FAF & USM Alger v. CAF, RS Berkane & FRMF (the “Berkane Jersey” Case)

This case arose from real, consequential events in the 2023/24 CAF Confederation Cup semi-final between USM Alger and Moroccan club RS Berkane, not merely an abstract review of a jersey design. When RS Berkane arrived for the first leg wearing a jersey depicting a map of Morocco that included the Western Sahara territory — a depiction that did not match the United Nations' official map of Morocco — Algerian authorities seized the jerseys on arrival. USM Alger refused to take the pitch for either leg of the tie in protest, and the semi-final was awarded to RS Berkane by forfeit rather than decided on the pitch. RS Berkane went on to reach the final, where it lost to Zamalek.

The Algerian Football Federation (FAF) first raised the map issue with CAF's own Secretariat on 14 April 2024. When the CAF Appeal Jury upheld the original approval of the jersey later that same month, FAF and USM Alger filed an appeal with CAS on 23 April 2024. The case did not reach a hearing for nearly seven months, finally heard remotely on 13 November 2024, with the Confederation of African Football, the Royal Moroccan Football Federation, and RS Berkane all participating; the parties did not dispute that the map on the jerseys diverged from the UN-recognised map of Morocco. The award itself was not issued until over three months later, on 26 February 2025 — close to a year after the original appeal was filed.

CAS first resolved a standing question: it held FAF's appeal admissible, since FAF had exhausted its internal remedies before escalating, but found USM Alger's own appeal inadmissible because the club had not done the same. On the substance, CAS annulled CAF's approval of the jersey, holding in its own words that the design "represent[ed] a territorial map containing a politically sensitive image" in violation of Article 1.03 of CAF's equipment regulations, Law 4 of the Laws of the Game, and Article 2 of CAF's own statutes, which require political neutrality.

Notably, CAS did not disturb the actual results of the 2023/24 Confederation Cup, including the forfeited semi-final itself — RS Berkane's run to the final, and its result there, stood undisturbed regardless of the ruling on the jersey. The case stands as a real, decided authority on the limits of what a competing federation can put on a match jersey in CAF competition, decided against the backdrop of Morocco's own efforts to have its territorial map more widely recognised ahead of co-hosting the 2030 World Cup with Spain and Portugal — a political context reported alongside the ruling, though separate from and narrower than the underlying territorial dispute itself, which CAS did not purport to resolve.