Suspending a Suspension: FIFA's Disciplinary Committee Suspends Implementation of Folarin Balogun's Red Card

Introduction

After spending several days considering how the United States’ Men’s National Team would adapt to missing their top scorer following a controversial red card, the footballing world learned that Folarin Balogun's one-match suspension had been suspended by FIFA’s Disciplinary Committee, and that he would be eligible to play in the Round of 16 match against Belgium on July 6.[1]

The decision has quickly become one of the most discussed disciplinary rulings of the 2026 FIFA World Cup, generating debate regarding FIFA's disciplinary framework, the scope of its discretion under the FIFA Disciplinary Code (“FDC”), and the administration of disciplinary decisions in high-profile international competitions.[2]

The Incident

In the United States' Round of 32 match against Bosnia and Herzegovina on July 1, 2026, Balogun scored late in the first half to give the United States a 1-0 lead. Early in the second half, Balogun challenged for a loose ball with Bosnian defender Tarik Muharemović and stepped on the inside of his ankle. While play was initially allowed to continue, following a Video Assistant Referee (“VAR”) system review, Balogun was shown a straight red card and sent off.[3]

The decision was immediately the subject of controversy, with some believing that the red card (and the summary one-match suspension which would follow) was overly harsh for the incident in question. Others felt it was an appropriate sanction, which had not been applied equally to others who had made similar tackles. Nevertheless, several supporters, pundits and public officials requested that FIFA review the incident.[4]

On July 2, FIFA reportedly confirmed that there was no appeal mechanism available to challenge the red card. One day later, FIFA's disciplinary bodies reportedly maintained that the automatic one-match suspension would apply.[5]

However, on July 5, 2026, nearly four days after the red card was issued and less than two days before the United States' Round of 16 match against Belgium, FIFA’s Disciplinary Committee announced that the implementation of Balogun's one-match suspension would be suspended for a period of one year, during which Balogun will be subject to a probationary period. FIFA stated that if Balogun commits another infringement of a similar nature and gravity during the probationary period, the suspended sanction may be reinstated in addition to any disciplinary measures imposed for the new offence.[6]

As a result, Balogun is, at the time of writing, eligible to play against Belgium.

Suspending the Suspension, Not Rescinding It

FIFA’s Disciplinary Committee has not yet released written reasons or an explanation for the decision, but provided the following update[7]:

By operation of Article 27 FDC, the implementation of the automatic match suspension for USA player Folarin Balogun is suspended for a probationary period of one (1) year.

What is notable in this instance is that FIFA’s Disciplinary Committee has not rescinded the suspension, or deemed the red card to have been improper. Rather, the suspension remains, but is not being enforced at this time. This is consistent with Article 9 of the FDC, which provides that decisions taken by the referee are final and may not be reviewed by FIFA judicial bodies, outside of an “obvious error,” such as mistaken identity.  

Instead, FIFA’s Disciplinary Committee relied on Article 27 of the FDC,[8] which provides that a judicial body may fully or partially suspend the implementation of a disciplinary measure and place the sanctioned individual on a probationary period. Here, the referee’s decision has not been overturned, but rather the consequences of that decision have been suspended.

FIFA's Historical Use of Article 27

FIFA has previously relied on Article 27 to suspend the implementation of disciplinary sanctions, including in the lead up to the 2026 FIFA World Cup. In World Cup qualifying, Portuguese superstar Cristiano Ronaldo received a three-match suspension following a red card against Ireland. After serving one match of the three, FIFA’s Disciplinary Committee suspended the implementation of the remaining two matches, allowing Ronaldo to participate in Portugal’s opening two World Cup fixtures. Similarly, Ecuador midfielder Moisés Caicedo and Argentina defender Nicolás Otamendi each benefited from suspended sanctions following red cards received during qualifying competitions, allowing them to remain eligible for subsequent World Cup matches.[9]

An even earlier example occurred during the 1962 FIFA World Cup, when Brazilian forward Garrincha was sent off in the semifinal against Chile, but was ultimately permitted to play in the final. At the time, however, FIFA did not employ the modern system of automatic suspensions following red cards, and disciplinary matters were determined by FIFA's disciplinary committee on a case-by-case basis.[10]

Global Response

The decision by FIFA’s Disciplinary Committee has attracted several responses from stakeholders, including notably the Royal Belgian Football Association (the “RBFA”) and the Union of European Football Associations (“UEFA”).

In a statement released immediately following the decision, the RBFA announced that it was “astonished” by the decision, pointing to Article 66.4 of the FDC, which provides for an automatic one-match suspension, and to Article 10.5 of the FIFA World Cup 2026 Competition Regulations, which similarly provides that an automatic suspension will be imposed for the team’s subsequent match when a red card is issued.[11]

The RBFA provided an update on July 6, 2026, explaining that it has sought clarity from FIFA, including requesting an explanation of the decision, and that FIFA has now deemed the RBFA’s request to be an appeal. The RBFA has taken issue with this deemed appeal, as it contends that FIFA’s own appeal procedures require a reasoned decision, which has yet to be provided.[12]

UEFA similarly released a statement on July 6, 2026, expressing its “disbelief.” UEFA provided its view that the one-match suspension is not discretionary nor subject to exception, particularly in the midst of a tournament. UEFA further raised concerns about the integrity of the game, consistency in disciplinary decision-making, how similar situations have been treated so far in the 2026 World Cup and how they will be treated going forward.[13]

Takeaways

Much of the discussion surrounding the Balogun decision has focused not on the ultimate outcome, but on the process used to reach it. This has generated broader discussion about transparency, consistency and predictability in sports disciplinary systems, as highlighted by UEFA.

By the time the suspension was lifted, Belgium had spent several days preparing for a match in which Balogun was expected not to play. Pundits, former players, coaches and participating federations questioned whether the determination could have been made earlier, particularly given its potential impact on match preparation.[14]

Finally, whether FIFA’s Disciplinary Committee’s decision is viewed as a justified correction of an overly harsh red card, or as an unusual exercise of disciplinary discretion, the Balogun ruling has become a notable example of the challenges associated with administering discipline in major international sporting competitions.

It is also demonstrative of the increase in after-the-fact challenges impacting the game, including both off- and on-field decisions. This includes the recent 2025 Africa Cup of Nations, which was initially won on the field by Senegal, who were ultimately determined to have forfeited the match and the recent EFL Championship Playoffs, where Southampton FC were ultimately expelled as a result of unauthorized surveillance.

Ultimately, it remains to be seen whether any further challenge to the decision will impact Balogun’s eligibility for the Round of 16 match, although all indications currently point to him playing. How FIFA and the FIFA Disciplinary Committee will handle future controversial red cards, both in the 2026 World Cup and beyond, also remains to be seen.

The Sports & Entertainment Group at Aird & Berlis LLP will continue to monitor developments arising from the Balogun decision and other significant issues impacting the world of football. For any inquiries, please contact the authors or a member of the group.