As the 2026 FIFA World Cup unfolds under what is widely regarded as the most rigorous anti-doping operation in the history of football — with FIFA coordinating three national anti-doping agencies (USADA, Sport Integrity Canada and MEX-NADO) within a single tournament — the international regulatory framework already has its next reform in place. The 2027 World Anti-Doping Code, finalised by WADA following a two-year stakeholder consultation process, will enter into force on 1 January 2027, introducing a number of significant amendments.
– The end of the single-tier sanction
The current sanctioning regime is, to a large extent, premised on a binary rationale: either the athlete succeeds in establishing the absence of intent and receives a two-year period of ineligibility, or fails to do so and faces a four-year ban. The 2027 Code departs from this rigidity by instituting a graduated sanctioning framework comprising three tiers — four, three or two years — determined by reference to the athlete’s degree of intent and the establishment of the route of ingestion of the prohibited substance into their system. Access to the most favourable tier is, however, considerably restricted.
On a separate front, the new Code expressly recognises that the recreational use of substances such as cocaine or ecstasy is, first and foremost, a public health matter. A first-time out-of-competition violation now carries a fixed period of ineligibility of only two months; in the event of a second violation, the sanction is set at four months, subject to reduction to two months upon enrolment in an approved therapeutic programme — a clear policy choice in favour of rehabilitation over purely punitive measures.
– Contamination: a definition fit for purpose
One of the most notable shortcomings of the current regime lies in its restrictive treatment of cases involving inadvertent contamination. The available mitigation was confined to contamination through supplements or products, failing to encompass increasingly prevalent scenarios in practice: consumption of traditional teas, exposure in shared sporting facilities, or accidental contact.
The 2027 Code replaces the concept of “Contaminated Product” with that of “Contaminated Source”, thereby covering the full range of these scenarios and affording disciplinary bodies greater latitude in determining the applicable sanction.
The case of Bolivia in the 2026 World Cup qualifying campaign is particularly instructive: players returned adverse analytical findings following the use of medication prescribed by the team physician to mitigate the effects of altitude, with a potential deduction of up to seven points having been at stake.
– Strengthened governance and athletes’ rights
The Code also seeks to address criticisms regarding the lack of transparency in results management. It is now mandatory for an independent expert opinion (from an Independent Review Expert) to be obtained whenever an anti-doping organisation considers not pursuing a case following an adverse finding, thereby preventing unilateral decisions to close proceedings. Appeal deadlines are harmonised at a single period of 21 days, and athletes under the age of 18 are afforded protection against the public disclosure of sanctions, in recognition of their particular vulnerability.
– The impact on Portugal
In Portugal, the legal framework governing the fight against doping is set out in Law No. 81/2021 of 30 November (as amended by Decree-Law No. 35/2022 of 20 May), which transposed the rules of the 2021 Code into the domestic legal order.
The entry into force of the 2027 Code will require a careful assessment of the need to adapt the national regulatory framework, particularly with regard to the sanctioning regime and the rules on data protection and the protection of minors. The Portuguese Anti-Doping Authority (ADoP) will naturally play a decisive role in this process.
By Ricardo Cardoso and Sara Rios Vieira, Practice Area – Sports, Fashion and Entertainment
