football

• Guidelines and Mitigation Strategies for Hot Conditions in Professional Football

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Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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This post looks at both of these calls and how you can feed in to them. It then goes on to take a look at an upcoming European Parliament motion, also on the European Sport Model. Following this, the post provides an opinion that, going forward, more focus is needed on European institutions in relation to sport and environmental issues.

Finally, alongside that is some further context on ongoing important European climate target discussions and also an update on UEFA discussions on domestic club games being played overseas.

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Green Sport Manifesto

There will be a launch event for the European Commission Green Sport Manifesto on the 8th October. Ahead of that the Commission has put out a call saying: “All organisations involved in sport in Europe are invited to sign up to five simple voluntary commitments and join others in highlighting their commitment to environmental sustainability”.

The initiative is targeting two groups. Firstly, sport sector organisations. Secondly, government or other public sector organisations. In doing so it is looking at the European-level, member-state level and locally.

For those people or organisations outside of these target groups this manifesto creates an opportunity to ask target organisations to consider signing-up and to learn about their reasons for doing so, or not.

It’s not totally clear to me whether clubs and organisations from non-European Union member states that participate in European competitions could also sign-up or not (though it seems not if I’m reading it right). But either way, for those not in member-states, this approach could also create an opportunity to ask sport organisations and public-bodies in their own countries to consider a similar approach.

The accompanying Green Sport Manifesto document is readable and useful. It does a good job of explaining why the manifesto is needed, its aims and how the initiative will work. There is also background on other initiatives supported in recent years.

It sets out a number of challenges identified in previous European Commission expert research in 2023, for instance, saying there is:

• “little evidence to suggest that the European sport sector is on track to deliver on European Green Deal targets.”

• “A lack of governance structures and clear responsibilities for green sport in many sports organisations, plus poor coordination across public bodies”

• “A lack of capacity, expertise and training for environmental sustainability in all but the largest and wealthiest sport organisations.”

On the one hand it may be tempting to question the value of initiatives such as this, which involve organisations making public commitments. For instance, take the UN Sports for Climate Action Framework (part of the UN Race to Zero). There is clearly little progress by some of the signatories.

On the other hand, the independent Net-Zero Tracker found that UN Race to Zero members “perform significantly better on minimum integrity criteria compared with non-members. But both groups need to improve”.

This suggests that the Green Sports Manifesto is worth signing up to and organisations should be encouraged to do so, while recognising its benefits will need to be assessed and it’s no silver bullet.

This Green Sports Manifesto was developed through the European Commission’s wonky-named “SHARE 2.0 thematic community of practice on green and sustainable sport”.

Its membership is not clear though anyone can express an interest in joining the group here (and if you are already a member and want to share more about its work, please get in touch!).

The manifesto document also mentions other priorities this group has identified including, for instance: “Further work should be done to provide a vision of how sport will function successfully in a carbon neutral world, including ethical, sustainable funding and sponsorship” and “support the development of mechanisms to ensure greater accountability and independent oversight”.

So, there are other interesting and potentially impactful things to look out for in the future too from this group.

Consultation on a “A strategic vision for sport in Europe: reinforcing the European Sport Model”

The consultation was launched this week and runs until 8th December. Anyone can respond to it whether as an individual or on behalf of an organisation and whether in an EU-member state or not. The consultation says “Whether you're a policymaker, educator, athlete, or a sports enthusiast, we want to hear what you think about our plans”.

You can respond by leaving feedback on the discussion page and/or completing the consultation survey (I gave the survey a test run and it takes 10 minutes or so and includes environment-related questions).

The Commission also expects to undertake workshops with key stakeholders, including representatives of professional sport and representatives of grassroots/recreational sports. So for those that fit that bill, there may be other routes to contribute through too.

The consultation is clearly much broader than football and much broader than climate change. The European Sport Model is summarised as:

“A values-based model for sport building on openness of competitions, a system of promotion and relegation, solidarity mechanisms and strong links between grassroots and elite level sport. The system is rooted in inclusion, diversity, equality and other core European principles.”

This new consultation seeks to build on that model and set “a new strategic vision for sport”. It follows directly from the President of the European Commission saying last September that “sport is a European public good and an increasingly valuable European asset – economically, socially, politically and culturally … [the European Commission needs to] … instil a more assertive approach to strengthening our European Sport Model which has come under pressure in recent years.”

The accompanying call for evidence document starts by saying that “The role of sport in Europe has become more prominent and more political in recent years … [and] … Sport in Europe faces growing challenges”. Included among other factors in the ‘problem definition’ is a recognition that:

“There is also a growing need to address the impact of climate change on professional and amateur athletes and sport facilities and to ensure sustainability of the sport model by addressing its environmental implications, such as the environmental footprint of sporting events.”

It is expected that this consultation will lead to a European Commission “Communication” in late 2026 (A ‘communication’ is non-binding on member states and organisations).

While it is non-binding it says its impacts are likely to include “a sustainable strategic framework with an assertive and political stance to coordinate responses with Member States and stakeholders”. It will also help “identify actions and initiatives to promote and strengthen the European Sport Model”.

It also seems likely this would eventually inform any updates to the Council on the European Union Work Plan for Sport 2024-27 beyond that period.

So, while it may take a while to see it come to fruition, this consultation seems likely to inform some key strategic European actions in the coming years and is worth responding to.

If you’ve not subscribed to receive the newsletter for free, do so here …

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European Parliament Motion, Debate and Vote

A debate and vote by members of the European Parliament on a motion on the European Sport Model, is currently scheduled to take place on 6th October. Should the vote be passed, it would lead to the adoption of a resolution from the Parliament of its political position.

While it is not legally binding it carries political weight and can influence the European Commission, Council of the EU and external actors. This will, for instance, include informing the consultation by the European Commission also on the European Sport Model mentioned above, and also UEFA’s discussions on playing domestic league games overseas.

The motion for resolution in Parliament includes a call “on the Commission and the Member States to encourage environmental responsibility and climate adaptation in sport, including sustainable equipment and sports infrastructure management, carbon-responsible event organisation and environmental education through sport".

The motion also includes other calls that may be related to environmental sustainability, without mentioning it directly. For instance, it “Calls on the sports governing bodies to prevent domestic competition matches from being played abroad” (see below for more on the issue).

Elsewhere it urges “organisers and sponsors uphold the values of the European Sport Model, including human rights, democratic values and sustainability.”

This debate is a little over two weeks away. So now would be the time for those of you in EU Member States to contact your MEP’s if you want them to contribute to the debate, including on green sport issues.

A greater focus on European institutions?

The above work by European institutions highlights that there are important actions happening at a European-level. While being far removed from the day-to-day actions that are also essential, this work by European institutions is key to informing the longer-term future of environmental action in relation to sport in Europe and beyond.

It is also clear that a number of stakeholders are already working with European institutions to inform and influence its work. Take a look at the EU transparency register and you will see bodies such as FIFA, UEFA, The Premier League, The European Club Association and others have dedicated resources and structured engagement with European bodies. At the same time, a number of sport NGO’s also engage with the EU, as do climate NGO’s.

Alongside this there are established European level groups through which organisations engage. This includes the EU Sport Forum and the Share 2.0 Community of Practice on Green Sport (though there is not much transparency on who is involved and what these are doing in practice).

All that said, it is essential to question whether the voices of the green sport community are currently coming through clearly and loudly enough to European institutions. Looking from the outside in, it seems there are areas that could benefit from further work by European institutions informed by a great range of views and knowledge on issues, including, for instance, on transport, merchandise, sport diplomacy, sponsorship and sustainability reporting. Some of this may be happening behind the scenes, so it may be partly a question of more transparency, or I may be looking in the wrong places or misunderstanding things that are happening. Please say if that is the case!

Either way, it also leads to a further question: Is there a need for sport and environment voices to engage in a more organised way at a European level? This could be about working more closely with climate and/or sports organisations (and - just as importantly - vice-versa) that have an established approach to European institutions. And/or it might be about considering new ways for green sport community voices to engage more directly themselves with European institutions?

Plenty more work is needed by and with organisations and people, aside from a focus on European institutions. At the same time, to restate a European Commission quote above: “The role of sport in Europe has become more prominent and more political in recent years”. So it seems timely to think afresh about on engaging at the European level.

A bit of wider context

EU climate target

This work is taking place at a particularly strategically important moment for Europe’s approach to climate issues. As reported in Reuters this week, the EU is set to miss a United Nations deadline for new climate targets as it struggles to agree on a 2040 climate target. Reuters says this “leaves open the question of how ambitious the EU's final target will be - and increases the likelihood that the EU will lag behind other major emitters, including China, in setting its new climate goal”.

Elsewhere, Bloomberg reports that Germany and France are saying that the targets should be discussed by EU member national leaders at their October meeting. The FT has reported that such debate by EU leaders “raises the risk of the climate target being vetoed by less ambitious member states”. Separately, the article also mentions, starkly, that “Europe is the world’s fastest warming continent, heating at twice the global average, resulting in floods and fires of increasing intensity.”

This work on new climate targets for Europe will shape what Member States do in coming years and influence what businesses and others need to do, across all sectors, including in relation to sport. So keep an eye out for further developments on this in coming days and weeks.

Domestic league games overseas

Last week the UEFA Executive Committee discussed domestic league matches being played abroad. The previous newsletter post looked at climate concerns related to these proposals.

Following its meeting UEFA issued a statement saying “no decision was taken today but UEFA will undertake a round of consultation with all stakeholders in European football - including fans.” Football Supporters Europe has said they “welcome UEFA’s commitment to meaningful consultation in the coming weeks”.

Elsewhere following the UEFA meeting, the UEFA President is reported as writing to European national associations and quoted by The Independent as calling for more co-ordination:

“as a way to ensure that such decisions – which affect European football as a whole – are assessed in their wider context. By coordinating in this way, we can anticipate the implications and reactions at a European level, rather than allowing the debate to unfold publicly in a fragmented manner.”

UEFA’s commitment to further consultation on playing domestic league matches overseas, should also include further consideration and engagement by UEFA on potential environmental impacts. Alongside this, the call by the UEFA President for a need for more co-ordination on issues “which affect European football as a whole” should prompt further considerations on whether there is the appropriate level of co-ordination at present between UEFA and national associations on climate issues.

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Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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This post takes a look at where we are now with the proposals, the opposition to them, the climate issues that the proposals lead to, and what’s next. It suggests that relocating fixtures overseas would be bad for the environment and for many other reasons, and the proposals should not go ahead.

Where we are now

Two matches are currently being proposed to be played overseas. Firstly, Spanish football’s Villarreal vs Barcelona scheduled for 20th December, proposed to be played in Miami. And, secondly, Italian football’s AC Milan vs Como, scheduled for 8th February, and proposed to be played in Perth, Australia.

The proposals have already been supported by football’s governing bodies in both Spain and Italy. The Italian Serie A says this will introduce “the excellence of Italian football to new audiences, strengthening the competitiveness of the system, and generating resources that benefit the entire movement”.1

Elsewhere the Head of the Spanish LaLiga says that “There are thousands of fans around the world — including Europeans — who have the right to see their teams play live at least once.” At the same time most commentators see the proposals as very commercially focussed decisions for the clubs and leagues, particularly to help them compete with the English Premier League.

Although a handful of club cup games have previously gone ahead overseas (the finals of Italian and Spanish cup tournaments) it would be a first for domestic league matches to take place overseas. For these games to go ahead approval is needed by the national football governing bodies (which has already happened), followed by UEFA (which meets next week), and then FIFA and the governing bodies where the games would be played.

Opposition to the proposals

While these proposals are supported by their respective leagues, a large and diverse range of voices are speaking out against them. This includes supporters’ groups for Villarreal and Barcelona, who in a strongly worded joint statement with the Spanish supporters body FASFE, have expressed their “absolute, total and firm opposition to the relocation of the match outside of Spain … Football is, to a much greater extent and much earlier, a social and cultural event than a branch of the entertainment industry and attempting to eradicate it from the community that created and sustains it since its inception is an attack we cannot stand idly by”.

In addition, Football Supporters Europe (the FSE) has expressed its unequivocal opposition, saying it is appalled and that this would strike “at the heart of the relationship between fans and their teams, breaking vital links between clubs and their communities”.

Alongside this the FSE, with the Independent Supporters Council (of North America) and the national supporters groups of Spain and Australia have written to FIFA expressing outright opposition. The statement includes in it a warning the proposals would “Generate significant environmental and logistical burdens”2.

Separately, in an official statement Real Madrid has said that this would upset competitive balance and “If this proposal [moving the Villarreal vs Barcelona game overseas] were to be carried out, its consequences would be so serious that it would be a turning point in the world of football.”

Elsewhere, The European Union Commissioner for Sport has said “European competitions must be played in Europe … I believe that clubs owe most of their success to their loyal fans & local communities … Moving competitions abroad isn’t innovation, it’s betrayal.” Also, in the coming days the European Parliament will debate what it calls the ‘European Sports Model’ including the adoption of a (non-binding) resolution that “Calls on the sports governing bodies to prevent domestic competition matches from being played abroad”.

This shows that there are many, strong, reasons for opposing the proposals. It is also important to look in more detail at the climate-related issues these proposals raise, of which three stand out.

Emissions

Firstly, and most obviously, there would be the extra emissions that these matches overseas would generate. This comes at a time when urgent cuts to emissions are needed, and the European Commission is proposing a new emissions-cutting target of 90% by 2040 for European countries.

Primarily, this increase in emissions would be from the teams, staff and fans flying long distances to and from the games. AC Milan and Como’s round-trips to Perth would clock up some 17,000 miles or more.

While many of the people attending an overseas match may live locally to the stadiums that the matches take place in, a number of supporters based in the clubs home cities and countries would highly likely fly to watch their team too. The scale at which this might happen, and the size of the extra climate impacts are unknown as no assessment has been made so far by clubs or governing bodies. However it is a very safe bet that the climate impacts of these games would be higher than them being held domestically, and that this increase would likely be significant given the amount of flying involved.

This would be even more so if fan travel to these overseas games were to be incentivised. Villarreal, a club with 19,500 season-ticket holders, has formally stated that “All Villarreal CF season-ticket holders this season will be able to fly to Miami and watch the match against FC Barcelona free of charge”.

This does not appear to be some off-the-cuff idea solely from Villarreal - Liverpool’s owner put forward a similar proposal for fans last year. Further domestic matches held overseas could see tens or hundreds of thousands of extra overseas flights and much further pollution.

Extreme Weather

Secondly, the proposed AC Milan vs Como in Perth, Australia also highlights the issue of extreme weather in football, and how it needs to be addressed further.

The game is expected to be played on 8th February, and weather records show that the daily temperatures in Perth on that day could be in excess of 30°C (over 20°C warmer than Milan on the same day).

UEFA works within FIFA guidelines on heat policy, while “Football Australia’s Heat Policy provides for a more conservative policy approach [than] that used by FIFA.”3

Football Australia also identifies the importance of acclimatisation and “allowing your body to adapt to hot and humid environments over the course of several days or weeks”. Both AC Milan and Como have fixtures scheduled the week before and after this proposed game.

Elsewhere, Football West, the governing body for football in West Australia, says “If the temperature at kick off is forecast to be … 36 degrees Celsius or higher for Senior Matches, Football West will reschedule a Competition Match.”

The potential health and climate impacts on players and fans of this match or others seems to have received no attention so far. This also leaves open important questions such as, which set of heat policy rules would this game be played under? Which rules are the most appropriate? And, is a more consistent approach needed in football?

Governance

Finally, the proposals also highlight structural climate gaps in football’s governance. UEFA has a sustainability strategy, made some sustainability updates to its rules, provided tools and guidance to clubs, and in particular, taken forward a raft of initiatives in relation to its EURO tournaments. At the same time it appears to have no requirement, policy or approach in place for considering the climate impacts of decisions at meetings of its key strategic body - the UEFA Executive Committee - even if the decisions it makes might have an environmental impact. This means its quite possible the upcoming UEFA Executive Committee meeting will not consider climate impacts as part of discussions and decisions on domestic games being played overseas.

This also highlights that UEFA may sometimes not consider climate issues in some of its important strategic decisions that could nevertheless have important climate impacts4. A recent example of this is UEFA’s decision to expand its European club tournaments, which as the BBC has noted, came with “an increasing impact on the planet”, but which appears to have been decided on blind to the climate impacts.

Climate governance gaps also extend to FIFA governance. If, next week, UEFA is to approve these games being played overseas, they would then need to be approved by FIFA too.

Current FIFA rules do not allow for domestic club games to be staged overseas. That said, FIFA set up a working group last year to look at a new framework for ‘out-of-territory games’ which it said at the time will report in the coming months. Its terms of reference include a list of “non-exhaustive factors” it will take into account in its considerations. These do not include sustainability, effectively removing the issue from its decision-making process on future domestic games overseas5.

This also appears to leaves open the possibility that the working group could report in the near future, and that FIFA Council could change its rules in relation to domestic games being played overseas, before them making a decision on these particular games. (That said, I’d welcome any clarifications as to whether that is the case, or an approval of changes in rules requires a full FIFA Congress meeting of all member associations, or some other procedure).

What next?

It’s not clear what exactly that UEFA will be discussing and deciding on at the Tirana meeting next week, and many questions remain. These include: will it be approval of these two specific matches? Will it be deciding on the principles and/or governance around approving domestic club matches to be played overseas? What will it ask FIFA to consider? Will its decisions set a precedent?

Writing for Eurosport, Philippe Auclair says that sources have said “UEFA's Executive Committee members themselves are "in the dark" and do not know whether any decisions have already been made internally, or what the trend is within the body.”

Elsewhere, while the Premier League CEO has said that “we don't have any plans to play matches abroad”, the Sport Unlocked podcast notes that this does not mean that proposals could not come to the table in the future. Relatedly, Matt Slater asks in The Athletic “does anyone really think a competition largely owned by Americans will not want to play games closer to home if La Liga, Serie A et al prove you can take the show on the road and the locals will turn up? … If either of those games takes place at their intended venues, every league will be booking flights and packing their bags”. In recent days the Football Supporters’ Association in England has said that the new independent football regulator for English men’s football has the power to intervene on the issue, if the wording in the legislation creating the regulator is interpreted robustly.

Football Espana has speculated “If Barcelona-Villarreal succeeds in Miami, what’s to stop a Manchester United-Liverpool match in Tokyo or a Bayern Munich-Borussia Dortmund clash in Shanghai?”. Also, is it so much of a stretch to imagine sponsors wanting to tie sponsorship deals to games played where they are headquartered, or where their key audiences are based? Or for the many airline sponsors in football to strongly push long-distance flights to any club games that are played overseas?

On the proposals, UEFA’s President has recently said “I don’t think it’s a good thing”, but despite this also said, “as much as we [UEFA] checked legally, we don’t have much space here if the federations agree, and both [Spanish and Italian] federations agreed”. UEFA say their next steps would be to “open this discussion also with [world football governing body] FIFA and with all the federations”.

At the same time, there are clearly some attempts to downplay the significance of UEFA’s decision on these two games. The UEFA President has also said “OK, if it’s an exception, fine; if there’s a reason, fine”. Javier Tebas, President of LaLiga has said “let’s put things in perspective: we are talking about 1 match out of 380”, and Italy’s Serie A made a strikingly similar point in a statement when saying “Talking about betrayal over a single game, out of a total of 380 Serie A matches, seems excessive”.

To my eyes, it seems very hard to balance statements about these just being one game, with statements from the same organisations about wanting to reach new audiences. To achieve those goals would need a continuing and deepening effort, with more games overseas over time, rather than a one-off. There is also a clear potential for this to lead to a race between leagues to go quicker and go bigger than others.

Along similar lines, the FSE and partner supporter groups say in their letter to FIFA

“Those behind the proposals claim they are only interested in a one-off event, a claim we reject. If permitted, this would open a Pandora’s box of disarray for football. Short-sighted commercial interests cannot take precedent over protecting domestic football and the communities our clubs grew out of.”

Staging domestic club games overseas would cause significant and unnecessary increases in football-related pollution at a time when more climate action is needed. For this reason, and the many other compelling reasons others have stated, the proposals should be blocked. In addition, the situation also highlights important questions that need to be addressed about climate governance in football, and how the game deals with extreme weather.

Fran

P.s. There are new developments and statements coming thick and fast at the moment in relation to these proposals, so keep an eye out on this newsletter’s socials for news on those.

P.p.s. This was a particularly (and needlessly?) complex one to write, so all comments, clarifications, corrections, and communication tips are more than welcome - either here in the comments or direct by email.

Donate here. All donations, big or small are super-welcome. These will help keep the newsletter going, open to all for free, and informing action on football and climate issues. If you’ve not subscribed to receive it for free, do so here

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Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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Under the central model used in the report, impacts could rise by between £95 million and £190 million per year depending on the extent of further climate change. Under one of the other alternative models also presented in the report, the current financial impacts may actually be as high as £835m and potentially rise much further with more climate change. Alongside this the report identifies annual emissions from grassroots sport of between 3 to 4 million tCO2e.

The report, Exploring the financial implications of climate change on grassroots sport by Alma Economics for the Department for Culture, Media and Sport was published last Friday. It looks at both the impact of the grassroots sport sector on the environment, and also the impact of climate change on the grassroots sport sector.

The report is an important development. It is the first report I am aware of commissioned by any Government to attempt to quantify these financial impacts. The report also sets out impacts on sports facilities and participants as well as the financial impacts. It identifies long-term outcomes including reduced participation in sport, and people become less active and less healthy. It says that “Certain sports might not survive”, that adverse weather causing financial unsustainability could mean “Sports clubs become unable to survive financially” and also that “If no action is taken, grassroots sport risks becoming elitist.”

At the same time, the report acknowledges that the figures it uses are likely to be conservative, and further research is needed1. Alongside this the report recommends the development of a “climate risk index is a tool used to assess the level of vulnerability and exposure of grassroots clubs to climate-related hazards”2. The authors note that “the carbon footprint and financial model could be extended to include further climate and financial impacts and sport types … [and also] … “a deeper dive into specific sports could provide more detailed insights”. This is a recommendation that would seem particularly important to take forward in football, with its position as our most popular sport.

Elsewhere the report says that “there are likely a host of additional channels through which climate change and adverse weather are affecting sports clubs throughout the country. A major cost to clubs both now and in the future will be investments to mitigate against the impact of weather and ensure their facilities can remain usable into the future. The model was not able to capture this due to the heterogeneous nature of such investments and the lack of data. The costs are, however, likely to be large”.

The report notes that without further action community sport clubs will struggle to absorb the financial burden, forcing up membership fees and making grassroots sport less accessible. Alongside this, sports National Governing Bodies “are now seeing an increase in funding requests to deal with climate change impacts”. These findings in the report lead to important questions about whether current approaches to climate change by national governing bodies in sport are enough, and who and how responses to climate change will be funded.

The most recent UK Government Sports Strategy, published in August 2023 under the last administration, included an action to “identify the support needed to help the sector adapt in the long-term”, but no update on its progress was published. The current Government is yet to set out its approach to sport and environmental sustainability. As a contrast, the French Ministry of Sports, Youth and Community Life has published A national plan to adapt sports practices to climate change (albeit with no financial assessments)3.

So far football’s governing bodies have not paid much attention to the impacts of climate change on football and appear to have made no assessment of the financial impacts now or in the future4. Alongside this, The Football Foundation, the organisation which channels funding from the Premier League, The FA and the Government to grassroots football, does not appear to have a strategy or objectives in relation to environmental sustainability. This report on financial implications also comes soon after the Government rejected cross-party calls for the new Independent Football Regulator to be able to consider the financial impacts of climate change on elite men's football in England.

This report is released against a backdrop of the Committee on Climate Change saying in April that "The UK’s preparations for climate change are inadequate" and there is a need to "Implement monitoring, evaluation and learning across all sectors." This report, while focussed on the impacts of climate change on grassroots sport, also has important insights and implications for elite sport too. In addition, it provides important analysis and action needed in relation to reducing emissions within the sector.

It sets the scene for further work that is needed urgently in the UK, and should also be a wake-up call to international governing bodies including UEFA and FIFA that have important gaps of their own in understanding and action on these issues. As a parent who has seen their son’s youth football matches in South London postponed due to weather impacts too many times (and a few go ahead that more resembled mud-wrestling), more action can’t come soon enough.

Fran

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Donate here. All donations, big or small are super-welcome. These will help keep the newsletter going, open to all and informing action on football and climate issues.

Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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When I put my pen down in March I didn’t expect to be returning here. Since then, I've had a long-ish and welcome time away from it to focus on some related, and some unrelated, things. And in the meantime there have been several developments on a range of the issues previously covered here. So it might seem a bit strange to bring it back.

But the itch to write it again never went away, and I haven’t been able to keep from reading, hearing, chatting and living the issues. Most of all, I’ve an inkling there are more contributions still to be made here which might just bring something different and useful to the table.

When I first started this newsletter a few years back, I didn't know clearly where I was going with it. My approach was a bit like Gromit’s during The Wrong Trousers when he’s on a moving train and lays out track in front of himself to keep the train going forward.

The Wrong Trousers | Train Chase Scene by Wallace & Gromit on YouTube. Watch on YouTube.

That approach seemed to work well enough for the newsletter last time, perhaps fortuitously. So, as I feel my way back into this thing, expect a similar approach to last time with some changes as we go along … though no capturing of penguins.

There are lots of ways you can help out with the newsletter: liking and sharing posts, commenting, providing insights and tips, offering to write a post, helping with research or publishing it, partnering, or donating. Any of these would be more than welcome. And if it helps, ping me a line to chat further.

See you again soon!

Fran

Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
LinkedIn | Bluesky | X

Along the way, I feel like I've learnt a hell of a lot. But that said, I'm still firmly in the foothills of expertise and action in comparison to the many amazing people I've come across. On which score a special thanks goes out to all those who went out of there way to contribute expert guest posts.

Sadly though, with a change of personal circumstances, it's not proved possible to keep this running as a free and open-to-all newsletter. A huge thanks to those who did show support in the recent donation drive to try and keep things going. It became clear to me quite quickly that this would not be enough to keep the show on the road, and those who did donate are being sent it back.

I looked at the idea of moving the newsletter to a pay-based approach. But on balance, I felt this would be a leap too far away from the original purpose, motivation and audience for the newsletter, and make it a very different kettle of fish.

So it's now time to take a step back and explore future directions both in the football and climate space and elsewhere, with a close eye on making things more viable for me to do so. Please get in touch if you have any suggestions, or just want to bounce around ideas, I'm all ears.

All the content will remain freely available online. And if anything unexpectedly leads to the newsletter coming back in some workable shape or form, then that's great, as it’s been a blast. Otherwise, there’s plenty happening on the football and climate agenda, and clearly lots more coming up …. so upwards and onwards to everybody involved!

Fran

As we hurtle head-long into the business end of the season, its also been a busy fortnight on the football and climate agenda. And with the Green Football Great Save campaign now in full swing expect much more to be kicking-off in the coming weeks.

Before we dive in, the previous newsletter started with a special message that I’d like to repeat: Please donate if you can and you would like to see this newsletter continue in its free and open-to-all form. Your support can make the difference to its future. You can donate here.

Fran

Quick links: Virada; Green Football’s Great Save; Football Governance Bill - An amendment; Football and Floods - Argentina; Club focus; In other news; Disclosures - Liverpool and Manchester City; Liverpool and Direct Air Capture; FIFA; The Premier League Environmental Sustainability Strategy.

Virada

In a letter to the United Nations and countries of the world, Brazil’s incoming President for the international climate talks in November (COP30), André Aranha Corrêa do Lago, has said …

“Together, we can make COP30 the kickstart of a new decade of inflection in the global climate fight. As the nation of football, Brazil believes we can win by “virada.” This means fighting back to turn the game around when defeat seems almost certain. Together, we can make COP30 the moment we turn the game around”

Green Football’s Great Save

This year’s Green Football campaign has kicked-off with a bang, and is running from 11th March to 2nd April. Fans, clubs, footballers and more are helping save football kits from ending up in landfill. There’s more happening than you can shake a stick at, and plenty of ways to get involved.

Looking at just a few kit suppliers we get a sense of the enormous scale of the emissions impacts from new kit. Adidas put their annual emissions at 5.4 million tCO2e, Nike put theirs at 9.5 million tCO2e and Puma put their scope 3 emissions at 1.4 million tCO2e. The proportion of these companies emissions that are due to football kit is not stated, but football is clearly a big part of their businesses, and these are just a few of the kit manufacturers.

For Green Football’s Great Save there are too many different actions from clubs, players and more to round-up all of them. But some of those taking action so far include:

• Clubs: Bolton, Bristol City, Dundee United, Forest Green Rovers, Lewes, Northampton Town, Oxford United, Preston North End, Queens Park Rangers, Spurs Women, Watford, Wycombe Wanderers

• Players: Ethan Ampadu of Leeds United; Josie Green of Crystal Palace Women; Emma Ilijoski and Kerry Beattie of Aberdeen Women; Ben Mee of Brentford; Demi Stokes of Newcastle United Women

• Community Sports Trusts: Manchester United, Millwall, Sheffield United, Sunderland, Wigan Athletic

Others also include:

• Professional Footballers Australia taking the campaign across the world

• Coverage by TNT, Sky the BBC, and Forbes.

• Former footballers Jamie Carragher and Kris Boyd joining in.

• Several grassroots County Football Associations including Birmingham County, Middlesex, and more.

Football Governance Bill - An amendment

In the UK, the plans to create an Independent Football Regulator, through a Football Governance Bill are continuing to proceed through the UK Parliament.

At the ‘Report Stage’ in the House of Lords this week, several proposed amendments were debated. This included one calling for environmental sustainability to be included in the remit of the regulator. It was put forward by Baroness Jones of the Green Party and supported by Conservative Peer, Lord Gascoigne and The Lord Bishop of Sheffield. The amendment was supported by a number of organisations and this newsletter.

In debate in the House of Lords, Baroness Jones said the amendment acknowledges “the link between environmental and financial sustainability” and that “although some clubs are doing commendable work in this area, progress is inconsistent, erratic and lacks enforcement. Without regulation, football will have fragmented, inadequate responses to climate threats”.

The Lord Bishop of Sheffield said that “We know that climate change impacts sport; we therefore need to equip clubs, especially those in the lower leagues, to mitigate the vagaries of extreme weather, whether in the form of droughts or torrential rain. Incorporating a duty to monitor and reduce the climate impacts of English football would only enhance its value to our nation and local communities.

Lord Gascoigne talked about the soft power and hard power of football saying “throughout the ages football has pushed and campaigned on many important issues, so it is right that the many things that clubs promote at home and abroad should include the environment, nature and broader sustainability”.

In response Baroness Twycross, speaking for the Government, said “the regulator’s focus should be on the problems that football has clearly shown itself to be unable to properly address through self-regulation. By contrast, football has demonstrated the ability to take action on the environment … [and also] … This Amendment would also constitute scope creep”.

Labour Party peers voted against the amendment. Conservative peers and Liberal Democrat peers largely did not vote one way or another. The amendment was therefore defeated by 168 votes to 8. Following this, the Bill will shortly move on to the House of Commons for further scrutiny.

Football and Floods: Argentina

Following flash flooding at least 16 people have died in the Argentinian city of Bahia Blanca. 3 days of mourning were declared across Argentina and $400 million in infrastructure damage estimated.

Local clubs, Club Villa Mitre and Club Olimpo, who play in the third tier of Argentinian football, have been extensively involved in the response efforts. This has included collecting and delivering donations, relaying official municipal communications, and suspending football activities.

Lionel Scaloni, the Argentina national manager and his coaching staff posted a video showing support for those affected and encouraging Red Cross donations. Leading clubs across Argentina have joined donation efforts including Boca Juniors, River Plate, and Independiente and Racing Club working together.

River Plate have also agreed to play a friendly match in Club Olimpo’s stadium to benefit the victims of the floods. Players showing support included Lionel Messi.

Club focus

• Bohemians have launched the development process for their climate transition plan.

• Bristol City is the first EFL team to join the UN-backed 'Sports for Nature' framework.

• Chester has installed new LED lights after receiving a sustainability grant to do so. It will see a two thirds reduction in energy bills from usage of the lights.

• Manchester United say their plans for a new stadium will see it at the “heart of a new sustainable district.”

• Newark And Sherwood United have revealed their plans for a new stadium built from reused shipping containers and, separately, are hosting a People, Planet, Pint and Football event at their existing stadium.

• Real Betis Balompié is the first LaLiga team to join the UN-backed 'Sports for Nature' framework.

• FC St. Pauli has published its first sustainability report. There’s lots of interesting stuff in there including an analysis on whether to introduce a match-and-public transport combination ticket (though I wasn’t clear if any changes are planned on the basis of it?). Another first - they have also published an easy-read version of the report alongside it.

• Villarreal had their game with Espanyol postponed at the last minute due to flooding risk.

• Wrexham are flying from Chester to Oxford for the game against Wycombe Wanderers.

• A Carbon Boot award went to Southampton and Aston Villa for their short flights to games. The team responsible for Carbon Boot also take a look at Arsenal’s travels to and from Manchester United last weekend.

• Community Sports Trusts in action included: Charlton Athletic and Spurs

In other news

EFL

• The EFL announced Bristol City and Plymouth as the first two EFL Green Clubs to receive Gold awards for improvement to their environmental practices and operations.

• Supporter groups, Spirit of Shankly and the Newcastle United Supporters Trust have written a joint-letter to the CEO of the EFL about the upcoming Carabao Cup Final. On the late Sunday kick-off time they say: “Travel on public transport is difficult later on Sunday evenings with direct trains not always available, and it shows disdain for ‘green football’ campaigns as many will be forced into using their own vehicles instead of public transport.”

Long-distance travels

• Italian Serie A commercial director Michele Ciccarese, has stated an ambition for the Italian top-flight to play regular season games in the United States in “one to three years.”

• Details of the second pre-season Premier League Summer Series in the US have been announced. I’m not clear on who the emissions from these matches should be attributed to - the Premier League? the clubs? or the US event organisers? If you have any insights, please share.

Grassroots

• The Birmingham County FA, signatories to the UN Sport for Nature Framework, has launched a Football for Nature Fund.

• The Berkshire and Buckinghamshire FA has launched an eco club pledge to inspire their local amateur clubs towards more action.

Also

• Sky Sports speaks to Plymouth players and staff, and Katie Cross of Pledgeball, about sustainable travel. Pledgeball are also hiring a new project manager.

• As part of the Free Kicks project, co-funded by the EU, there’s a webinar on 26th March on Engaging Fans With Sustainability on Match Day and Beyond

• Congratulations to all the nominees in the sustainability category for the Football Business Awards.

• Look out for the decision on the next International Olympic Committee. President which will be taken between the 18th and 21st March. Reuters reports on Olympians make climate plea to IOC presidential candidates.

Disclosures - Liverpool and Manchester City

In the UK the biggest companies are required to make climate-related financial disclosures (CFDs) in their annual accounts. I looked at Arsenal’s in the last newsletter. We now have two more. Here are a few points I took away from both.

Liverpool

• This is Liverpool’s second year of including a CFD in their annual accounts. This year it’s on pages 3-5 with further information on energy and emissions also reported on page 10.

• Most of the CFD restates what was said last year with a slightly extended ‘metrics and targets’ section. That section now includes some further narrative, though to my eyes it seemed light on actual metrics and targets.

• The top risks identified are unchanged: increased storms causing cancellation or abandonment of matches or damage to facilities, and also the impacts of sustained temperature increases on players, coaches, staff, and fans.

• Scope 1 and 2 emissions, the intensity ratio, and energy consumption are all up this season. Emissions are up 16.5% and energy consumption by 11%. No reasons for these figures are given.

• The scope 1 and scope 2 emissions set out here do not cover all of Liverpool’s emissions reporting. Details on their scope 3 emissions, which are the lion’s share of their overall emissions, will be in their ‘The Red Way’ annual update, which is referred to here several times. That update is usually published later in Spring.

Manchester City

• This is also Manchester City’s second year of including a CFD in their annual accounts. This year, it’s on pages 7-12 with further information on energy and emissions also reported on page 15.

• The information in this CFD appears to be a summary of information published in October 2024 in Manchester City’s annual ‘Game Plan’ Report, with several references made to it. But that report is 97 pages so it's hard to be sure.

• Risks are identified for eight different clubs globally in the City Group. For Manchester City itself, the separate Game Plan report includes over 50 risks. That said it’s hard to identify in this CFD or from Game Plan what the club believes the top risks for Manchester City are.

• The SECR section on page.15 reports the Group UK emissions up by nearly 60% to 6,930 tCO2e. This appears to be in relation to scope 1 and 2 emissions only. Separately, it also refers to the club’s emissions reducing by 16%, equal to 5,840 tCO2, though does not say what from or to. This appears to be in relation to Game Plan figures, but could have been clarified here.

• Elsewhere the report says that “'Game Plan' is the club's 20th annual report with continuous annual CO2 reductions exceeding 14%”, which appears to me a mis-statement of plans to try and reduce emissions 14% per annum to 2030.

• Understanding the metrics here is difficult and the report says that “From 2024-2030, the Group will establish new metrics to measure.” This will hopefully make things clearer and more consistent.

The purpose of these CFDs is wider than reporting on targets and metrics. That said, looking at what both clubs say in these CFDs on targets and metrics it's difficult to understand what progress is being made towards their net zero commitments.

Elsewhere a recent Financial Reporting Council review of CFDs by companies includes recommendations and examples of how to report on these targets and metrics, as well as many other points for a good CFD. Included in this, the FRC is also clear that companies should not cross-refer to information presented outside the annual report. Hopefully, future reports from both clubs will be easier to read without the extensive and difficult cross-referencing to their separate sustainability strategies.

Liverpool and Direct Air Capture

Liverpool have announced a partnership with a carbon capture, utilisation and sequestration company. This is a first in bringing the role of direct air capture (DAC) into football. The International Energy Agency provides a useful introduction to the technology here. The partnership will launch products for Liverpool supporters and “Each product will have its carbon footprint addressed by removing an equivalent amount of carbon (CO2).” The scale of Liverpool’s investment and the expected amount of emissions to be captured is unclear. DAC, according to a news story in The Times last week, costs “around £600 per tonne of CO₂”, and Liverpool’s emissions last year were reported as 75,133 tCO2e.

FIFA

• FIFA’s Annual Report 2024 mentions (on pg.108) that FIFA will invest $10m on sustainability for the FIFA World Cup 2026. This seems small in comparison to the €30.6m investment by UEFA into the EURO 2024 tournament.

• FIFA is to consider expanding the Men’s World Cup to 64 teams for the 2030 tournament. There is no indication that environmental impacts will be among the considerations in the mix.

• Elsewhere The Guardian reports that Dangerous heat is a real threat for the 2026 World Cup. Are teams ready?

• FIFA has kicked-off the bidding process for the Women’s World Cups in 2031 and 2035. The bidding requirements appear unchanged from other recent FIFA World Cup requirements on sustainability requirements .

• An updated version of the FIFA Stadium Guidelines includes a section on sustainability.

Premier League Environmental Sustainability Strategy

Just as I was finishing off putting together this newsletter the Premier League published its Environmental Sustainability Strategy, so this section is a bit of a last minute bolt on. I’ve not had a chance to take it all in and hope to return to it in a future post. For now, I’ll just solely focus in on one point in it which is the minimum standard for “All Premier League clubs to have a robust environmental policy by the end of Season 2024/25”.

Taking a look at the policies and statements published by clubs to-date we see a mish-mash of approaches. Aston Villa’s short statement was last updated in 2021 and says a long-term strategy will be published in due course. Bournemouth has a single slide published in 2021. Everton does not seem to have a policy on its website anymore having removed details of its 2019 ‘Everton For Change’ work. Manchester United last updated their short statement in 2017. West Ham have seven bullet points on initiatives that was posted online in 2022. Other clubs have more extensive or up-to-date statements or policies in place, though they all take hugely different approaches.

What constitutes a robust policy for Premier League clubs, and who decides if clubs have met a minimum standard, is not clear. Will clubs be left to mark their own homework? How will fans know if they are robust? Some form of independent assessment would be the best approach along with transparency on what a robust policy for clubs should include. For instance, should it include a club setting a target to cut emissions? Only nine clubs have so far.

In the meantime, based on what we see now it looks like several clubs will not have a robust policy in place by the end of the season. What next steps the Premier League would take if they are not, isn’t clear.

There’s a lot more in this strategy to take in than what I have narrowly focussed on here now, but that’s for a future post. For now, I’d be keen to hear others views on the above point or any aspects of the strategy - either in the comments here, or drop me a line directly if you prefer.

Phew! Busy times. As ever, comments, corrections, content suggestions and offers to write guest posts are welcome at any time. And donations to keep this free and open-to-all are really, really super welcome.

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Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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