UEFA’s Annual Sustainability Report
Respect and Boundaries: Where UEFA draws its line on emissions
UEFA’s latest Respect Report sets out its sustainability ambitions and progress. Taking a closer look at what emissions it counts – and what it leaves out – raises some important questions for UEFA’s approach going forward.
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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Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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Great piece, thanks! It would also be interesting to dive into the claim that 100% emissions are mitigated, which seems some sort of offset fairytale and highly misleading.