The missing pillar: UEFA's climate resilience gap
What it is and how to address it
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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
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.
Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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The European Scientific Advisory Board on Climate Change's February 2026 recommendations propose SSP2-4.5 as the common reference for adaptation planning - consistent with a warming trajectory of 2.8–3.3°C by 2100 - with SSP3-7.0 as the stress-testing scenario. This would mean not using a 1.5°C scenario as a central scenario. In addition the high-emissions scenario, SSP5-8.5, was recently established as implausible in a peer-reviewed paper published in April 2026 (van Vuuren et al., Geoscientific Model Development). In that paper SSP3-7.0 is proposed as the high-warming planning case, the same scenario the EFCR framework is already using.