Alkarama has filed an urgent appeal to the UN Working Group on Business and Human Rights and other special procedures, calling for immediate action regarding FIFA’s bidding process for the 2034 World Cup in Saudi Arabia. The appeal highlights serious concerns over FIFA’s expedited 27-day timeline, the lack of independent and comprehensive human rights due diligence, and the lack of independance of the required human rights risks assessment that Saudi Arabia commissioned to AS&H Clifford Chance. These actions collectively point to a severe non-compliance with the UN Guiding Principles on Business and Human Rights (UNGPs), and a disregard for FIFA’s own Human Rights Policy.
Alkarama also issued a report built on the complaint sent to the Special Procedure detailing the claims made to the mandate holders based on its work documenting severe and systematic violations in Saudi Arabia over the past 20 years, considering FIFA's obligations under the UNGPs and other international instruments.
Background: Accelerated Bidding Process Raises Transparency and Due Diligence Concerns
On 4 October 2023, FIFA unexpectedly announced a concurrent bidding process for the 2030 and 2034 World Cups, imposing a 27-day deadline for nations interested in hosting the 2034 tournament. Saudi Arabia’s rapid announcement of its bid, made mere minutes after FIFA’s call, immediately raised questions about potential pre-coordination.
By the October 31 deadline, Saudi Arabia remained the sole candidate after the withdrawal of both Indonesia and Australia, effectively leaving the bidding process uncompetitive and circumventing FIFA’s commitment to transparent and fair selection procedures. This expedited timeline severely limited FIFA’s ability to conduct robust human rights due diligence, as expected under its Human Rights policy and commitment to the UNGPs.
Saudi Arabia’s bid, spanning five cities and entailing extensive construction projects, neglects documented human rights concerns. The inclusion of Neom as a primary venue heightens these risks, given the city’s association with forced evictions and executions. Migrant workers essential to World Cup projects face exploitation, while the crucial independent voices of journalists and human rights defenders are systematically silenced by cybercrime and counter-terrorism laws that stifle peaceful criticism and dissent.
Human Rights Context in Saudi Arabia: Severe Risks for a Mega Sporting Event
In its urgent appeal, Alkarama based its claims on cases it documented in Saudi Arabia to the UN Human Rights mechanisms that highlight the authoritarian and repressive nature of the authorities’ policies in key domains, raising grave concerns over its capacity to host a World Cup that respects basic human rights principles.
Alkarama highlighted the systematic criminalisation of political dissent and other peaceful activism through draconian laws and penalties targetting human rights defenders, journalists, scholars and other peaceful critics.
While arbitrary detention as a means of suppressing dissent is so systematic that the Working Group on Arbitrary Detention has raised concerns that it amounts to a crime against humanity, torture and ill-treatment in detention have caused permanent disability and death among political prisoners.
As Saudi Arabia's bid promises the construction of 11 new venues in record time, significant concerns should have been raised about the lack of protection for workers' rights, including freedom of speech and the ability of workers to associate and organise to denounce potential abuses. In addition to the crackdown on any form of criticism, including on social media, Alkarama highlighted the extreme vulnerability of migrant workers to abuse, wage theft and forced labour.
Finally, Alkarama highlighted the contradictions of Saudi Arabia's claims of inclusiveness and respect for the rights of minorities and other protected groups, given its appalling record of systematic discrimination and institutionalised prejudice against these groups. Such human rights violations pose a significant challenge to Saudi Arabia's ability to host an international event in line with FIFA's Human Rights Policy and global human rights standards.
UN Guiding Principles Violations by FIFA and AS&H Clifford Chance
Alkarama argued that both FIFA and AS&H Clifford Chance, as companies closely involved in the potential awarding of the 2034 World Cup to Saudi Arabia, violated several key provisions of the UNGPs by failing to comply with essential human rights due diligence, stakeholder engagement and transparency requirements in the evaluation of the Saudi bid.
The violations of the United Nations Guiding Principles on Business and Human Rights (UNGPs) by FIFA in its decision to support Saudi Arabia's bid are significant, particularly with regard to Principle 13, which deals with the responsibility to respect human rights. Principle 13(a) requires organisations to avoid causing or contributing to human rights abuses. However, FIFA's decision to proceed with Saudi Arabia's bid without obtaining binding human rights commitments or conducting a thorough assessment directly contributes to increased human rights risks. In addition, Principle 13(b) requires organisations to prevent or mitigate adverse human rights impacts directly related to their activities. FIFA's lack of proactive measures or binding human rights assurances underscores its failure to effectively mitigate such risks.
Furthermore, FIFA's accelerated timeline compromised its ability to conduct a comprehensive due diligence process as required by Principle 17. This principle requires organisations to identify, prevent, mitigate and address human rights impacts. In FIFA's case, its reliance on a limited assessment conducted by AS&H Clifford Chance, which relied heavily on Saudi government sources - thus excluding independent stakeholders - meant that critical human rights issues raised by UN human rights mechanisms, in particular violations of the right to life, liberty and security, were not included in the assessment. Conducted in just six weeks, the assessment was so strictly limited in scope by the Saudi authorities themselves that it failed to meet UNGP standards.
Moreover, FIFA and AS&H Clifford Chance's failure to engage with independent civil society groups, migrant worker advocates or other communities directly affected by human rights issues in Saudi Arabia is in direct contravention of Principle 18, which requires the identification and assessment of human rights impacts.
FIFA's decision to withhold comprehensive information on the human rights considerations associated with the Saudi bid, and the limited nature of Clifford Chance's assessment, further undermine accountability. Such behaviour also directly contravenes the transparency requirements set out in Principle 21, which requires open communication on human rights impacts.
In addition, Principle 23, which requires context-specific due diligence in high-risk environments, has not been followed. The high-risk environment in Saudi Arabia, characterised by restrictive laws, inadequate legal protection and documented human rights violations, required a higher level of due diligence.
Finally, FIFA's actions contradict Principle 24, which emphasises the need to prioritise measures to address serious human rights impacts. FIFA's decision to proceed with the bid without establishing strong human rights benchmarks or enforcement mechanisms demonstrates a preference for expediency over the protection of vulnerable populations. The limited scope of AS&H Clifford Chance's assessment failed to provide sufficient safeguards for affected groups, reflecting a disregard for Principle 24's prioritisation of urgent human rights issues.
Conclusion and Accountability of FIFA and AS&H Clifford Chance
FIFA and AS&H Clifford Chance are jointly responsible for failing to uphold human rights standards in the bidding process for the 2034 World Cup. FIFA's unreasonably short timeframe, lack of independent assessment and exclusion of civil society indicate a serious disregard for human rights. AS&H Clifford Chance's limited assessment, conducted under government-imposed restrictions and without stakeholder engagement, further undermines the credibility of this due diligence process.
"FIFA's decision to move forward with the World Cup bid without adequate due diligence or meaningful stakeholder consultation jeopardises basic human rights protections and is a textbook case of corporate complicity in authoritarian sport washing," said Rachid Mesli, Director of Alkarama. "We urge the UN experts to intervene immediately to hold FIFA and AS&H Clifford Chance accountable and prevent potential complicity in further rights abuses."
In lighht of this, Alkarama called upon the UN Working Group on Business and Human Rights and other concerned special procedures to do the following regarding FIFA and AS&H Clifford Chance:
● Requests to FIFA:
Alkarama called on UN experts to recommended that FIFA take immediate actions to ensure the integrity of its bidding process, specifically by suspending the current bidding process, including the vote scheduled for December 2024. FIFA should reopen the bidding process with a revised timeline that allows sufficient time for comprehensive human rights assessments and meaningful consultation with all relevant stakeholders. Furthermore, FIFA should conduct an independent human rights assessment, free from any government influence, to guarantee impartiality. Moving forward, FIFA should be urged to establish measurable and enforceable human rights standards for all future host countries and to secure binding commitments from Saudi Arabia to address identified human rights risks.
● Requests to AS&H Clifford Chance:
Alkarama called upon the UN Working Group on Business and Human Rights and other experts to advise AS&H Clifford Chance to fully adhere to the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the UN Basic Principles on the Role of Lawyers. This adherence includes revising their current assessment to ensure a comprehensive and independent human rights analysis, one that is free from partiality and government influence. Additionally, AS&H Clifford Chance should actively engage with independent civil society organizations and affected communities, enhancing the transparency and credibility of their findings through a broad consultation with relevant stakeholders.