Saudi Arabia's new Sports Law: What investors and stakeholders in the sports sector need to know

Alert

03 August 2026

20 min read

Introduction to the sports law

Having been identified as a key sector in the Vision 2030 project, the sports sector has been a key area of focus in the Kingdom of Saudi Arabia (the "Kingdom"). The Kingdom has hosted global sporting events, made statement acquisitions in the global sports sector via PIF and its sports investment arm, SURJ Sports Investments, and has opened up Saudi sports assets, notably Saudi Pro League football clubs, for inbound foreign investment. Following this major evolution of the sports sector, there is now a similarly robust and sophisticated legislative framework in place to drive the continuing evolution of sports in the Kingdom.

The Sports Law was approved by Cabinet Decision No. 414/1447 and promulgated by Royal Decree No. M/121/1447 dated 10/06/1447H (the "Sports Law"). The Kingdom's first standalone Sports Law supersedes the Statute of Sports Federations and the Saudi Arabian Olympic Committee issued by Royal Decree No. (M/55) dated 1407/10/19 AH and cancels all conflicting provisions.

The implementing regulations to the Sports Law (the "Implementing Regulations") will also be issued imminently by the Minister of Sports (the "Minister"), although as of the date of publication of this alert these have not yet been issued. A significant number of the Sports Law's provisions expressly defer to the Implementing Regulations for further detail. Clients should treat this alert as a guide to the framework established by the Sports Law itself and must monitor the Implementing Regulations closely as they will fill critical commercial and operational gaps.

For a sector that has previously been fragmented, a comprehensive and codified legislation is a welcome change. However, not only does the Sports Law consolidate existing practice, it creates a new commercial investment architecture for the sports sector, introduces personal liability standards for sports entity governance, establishes a comprehensive licensing regime across the entire sports value chain, and formalises a dedicated sports arbitration centre within the Kingdom. For parties with exposure or ambitions in the Saudi sports market, the Sports Law simultaneously opens significant new investment pathways and imposes a compliance burden that requires immediate attention.

The new sports entity framework

One of the primary functions of the Sports Law is to categorise the different entities involved in sport within the Kingdom. The Sports Law defines a "Sports Entity" as either a Committee, a Federation, a Club or an Association. Understanding the legal characteristics of the type of Sports Entity you are dealing with is the starting point for any commercial engagement in the sector. The choice of form will have direct consequences for investment access, governance requirements, profit distribution, and commercial flexibility.

The Saudi Olympic and Paralympic Committee (the "Committee") is a non-governmental sports body with legal personality that does not primarily seek to make a profit and is the entity recognised domestically and internationally as the Kingdom's National Olympic and Paralympic Committee. The Committee may establish companies and contribute or participate in them in accordance with the Companies Law, after obtaining the Minister's approval. It may also own real estate and movable property and invest funds in accordance with the Implementing Regulations. The Committee is required to adopt its own bylaws through vote of the eligible Federations, and the Committee must act in accordance with these bylaws.
"Federations" are non-governmental sports bodies with legal personality that do not primarily seek profit; each is the recognised entity in the Kingdom for the sport within its jurisdiction. Only one federation may be established per sport. Federations hold wide powers in relation to their respective sports, including licensing clubs, coaches, sports agents, and other individuals, and registering professional and amateur players and referees. They may organise sports competitions, set participation conditions, operate and own the rights related to them, and market them.
"Clubs" are the category most directly relevant to private investment. A Club is a non-governmental Sports Entity with legal personality that takes the form of either a non-profit sports institution or a company governed by the Companies Law. The choice to constitute a Club as either a non-profit or a commercial organisation is the foundational premise of the commercial investment model contemplated by the Sports Law.
"Associations" are entities established by Clubs to manage and commercially market competitions. An Association similarly takes the form of either a non-profit sports body or a company under the Companies Law and exercises its functions in managing and marketing sports competitions in accordance with its bylaws and the regulations of the concerned Federation.

The Ministry will establish a National Sports Registry (the "Registry") in which all Sports Entities, the Saudi Sports Arbitration Centre ("SSAC"), the Saudi Anti-Doping Committee ("SADC"), sports groups, facilities, centres, institutes, academies, and schools must be registered. Failure to register may render contracts with the entity void or unenforceable. The Implementing Regulations will specify which contents of the Registry are publicly accessible. Legal personality for a Sports Entity (in non-company form) is acquired only from the date of registration. Any amendment to a Sports Entity's bylaws must also be recorded in the Registry. Registry status is a prerequisite for legal personality and therefore for the enforceability of commercial arrangements with Sports Entities.

In addition to codifying the Sports Entities, the Sports Law also includes definitions for athletes, coaches and agents. Athletes are now split between professional and amateur, and athletes come under the purview of their respective Federations, which will include setting licensing conditions and penalties for breaches of the Sports Law. The changes made should help to professionalise the sports sector and those that work in it. Athletes will receive greater protection, and all individuals will be subject to regulatory oversight designed to ensure compliance and limit misconduct.

Investing in Saudi sport: The company pathway

This is the most commercially significant innovation in the Sports Law for institutional investors and there are now various options for ownership of a sports company within the Kingdom.

Before submitting an application to establish a sports company or before an existing company engages in sports activities, the Minister's approval must first be obtained. The Minister shall issue his decision within a period not exceeding 60 days from the date of submission of a complete application; if this period expires without a decision, the application is deemed rejected. The capital of a sports company shall not be less than the amount specified in the Implementing Regulations, and in any event shall not fall below the capital specified in the Companies Law. The exact minimum has not yet been prescribed.

Once Ministerial approval is obtained, the company must apply to register its constitutional documents with the Registry within 60 days of establishment or of the Minister's approval decision, as applicable. It must also notify the Ministry of Sports (the "Ministry") of any subsequent amendments to those documents within the same period.

For existing Clubs and Associations currently constituted as non-profit institutions, the Sports Law creates a formal conversion mechanism that did not previously exist. The General Assembly of either a Club constituted as a sports institution or an Association constituted as a sports body may issue a resolution to transform such Sports Entity into a company, and that resolution must be approved by the Minister to take effect.

Upon conversion, all trademarks, logos, fixed and movable assets, contracts, rights, and obligations of the Club will transfer to the newly formed company and the company assumes full responsibility for the obligations arising from the Club or Association prior to their transformation. Upon establishment of the company and completion of the transfer the legal personality of the original institution is extinguished. Investors should note that the Minister retains discretion over how conversion proceeds are applied, which may affect post-conversion capital structure and distributions, and the Implementing Regulations will specify the controls on this.

For new investors, Club conversions represent an entirely new M&A opportunity in the Kingdom. Previously constituted as non-profit entities without transferable equity, Saudi Clubs can now become investable corporate vehicles. Investors considering acquiring stakes in Clubs should conduct full historical liability due diligence given that pre-conversion obligations transfer wholesale to the company, and should await the Implementing Regulations, which will specify the conversion procedure in detail.

A Club's conversion into a company may constitute a change of control event under existing documentation and could affect counterparty rights and obligations. Investors with existing commercial relationships with Clubs, whether through sponsorship, naming rights, venue, or broadcast agreements, should review those arrangements now.

Foreign ownership and cross-border investment

As a protective measure over assets with important community value, the Sports Law states that the share of a foreign partner or shareholder in a sports company shall not exceed the percentage determined by the Minister. That percentage has not yet been set and will be established when the Implementing Regulations are published. This is a critical unknown for any international investor structuring an acquisition or a co-investment with non-Saudi capital. Until the Ministerial determination is made, international investors cannot finalise ownership structures for sports companies. Any investor that is in advanced discussions on a sports investment during this interim period should build contingency provisions into any heads of terms or conditional agreements to accommodate the foreign ownership threshold once published, such as conditions precedent tied to confirmation of the foreign ownership cap, or price adjustment mechanisms if the cap is lower than anticipated.

The Ministry is required to coordinate with the Ministry of Commerce, the Ministry of Investment (specifically in respect of foreign investment), and other concerned authorities to establish the conditions for obtaining approvals for mergers, acquisitions, and disposals of ownership rights in sports companies, in line with the Ministry's strategic orientations for the sports sector. The inclusion of this provision clearly signals that M&A activity in the sports sector will require sector-specific regulatory approvals in addition to those under the Companies Law and the Investment Law. Investors must factor additional Ministry clearance timelines into transaction planning and should engage early and proactively with the Ministry as a key stakeholder. The mechanics of this approval process will be prescribed in the Implementing Regulations.

Governance and board accountability

As well as categorizing the types of Sports Entities and individuals participating in sport in the Kingdom, the Sports Law also provides requirements on the governance of such Sports Entities. All Sports Entities must comprise three statutory organs: a General Assembly, a Board of Directors ("Board"), and either a General Secretariat or Executive Management. The Board must comprise a minimum of three experienced and competent members, unless the Implementing Regulations specify a larger number, and must meet at least four times per financial year. The General Assembly must meet at least once per financial year. The General Assembly is responsible for adopting financial statements, approving amendments to the bylaws, and approving the dissolution of the Sports Entity. Every amendment to a Sports Entity's bylaws must be recorded in the Registry.

As well as the strict governance regime, the Sports Law also introduces a significant personal liability regime. A member of the Board, and the secretary-general or chief executive officer, shall be personally liable to compensate the Sports Entity for any damage arising from their violation of the provisions of the Sports Law, the Implementing Regulations, or the bylaws of the Sports Entity, or due to any error, negligence, or failure in performing their duties. Members of the Board who are proven to have committed such violations shall be jointly and severally liable to compensate the Sports Entity.

A Board member or senior officer may escape liability if they prove, through the means specified in the bylaws, that they explicitly objected to or reserved their position on the relevant decision or action. Absence from the meeting at which a decision is taken does not automatically exempt a director from liability, unless it is proven that they were unaware of the decision or were unable to object after becoming aware of it. Any members of the General Assembly representing 20% or more of the voting rights may themselves file a liability claim against a board member or senior officer. Filing such a claim requires at least 14 days' prior notice to the Ministry. Except in cases of forgery, fraud, and breach of trust, liability claims are time-barred five years after the relevant individual's departure from office.

For investors appointing nominees to the boards of sports entities, these provisions represent a materially stricter personal liability framework than may be seen in typical corporate contexts. Directors should ensure appropriate governance infrastructure is in place, including documented dissent procedures, formal conflict-of-interest protocols, and directors' and officers' insurance that specifically extends to Sports Entity liability.

Licensing across the sports value chain

The Sports Law creates a licensing requirement that runs across virtually every commercial activity in the sector. Non-compliance is a defined violation subject to fines of up to SAR 5 million and licence cancellation. Existing stakeholders in the sector should carefully consider their current operations and any likely changes to their licensing to ensure compliance.

Sports facilities: A Ministry licence must be obtained before constructing or making amendments to any sports facility. The Implementing Regulations will define the classification of sports facilities and the applicable construction and operational standards. The management and operation of sports facilities also requires a separate Ministry licence. Facilities dedicated to individual or family use are exempt from the Sports Law's provisions. Investors in sports real estate, whether developing stadiums, multi-use arenas, or training complexes, must plan for two separate licensing processes: one for construction or modification, and one for operations. These are distinct licences and must be treated as such in project timetables and development agreements.
Sports events: Private parties may organise a sports event after obtaining a licence from the Ministry. The Ministry may delegate this licensing function to the Committee or a Federation within their respective jurisdictions. Sports events organised by government or non-governmental entities for their own employees, and events specified in the Implementing Regulations, are exempt from the licence requirement. The management and operation of sports competitions and events on a commercial basis requires a separate Ministry licence, even where the organiser is separately licensed. The Ministry also issues instructions governing ticketing for sports competitions and events. Any entity planning to acquire rights to host international sporting events in the Kingdom, such as exhibitions, leagues, boxing, golf or motorsport, must plan for Ministry licensing at both the organisational and operational management levels. This two-licence structure should be built into any rights acquisition or hosting agreement, and licence conditions should be treated as material contract terms.
Sports centres: Sports centres, institutes, and academies may not be established or commence operations without a Ministry licence. The Implementing Regulations will specify licensing conditions and controls. The coaching and technical staff of sports centres, institutes, academies, and schools must be individually licensed by the Ministry. Sports schools or academies additionally require licences from the Ministry of Education and they may not commence operations without obtaining all required licences.
Sports agents: Sports agents may not engage in agency activities without obtaining a licence from the Federation concerned. The Federation determines all provisions related to sports agents, including licensing conditions and the controls on the practice of agency. Investment in talent management or agency businesses requires a federation-by-federation licence analysis. There is no single national sports agent licence and each Federation governs its own discipline independently.

Sports discipline and anti-doping

Disciplinary proceedings over the sports sector have been codified, with Federations being granted wide ranging disciplinary powers over athletes that fall under their scope, and specific powers being granted to the SSAC and SADC:

Authority of Federations: Federations exercise disciplinary powers over their members, their affiliates, and those licensed and registered by them. Federations have the right to conduct investigations and impose disciplinary penalties on those who violate their regulations. The disciplinary penalties available include fines; exclusion or permanent or temporary suspension from competitions; deprivation of entry to sports facilities; cancellation of results or withdrawal of prizes and titles; and cancellation or suspension of licences.
Federations must exercise these powers under published disciplinary regulations that set out defined offences and penalties, fair investigation procedures, the right to present a defence, and access to specialist advisers. Critically, the imposition of disciplinary penalties does not extinguish any civil or criminal liability that may arise from the same underlying conduct.
This dual exposure (disciplinary and criminal or civil) is particularly relevant for Clubs operating as companies. An investor should not assume that a Federation's disciplinary determination closes out all legal exposure from a player or Club misconduct event. Sponsor agreements and investment documentation should address this explicitly.
The Saudi Sports Arbitration Centre (SSAC): The SSAC formally established and registered, acquiring legal personality from the date of its registration. The SSAC oversees arbitration and other alternative dispute resolution procedures for sports-related disputes in which sports entities, their members, licensees, registered individuals, board members, and senior executives are parties, where those parties agree to resolve the dispute within the SSAC's framework.
A particularly important provision concerns deemed arbitration agreements: an arbitration clause contained in the bylaws or regulations of a Sports Entity constitutes a written arbitration agreement binding on the entity, its members, licensees, registered parties, and board members without the need for a separate arbitration agreement in each individual contract. Until a dedicated General Assembly is established for the SSAC, the General Assembly of the Committee will act as the SSAC's governing body and will appoint its board of directors.
Parties entering into commercial arrangements with Sports Entities should review their dispute resolution clauses carefully. The applicable Sports Entity's bylaws may already contain an arbitration clause that binds counterparties by operation of the Sports Law. Where parties wish to preserve the ability to litigate in the Saudi Administrative Courts or refer disputes to international arbitration forums, this must be expressly addressed in the commercial contract.
The Saudi Anti-Doping Committee (SADC): The SADC is an independent non-governmental body with legal personality, responsible for combating prohibited doping in sport across the Kingdom, operating independently in accordance with its bylaws and the international agreements to which the Kingdom is a party. The SADC is empowered to issue anti-doping regulations, collect and analyse biological samples, conduct investigations, and impose penalties on those who violate its anti-doping regulations.
Samples and analysis results may be used only for compliance verification purposes and may not be repurposed for any other use. Sports entities, players, coaches, support staff, and others are obliged to enable the SADC to perform its duties and to cooperate with its programmes. The cooperation obligation is a legal requirement, not merely a matter of sporting ethics. Non-compliance is a regulatory violation carrying enforcement consequences under the Sports Law. Adequate anti-doping compliance infrastructure, for example cooperation protocols and staff training, should be a standard due diligence requirement and a condition of post-acquisition management for any Sports Entity investment.

Enforcement: Penalties, inspections and the Review Committee

The Sports Law sets out a detailed catalogue of violations and creates a committee of the Ministry (the "Review Committee") that is empowered under the Sports Law to oversee disciplinary actions. Violations include operating without a required licence or in breach of licence conditions; providing false or misleading information; establishing a sports facility that does not comply with Ministry standards; damaging sports facilities; and obstructing Ministry inspectors. Failure to comply with Ministry instructions or to provide requested documents are also defined violations, as is any act that otherwise contravenes the provisions of the Sports Law or the Implementing Regulations.

Penalties that may be imposed include: fines not exceeding SAR 5,000,000; licence cancellation; licence suspension for up to three years; disqualification from obtaining a licence for up to four years; suspension from working in sports entities for up to five years; and permanent or temporary closure of a sports facility.

The Review Committee may additionally impose continuing daily fines, require public apologies at the violator's expense, mandate publication of the penalty decision at the violator's expense, require the removal of the violation, and order the restitution of amounts wrongfully obtained, which may include requiring their return to the public treasury. Penalties are doubled on repeat violations, defined as those committed within two years of a prior violation, subject in all cases to the applicable maximum. Aggravating circumstances will increase the applicable penalty.

Ministry inspectors have the status of law enforcement officers and are empowered to conduct unannounced site visits, enter licensed premises and competition venues, review and seize records and documents, and seek assistance from the security services. Officials and employees at inspected locations are legally obliged to facilitate the inspectors' work, cooperate with them, and provide all requested information and documents. The Implementing Regulations are expected to specify procedural safeguards for inspections. In the interim, Sports Entities should establish internal protocols for responding to unannounced inspections, including document retention policies and escalation procedures.

The Ministry may directly impose fines not exceeding SAR 50,000. Violations attracting higher penalties are referred to the Review Committee. The Review Committee issues decisions by majority vote; decisions imposing fines above SAR 350,000 or licence cancellation or deprivation for more than two years require Ministerial approval. The Review Committee must decide within 60 days of receipt (extendable by 30 days). Where parties do not accept the outcome, they may appeal to the competent Administrative Court within 60 days. Investors should ensure all Sports Entities in which they hold interests have documented compliance programmes, that staff are trained on the Sports Law's requirements, and that Ministry requests for information are dealt with promptly and accurately. The potential for mandatory public disclosure of penalty decisions adds a reputational dimension to financial exposure that should not be underestimated.

Implementing Regulations: What remains to be determined

The following matters are expressly reserved for the Implementing Regulations and are not yet determined:

The foreign ownership cap applicable to sports companies;
Minimum capital requirements for sports companies;
Conditions and procedures for Club-to-company conversions;
M&A approval conditions for mergers, acquisitions, and disposals of ownership rights;
Licensing conditions across all categories (facilities, events, academies, sports agents);
Classification of sports facilities and applicable construction and operational standards;
Registry content requirements, registration procedures, and public access rules; and
Licence fees payable to the Ministry.

The Implementing Regulations are expected imminently. Clients should treat the current period as a preparation and engagement window.

What you should do now

For investors with existing sports sector exposure:

map all current contractual relationships against the new Sports Entity categories and identify which counterparties have converted or are likely to convert to company form;
review existing agreements for change of control, assignment, and novation provisions that may be triggered by a Club's conversion;
review licence compliance across your portfolio before the Implementing Regulations are published, to allow time to apply for any new licences or cure deficiencies; and
review board governance arrangements for any Sports Entity in which you hold a board seat in light of the new personal liability regime.

For investors considering new investment:

do not finalise ownership structures for sports companies involving foreign investors until the foreign ownership cap is confirmed;
commence preliminary Ministry engagement for any planned acquisition or establishment of a sports company;
build the two-stage regulatory clearance timeline (Ministerial approval followed by registry filing) into transaction documentation; and
include express Sports Law compliance representations, warranties, and conditions precedent in any acquisition documentation.

For all stakeholders:

monitor the Implementing Regulations closely and be ready to act promptly on publication;
review dispute resolution clauses in all sports-related contracts to assess whether SSAC arbitration has been incorporated by reference through a counterparty's bylaws;
ensure anti-doping cooperation obligations are reflected in investee entity governance documents and employment arrangements; and
engage with the Registry process and verify that all relevant Sports Entities are registered.

_{White & Case means the international legal practice comprising White & Case LLP, a New York State registered limited liability partnership, White & Case LLP, a limited liability partnership incorporated under English law and all other affiliated partnerships, companies and entities.}

_{This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.}