By Dr. John Wendt
The controversial FIFA Club World Cup is coming to the United States and will be held between June 15 and July 13, 2025.[1] In the first ever event thirty-two teams from six confederations will play 63 games in twelve stadia across the United States.[2] Fans will be travelling to the US from across the globe. Two of the Premier League Clubs from the United Kingdom (UK), Manchester City and Chelsea, have qualified for the tournament, but some of their fans will not be making the trip.
In fact, approximately 150 Chelsea and Manchester City fans will be prevented from travelling to the US because they are under Football Banning Orders (FBO) after the UK Home Office enacted new legislation. Any fan under an FBO must surrender their passport to police from July 9 to July 13, 2025 (the control period begins five days before the day of the match and ends when the match finishes or is cancelled) or face an unlimited fine and/or up to six months in prison.[3]
Dame Diana Johnson, UK Minister for Policing and Crime Prevention said, “Many Manchester City and Chelsea fans will want to travel to support their teams in this summer’s tournament and we want them all to do so safely and enjoyably. But for the tiny minority of troublemakers who use football as an excuse for criminality, we will be applying the same proven preventative measures that we have successfully done for other overseas tournaments. We will continue to crack down on the hooligan minority, so that the vast majority can carry on attending football without trouble.”[4]
FBOs were first introduced under the Football Spectators Act of 1989 (FSA 1989) as a tool to combat hooliganism and football related disorders. It was a legal means to manage fan behavior and ensure the safety of players and spectators. They are court orders that restrict an individual’s ability to attend football matches because they have committed an offense related to disorderly conduct, violence, or hate crimes. This includes violence in the stands, invasions of the pitch, discharging flares, alcohol-related offenses or even online hate crimes.
An FBO can be issued in two ways. One, at a hearing after a conviction for a soccer-related offense, as under the Football Spectators Act 1989. Or two, by an application to a court from the police or the Crown Prosecution Service (CPS). The police or CPS can apply to the court to issue an FBO against an individual who has at any time caused or contributed to soccer-related violence or disorder. The Court must be satisfied that there are reasonable grounds to believe that making the FBO would help to prevent violence or disorder at or in connection with any regulated soccer matches.[5]
Under the Football Spectators Act 1989 Act a court must impose an FBO an individual has been convicted of a relevant offense; if the court believes the order will prevent future violence of disorder or the court does not find exceptional circumstances that make the order unjust. Additionally, a police force or the Crown Prosecution Services (CPS) can apply for an FBO even if the individual has not been convicted of a criminal offense if the individual caused or contributed to a soccer related disorder or the order is necessary to prevent future issues.[6] An FBO can prohibit an offender from attending soccer games or surrounding areas for a specific period ranging from three to ten years.
Failure to comply with an FBO can result in an unlimited fine, up to six months in prison, and additional restrictions on attending or travelling to soccer events.[7] In 2025, in an attempt to prevent agitators from causing trouble abroad, new legislation was introduced to prevent individuals with FBOs from travelling to internation tournaments such as the Club World Cup. CPS and police are taking a “robust stance” regarding hooliganism and disorder.[8] During the 2023-2024 season there were 825 new FBOs issued, and with a total of over 2,100 total FBOs currently in place in England and Wales.[9] Some may argue that an offender should just be let off with an ejection from the game and a warning. That is not the approach taken. Cautions are rarely given, and “conditional cautions” are reserved for minor offenses committed by individuals with no previous records of offenses.[10]
CPS used a similar tactic prior to the Euro 2024 Tournament held in Germany. By August 2024, 99% of the individuals subject to a ban surrendered their passports.[11] About 90% gave up their passports with another 8% taken by police after visits to fans’ homes and residences.[12] Passports were returned to their owners after the competition ended.[13] Police Constable Matt Ford led the operation which included stationing additional soccer officers at Manchester Airport. Ford said, “We are committed to playing our part in stopping those intent on causing problems from attending the tournament and providing a secure environment for all fans… Officers will engage with supporters and monitor those travelling whilst continuing a line of communication with colleagues that are stationed in Germany. Any fans found misbehaving could face an FBO upon their return to the UK and may be prosecuted for offences committed whilst in attendance. The initiative highlights our dedication to maintaining public order and ensuring that the European Championships are a positive experience for all legitimate supporters.”[14]
Geoff Pearson, a University of Manchester law professor and an expert on football crowds and policing described FBOs: “They were originally designed to prevent the kind of violence we saw involving hooligan firms, hence the conditions preventing you not only from attending matches but also setting an exclusion zone around the stadium and city centres…In that sense, they are designed to prevent fighting at football games. Where they have been used against people who have been convicted of crimes around football, I think they’ve been quite successful.”[15] While Amanda Jacks, a case worker at the Football Supporters Association, described FBOs somewhat differently: “They are not punishments, they’re civil preventative measures. That’s something a lot of people don’t appreciate. When someone gets an FBO it’s presented that they got it as a punishment. They’re not there as a punishment, they’re there to prevent disorder.”[16]
To give you an example of how serious FBOs are, in May 2025, two Everton soccer fans decided to run onto the Nottingham Forest pitch to celebrate their club’s victory. One gentleman aged 36 said that he’d “had a few beers and the emotion overcame him” while the other aged 60 said he “was excited and wanted to celebrate”.[17] Both argued that they had no malicious intent but rather just wanted to celebrate with their team. The Sentencing Dean recognized that the gentlemen were well respected and hardworking and they both “ran onto the pitch in a moment of overexcitement.” Yet, both were fined, and both received a three-year Banning Order[18] and this was a non-violent situation.
In 2023 a 16-year-old boy ran onto the Anfield pitch to celebrate a goal and crashed into the Liverpool players including Andrew Robertson and Curtis Jones. Robertson went down clutching his ankle. Then Liverpool manager Jurgen Klopp was fuming and could be seen yelling at the invader. The young man was escorted from the pitch and stadium and arrested by Merseyside Police. The Liverpool Club said, “There is no excuse for this unacceptable and dangerous behaviour. The safety and security of players, colleagues and supporters is paramount…The club will now follow its formal sanctions process and has suspended the alleged offender’s account until the process is complete. If found guilty of the offence of entering the pitch without permission, the offender could face a criminal record and a lifetime ban from Anfield and all Premier League stadiums. These acts are dangerous, illegal and have severe consequences.”[19] Could you imagine being 16 years old and never attending a game for the rest of your life?
Or in a more egregious situation, a thirty-five-year-old Tottenham supporter ran down stadium steps, over two barriers, onto the pitch and kicked Arsenal goalkeeper Aaron Ramsdale in the back before running back into the stands. The gentleman, who had consumed six pints before the game and admitted being drunk also admitted to dangerously throwing coins onto the pitch. He was banned for four years, handed a 12-month community order, required to pay £100 to Ramsdale and required to carry out 150 hours of unpaid work.[20]
More recently, four young men from Mansfield, UK received three-year banning orders on May 4, 2025, after each pleaded guilty to “using threatening / abusive / insulting words / behaviour with intent to cause fear of / provoke unlawful violence” in an altercation with fans from Rotherham United on December 21, 2024.[21] As reported by the Nottingham Police, Mansfield Sergeant Cat Darby described the incident as, “This was disgraceful behaviour carried out in full view of Christmas shoppers. Rather than celebrating their team’s 1-0 victory and returning home with a spring in their step, these young men decided to seek out a wholly unnecessary and avoidable confrontation with rival fans. In doing so they not only brought shame on themselves, they also damaged the reputation of our town and the club that many of us are proud to support.”[22] Additionally Nottinghamshire Police Constable John Albanese said, “Incidents like this give football clubs – and football supporters in general – a bad reputation, and will never be tolerated. Whether they happen inside or outside of the stadiums, supporters should know that incidents of this nature will be thoroughly investigated and will likely end up with a visit from a police officer. Further still they can also expect to be banned from football matches for a long time.”[23] Soccer is a beautiful game. Most of the fans are loyal, energetic and even emotional. They appreciate the beauty of the game. But soccer players, managers, staff and fans also have a fundamental right to be safe. In these times someone running onto a field or pitch may mean well, or it could also be dangerous. Fans that are in the US and travelling to the US for the 2025 Club World Cup should have a good time and not be interrupted, accosted or placed in danger because of a few overzealous fans or hooligans – they have no place in the game.
[1] Kyle Bonn, Why Is the New FIFA Club World Cup Controversial? Opposition to Expanded Tournament Explained, (2024), https://www.sportingnews.com/us/soccer/news/why-fifa-club-world-cup-controversial-opposition-expanded/a0416439ca7267c73b5fa194 (last visited Apr 28, 2025).
[2] FIFA, FIFA Club World Cup 2025TM, (2025), https://www.fifa.com/en/tournaments/mens/club-world-cup/usa-2025 (last visited Apr 28, 2025).
[3] Anahita Hossein-Pour, Violent Chelsea and Manchester City Fans to Be Banned from Travelling to Club World Cup, (2025), https://www.independent.co.uk/sport/football/chelsea-city-fans-banned-club-world-cup-b2726111.html (last visited Apr 27, 2025). It can be noted that both Manchester City and Chelsea were two of the top five Premier League clubs with the highest numbers of supporters arrested in the 2023 – 2024 soccer season: https://www.gov.uk/government/statistics/football-related-arrests-and-banning-orders-2023-to-2024-season/football-related-arrests-and-banning-orders-england-and-wales-2023-to-2024-season
[4] Id.
[5] GOV.UK, User Guide to Football-Related Arrests and Banning Orders Statistics, England and Wales, GOV.UK (2025), https://www.gov.uk/government/publications/user-guide-to-football-related-arrests-and-banning-order-statistics/user-guide-to-football-related-arrests-and-banning-orders-statistics-england-and-wales (last visited May 3, 2025).
[6] Rhys Rosser, Football Banning Orders – A Guide, (2025), https://www.londoncriminalbarrister.co.uk/football-banning-orders-a-guide (last visited Apr 30, 2025).
[7] Id.
[8] The Crown Prosecution Service, Football Related Offences and Football Banning Orders, (2022), https://www.cps.gov.uk/legal-guidance/football-related-offences-and-football-banning-orders (last visited Apr 27, 2025). The relevant tests and procedures for FBOs can be found at “Football Related Offences and Football Banning Orders” can also be found at this site.
[9] GOV.UK, Football-Related Arrests and Banning Orders, England and Wales: 2023 to 2024 Season, (2025), https://www.gov.uk/government/statistics/football-related-arrests-and-banning-orders-2023-to-2024-season/football-related-arrests-and-banning-orders-england-and-wales-2023-to-2024-season (last visited May 2, 2025).
[10] The Crown Prosecution Service, supra note 8.
[11] Hossein-Pour, supra note 3. See also Nancy Froston, Chelsea, Manchester City Fans with Banning Orders Stopped from Travelling to Club World Cup, The New York Times, Apr. 4, 2025, https://www.nytimes.com/athletic/6249295/2025/04/02/chelsea-manchester-city-fans-club-world-cup/ (last visited Apr 27, 2025).
[12] BBC, Greater Manchester: Crackdown on Banned Fans Heading to Euro 2024, (2024), https://www.bbc.com/news/articles/c999e1kdr41o (last visited Apr 27, 2025).
[13] Clare Lissaman, Euro 2024: More than 100 Banned Fans Told to Hand in Passports, (2024), https://www.bbc.com/news/articles/cgrrzlm37rpo (last visited Apr 27, 2025).
[14] Greater Manchester Police, GMP Kick off Euro 2024 with Dedicated Football Policing Operation at Manchester Airport, (2024), https://www.gmp.police.uk/news/greater-manchester/news/news/2024/june/gmp-kick-off-euro-2024-with-dedicated-football-policing-operation-at-manchester-airport/ (last visited Apr 27, 2025).
[15] Philip Buckingham, Football Banning Orders on the Rise: Draconian or Justified?, The New York Times, Jul. 25, 2022, https://www.nytimes.com/athletic/3297380/2022/05/08/football-banning-orders-on-the-rise-draconian-or-justified/ (last visited Apr 27, 2025).
[16] Id. As this is considered a civil application, the standard of proof is the civil standard i.e. the balance of probabilities.
[17] Martin Naylor, Bans for Football Fans Who Ran onto Pitch to Celebrate Winner, Nottinghamshire Live (2025), https://www.nottinghampost.com/news/nottingham-news/bans-everton-football-fans-who-10149223 (last visited May 5, 2025).
[18] Id.
[19] Reuters, Liverpool to Ban Pitch Invader Who Nearly Injured Robertson, Reuters, Mar. 6, 2023, https://www.reuters.com/lifestyle/sports/liverpool-ban-pitch-invader-who-nearly-injured-robertson-2023-03-06/ (last visited May 8, 2025).
[20] The Guardian, Man Who Kicked Arsenal’s Aaron Ramsdale Ordered to Pay Compensation, The Guardian, Feb. 17, 2023, https://www.theguardian.com/uk-news/2023/feb/17/man-admits-assaulting-arsenal-aaron-ramsdale-tottenham-match-joseph-watts (last visited May 8, 2025).
[21] Nottingham Police, Football Banning Orders after Mansfield Disorder, (2025), https://www.nottinghamshire.police.uk/news/nottinghamshire/news/news/2025/may/football-banning-orders-after-mansfield-disorder/ (last visited May 8, 2025).
[22] Id.
[23] Id.
