On 20 May 2026, the Brussels Court of Appeal – Markets Court Section (court) dismissed the Union Cycliste Internationale’s (UCI) appeal against the interim measures decision adopted by the Belgian Competition Authority (BCA) in October 2025. The court upheld the BCA’s decision in full and found that it did not commit any manifest error of assessment in concluding that the Maximum Gear Ratio Test Protocol (Protocol) constituted prima facie a restriction of competition law. The court therefore considered that its suspension was justified, and must remain in force, to prevent serious, imminent, and irreparable harm to SRAM and the professional cycling teams using its equipment. 

Norton Rose Fulbright had the privilege of representing SRAM in these proceedings and supporting it throughout this matter.

At the crossroads of sport and competition law

The case originated in what initially appeared to be a narrow technical dispute. Following discussions within SafeR – a body dependent on the UCI that brings together riders, teams and race organisers (excluding manufacturers) to develop safety recommendations – and an unconclusive rider survey, the UCI adopted the Protocol in June 2025. The Protocol limited the maximum gear development to 10.46 meters per pedal revolution – equivalent to a 54-tooth chainring paired with an 11-tooth cog (54×11) in the races where it applied.

This limit de facto excluded SRAM, as its RED AXS drivetrains use a 10-tooth smallest cog. Complying with the Protocol required SRAM-equipped teams to mechanically and electronically block the 10-tooth cog and effectively race with a degraded 11-speed configuration, whereas the other teams could continue competing with their full, unmodified systems. SRAM maintained that the Protocol introduced a discrimination, entailing immediate serious commercial and reputational harm.

After a series of unsuccessful attempts to engage constructively with the UCI and to address the concerns raised by the Protocol, SRAM was left with no alternative but to file a complaint before the BCA to prevent the ongoing harm. On 9 October 2025, the BCA’s College ordered the immediate suspension of the Protocol – a decision subsequently challenged by the UCI but ultimately upheld by the court.

Grounded in core principles of competition law, the ruling extends well beyond this specific dispute. In dismissing the UCI’s appeal, the court makes a compelling application of Superleague – the seminal European Court of Justice’s (ECJ) judgment setting the framework within which sports federations’ rule-making powers are to be exercised – and brings groundbreaking clarifications. 

A firm stand on sports governance requiring substantive criteria and robust procedural safeguards

The court rejected all of UCI’s grounds of appeal as unfounded. From a procedural standpoint, it unequivocally confirmed the BCA’s territorial jurisdiction, holding that the effects of the Protocol were clearly and sufficiently felt in Belgium through Belgian-based teams, riders, distributors, and race organisers. 

Three substantive findings stand out, as they give the ruling its reach beyond the gear ratio issue – and well beyond cycling itself.

First, the court confirmed that the BCA was right to apply the Superleague and ISU judgments. Under that line of case law, a sports federation adopting rules binding on athletes, teams, and equipment manufacturers must do so within a framework based on substantive criteria and procedural safeguards designed to ensure that those rules are transparent, objective, precise, non-discriminatory, and proportionate. In the absence of such framework, the rules are, by their very nature, harmful to competition. As a result, they are characterised as restrictions by object within the meaning of Article 101(1) TFEU, without any need to examine their actual or potential effects. 

Applying these principles, the court identified serious deficiencies at each stage of the rule-making process, and emphasised that the UCI’s regulatory power must be embedded in a structured framework. In doing so, it made clear that procedural safeguards cannot be deferred or treated as an afterthought, noting in particular that: 

“the fact that equipment manufacturers will be consulted at a later stage is irrelevant, since it is the adoption of the standard that must be governed “by substantive criteria and procedural rules designed to ensure [its] transparency, objectivity, precision, and non-discrimination.”” (para. 35)

Second, the court rejected the UCI’s argument that, acting purely as a sports regulator not active on the relevant markets, it should fall outside the scope of competition law. Relying on the Alphabet and FIFA line of cases, it held that the federation’s regulatory powers remain subject to competition law where their exercise has an impact on the economic activities of market players. 

In that context, the court expressly clarified that the Superleague legal standard applies irrespective of the existence of a conflict of interest, holding that: 

“Consequently, the fact that the UCI is not in a situation of potential conflict of interest when it regulates cycling – unlike the case that gave rise to the Superleague judgment – and that the rules it establishes do not confer an advantage upon it relative to actual or potential competitors, do not have the effect of exempting the UCI from competition law.” (para. 31)

Third, the court clarified the limits of the safety defence. While the UCI argued that the Protocol pursued the legitimate objective of rider safety and that any restriction of competition law was therefore inherent and proportionate, the Court rejected this line of reasoning. It confirmed the BCA’s finding that, even assuming the legitimacy of the objective, the UCI had failed to demonstrate why it could not be pursued through an open, transparent, objective and non-discriminatory process. The underlying principle is simple: a sports federation acting on safety must do so through proper procedure, not use it to bypass it. 

The court found that: 

“[…] data already exists on the frequency and severity of accidents in an environment where the two transmission systems coexist […] the teams are not opposed to sharing their data […] the use of a limited SRAM system could potentially lead to more accidents and thus skew the test results. The UCI maintains that the Test Protocol aims to “obtain subjective feedback from riders and other stakeholders regarding their perceptions of the gear ratio limitation.” However, it does not explain why such subjective feedback would be necessary to achieve the objective of improving rider safety, nor, more importantly, why it could not have achieved this objective by following a transparent, objective, and non-discriminatory adoption process. […] other measures, potentially causing less distortion, could have been considered […].” (para. 42)

Far beyond the peloton: a decision clarifying the landscape of sports regulation

The temptation, for those watching from outside the cycling industry, is to view this case as a niche dispute concerning a specific piece of equipment in a specific sport. That reading would be misplaced – and the court itself rejected it. What started as a technical issue relating to bike transmissions ultimately results in the articulation of a procedural standard applicable to sports federations across all disciplines.

The BCA's October ruling marks what appears to be the first application of the ECJ's Superleague legal standard to a sports federation that does not itself compete in the regulated market. Until now, the leading European cases on federation rule-making – Meca-Medina, ISU, Superleague – involved federations with a commercial role in the markets they regulated. Relying on Superleague, the BCA extended that framework to a sports governing body without any conflict of interests – an approach now endorsed by the court.

The implications extend well beyond this case. Most international federations act primarily as regulators without necessarily having a direct commercial interest in the markets they oversee. Following the court’s ruling, any such federation operating in or affecting the European market is subject to a clear procedural standard for the rules they adopt. This decision is therefore likely to resonate well beyond cycling and for other national courts and competition authorities across the EU.

Key takeaways 

• Excluding stakeholders whose economic activities are impacted by the outcome of the federation’s rule-making is inherently discriminatory and should, in itself, warrant antitrust intervention.
• A legitimate safety objective does not excuse a flawed process. Sports federations bear the burden of demonstrating that their rules are adopted in accordance with a procedural and substantive framework that is open, transparent, objective and non-discriminatory.
• Any “sporting exception” is narrowly circumscribed and applies only to rules that are purely sporting in nature.
• Any technical standard – even labelled as a “test” – backed by sanctions is to be treated as a binding norm capable of producing permanent effects.
• The Superleague/ISU framework applies to sports federations regardless of market participation – the key trigger is the impact on economic activity of market players.

Conclusion

Nothing in the court’s ruling calls into question the regulatory authority of sports federations. Rather, it provides clear and constructive guidance on how that role must be exercised. Rule-making in sport must operate within a framework that is open, transparent, objective and non-discriminatory. This is no longer aspirational; it is the legal standard. 

The court also firmly endorsed the use of interim measures. It confirmed that the Protocol caused serious, immediate and irreparable harm, in particular to SRAM’s reputation, thereby fully justifying the BCA’s legitimate intervention under an urgent procedure to bring that harm to an end.

The message of the ruling is clear. For the UCI, it calls for a reassessment of how technical standards are conceived and adopted. More broadly, it sets a benchmark for all international sports federations operating in or affecting the European market. It lays the foundation for a more disciplined model of sports governance – one in which regulatory authority is exercised within clear procedural boundaries, to the benefit of all stakeholders and the integrity of sport as a whole.