LEGAL ANALYSIS OF CAF’s RETROACTIVE FORFEITURE OF THE 2025 AFCON FINAL
The AFCON 2025 tournament might have come to an end; however, its title is still very much in the air.
On 17th March 2026, the Confederation of African Football (CAF) Appeal Board presided by Justice Harriman issued its ruling in the appeal lodged by the Fédération Royale Marocaine de Football (FRMF) concerning the final of the TotalEnergies CAF Africa Cup of Nations (AFCON) Morocco 2025, played on 18 January 2026 between Senegal and the host nation Morocco.
The Appeal Board declared that the Senegal national team had forfeited the match pursuant to Article 84 of the AFCON Regulations. As a consequence, the on-field result of 1-0 to Senegal was set aside and recorded as a 3-0 victory to Morocco, thereby awarding the 2025 AFCON title to the host federation.
The underlying facts, as accepted by the Board, were that late in normal time, with the score at 0-0, Senegal’s national team and staff left the field of play for approximately 15-17 minutes without the referee’s authorisation, in protest against a penalty awarded to Morocco (and an earlier disallowed Senegal goal). Play eventually resumed after intervention, the penalty was saved, and Senegal scored the only goal of extra time. The Appeal Board found that this conduct fell squarely within Article 82 of the Regulations, which provides that a team which “refuses to play or leaves the ground before the regular end of the match without the authorisation of the referee… shall be considered loser and shall be eliminated for good from the current competition”, thereby triggering the forfeiture sanction stipulated in Article 84 of the Regulation.
The FRMF’s position was procedural and regulatory rather than sporting. It sought strict statutory interpretation and application of the competition rules to ensure clarity, stability, and equal treatment for all participants. It maintained that the unauthorised withdrawal constituted a clear breach warranting the prescribed sanction.
Senegal’s Fédération Sénégalaise de Football (FSF), in its immediate response, contended that the match had been validly completed and concluded under the authority of the appointed referee, that the temporary protest did not amount to a refusal to play within the meaning of the Regulations once the team returned, and that the Appeal Board’s retroactive forfeiture undermined the finality of on-field decisions.
The FSF described the ruling as lacking legal foundation and announced its intention to challenge the decision via an appeal before the Court of Arbitration for Sport (CAS).
RECONCILIATION OF ARTICLE 82 WITH IFAB LAW 5
The crux of the controversy lies in how Article 82 of the AFCON Regulations, which declares a team the loser if it “leaves the ground before the regular end of the match without the authorisation of the referee”, can be applied literally and in isolation, or whether it must be read in harmony with other governing norms, particularly the referee’s authority under IFAB Law 5, which states that the IFAB Law 5 establishes the referee as the sole and supreme authority on the field during a match, with absolute power to stop, suspend, resume or abandon play.
The Appeal Board interpreted Article 82 literally. Senegal’s 15–17-minute walk-off in the 98th minute triggered automatic forfeiture under the linked Article 84, regardless of the referee’s later decision to resume play and complete extra time. Yet this interpretation sits uneasily beside other provisions and established sports-law principles.
Article 148 of the CAF Disciplinary Code offers a contrasting starting point. It states that a team which “refuses to play a match or to continue playing one which it has begun” faces a minimum $20,000 fine “and will, in principle, forfeit the match.” The phrase “in principle” implies that it leaves room for discretion and proportionality rather than mandating automatic 3-0 reversal.
The Field of Play Doctrine, notably articulated in CAS 2015/A/4208, further complicates the picture. It holds that on-field decisions by the referee are generally immune from administrative reversal unless there is clear evidence of bad faith, arbitrariness or a manifest error of law. Overturning a fully completed final from the boardroom risks breaching this doctrine, especially when the referee exercised his discretion to continue rather than end the contest.
In CAS 2019/A/6483 – Wydad AC v. Espérance Sportive de Tunis, the referee formally abandoned the match after a prolonged delay, and CAS upheld the resulting forfeiture. Here, by contrast, the referee resumed and finished the game , a choice Morocco itself accepted by participating in the penalty and extra time. This participation opens the door to an estoppel argument having approbated the referee’s decision to continue, a party may be precluded from later seeking to undo the outcome through administrative channels.
This literal interpretation of Article 82 sits uneasily not only with IFAB Law 5 and the Field of Play Doctrine, but also with CAF’s own historical practice. In the decisive final round group match of the 1976 AFCON (Guinea v Morocco, 14 March 1976, Addis Ababa), the Moroccan team temporarily left the pitch in protest against a refereeing decision while trailing 0-1. Play resumed after their return, the match ended 1-1 (late equaliser by Ahmed Makrouh/Baba), and Morocco went on to be declared tournament winner without any forfeiture or disciplinary sanction being applied by CAF.
More so, the principle of proportionality also comes to play. Stripping a confederation of a continental title for a temporary protest that did not prevent the match from reaching a natural conclusion strikes raised a lot of issues especially when Article 148 already provides calibrated sanctions (fine plus conditional forfeiture). The Appeal Board’s choice to treat the walk-off as an irreversible “interruption” under Article 84, while ignoring the completed extra-time goal, risks undermining the very sporting finality that fans and players expect.
The ruling by the CAF Appeal Board highlights the Board’s literal application of Article 82 and on the other hand, the FSF’s arguments emphasise the referee’s supreme authority under IFAB Law 5 to resume and complete the match.
Ultimately, the dispute turns on interpretive approaches to harmonising these provisions, whether the walk-off triggers an irreversible sanction regardless of later resumption, or whether the referee’s exercise of authority and the match’s natural conclusion render the result conclusive.