Kraków, 10 October 2026

Mr Fredy Fürst
Head of the PZPN Licensing Department
Polish Football Association
7 Bitwy Warszawskiej 1920 r. Street
02-366 Warsaw

for information:

1. Mr Tomasz Jóźwik
   Chairman of the PZPN Club Licensing Committee
   Polish Football Association
   7 Bitwy Warszawskiej 1920 r. Street
   02-366 Warsaw
2. Mr Łukasz Wachowski
   PZPN General Secretary
   Polish Football Association
   7 Bitwy Warszawskiej 1920 r. Street
   02-366 Warsaw

Re: decision of the PZPN Club Licensing Committee concerning Legia Warszawa S.A., announced in the communication of 9 October 2026 – request to consider lodging an appeal on behalf of the Licensor (point 5.1.30(c) of the Licensing Manual)

Dear Mr Head,

acting on behalf of Towarzystwo Sportowe Wisła Kraków S.A., with its registered office in Kraków, entered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for Kraków – Śródmieście in Kraków, 11th Commercial Division of the National Court Register, under KRS number: 0000130748 (hereinafter: „Wisła Kraków”), in connection with the communication published on 9 October 2026 by the PZPN Club Licensing Committee concerning the control measure applied to Legia Warszawa S.A., with its registered office in Warsaw (hereinafter: „Legia Warszawa”), I request an urgent review of the full text of the decision, together with its statement of reasons and the case files, and consideration by the Head of the PZPN Licensing Department of exercising the power provided for in point 5.1.30(c) of the PZPN Licensing Manual for Ekstraklasa Clubs for the 2026/2027 season and subsequent seasons, approved by Resolution No. VI/133 of the PZPN Management Board of 10 December 2025 (hereinafter: „Licensing Manual”), to lodge, on behalf of the Licensor, an appeal with the PZPN Club Licensing Appeals Committee against the aforementioned decision in part – with regard to the type, amount and structure of the control measure applied and the scope of the obligations imposed on Legia Warszawa.

Wisła Kraków does not challenge the fundamental findings of the PZPN Club Licensing Committee disclosed in the communication of 9 October 2026. On the contrary, these findings largely confirm the circumstances and reservations presented by Wisła Kraków in its letter of 30 September 2026. The doubts requiring review by the appellate body primarily concern the adequacy, effectiveness and preventive nature of the financial measure of PLN 250,000.00 applied for each match played by Legia Warszawa as the home team while criterion I.18 remains unmet, as well as the need to apply additional measures ensuring the actual and, as far as possible, prompt restoration of compliance with the mandatory type A criterion.

Wisła Kraków, as a club directly affected by the consequences of the established infringement, is not a participant in the licensing proceedings in question within the meaning of point 5.1.2 of the Licensing Manual and does not have an independent right to appeal the decision issued. Among entities other than the Applicant or the Licensee, point 5.1.30(c) of the Licensing Manual grants standing to lodge an appeal to the Head of the PZPN Licensing Department, acting on behalf of the Licensor. For this reason, Wisła Kraków addresses this submission specifically to the Head of the Licensing Department. Importantly, this application does not seek to challenge the fundamental findings of the PZPN Club Licensing Committee, but rather to enable the PZPN Club Licensing Appeals Committee to assess whether the response to the established infringement is sufficient, proportionate, and properly directed toward restoring compliance.

The fact that, pursuant to point 5.1.29 of the Licensing Manual, the reasoning of the Licensing Body’s decision is also signed by the Head of the PZPN Licensing Department does not exclude the Head’s authority to lodge an appeal. The Licensing Manual clearly distinguishes the Head of the PZPN Licensing Department’s participation in signing the reasoning of the decision from the separate competence granted to the Head under point 5.1.30(c) of the Licensing Manual to lodge an appeal on behalf of the Licensor. If merely countersigning the reasoning were deemed to exclude the possibility of exercising this right, point 5.1.30(c) of the Licensing Manual would be deprived of practical significance precisely in cases in which the decision was prepared and reasoned in accordance with the requirements of the Licensing Manual. The appellate right of the Head of the PZPN Licensing Department should therefore be regarded as a deliberately established element of the instance-based review mechanism, serving to protect the correctness and consistency of the Licensing System.

The significance of the entitlement provided for in point 5.1.30(c) of the Licensing Manual is particularly important in the present case also in view of the structure of point 6.2.6 of the Licensing Manual. This provision allows the Licensing Bodies to change the control measures applied during the Licensing Season, but expressly excludes from this mechanism the obligation to pay a specified monetary amount and the deduction of points. This means that, with respect to the obligation to pay already imposed on Legia Warszawa, a subsequent adjustment of its amount or structure through the ordinary procedure for changing a control measure provided for in point 6.2.6 of the Licensing Manual has been excluded. Appellate review is therefore now of fundamental importance for determining whether the amount of PLN 250,000.00 per match was properly calibrated.

The Licensing Manual also provides a mechanism for particularly swift review of the ruling. Pursuant to point 5.1.37, the PZPN Club Licensing Committee may, within no more than 3 business days of service of a duly filed appeal, recognize it ex officio as justified, uphold it in its entirety, and amend the challenged decision. Accordingly, the Licensing Department Manager’s exercise of the right of appeal need not lead to lengthy proceedings before the PZPN Club Licensing Appeals Committee if the Club Licensing Committee itself considers the objections raised to be justified.

In view of the above, I request that:

1. considering the filing, pursuant to point 5.1.30(c) in conjunction with point 5.1.34 of the Licensing Manual, on behalf of the Licensor, of an appeal against the decision of the PZPN Club Licensing Committee announced in the communication of 9 October 2026 - insofar as it concerns the type, amount, and structure of the financial measure applied, and any supplementation of the decision with further control measures or prospective obligations, without challenging the ruling extending infrastructure oversight or the obligations concerning the submission of a work schedule and documentation of its implementation;
2. examining whether the financial measure in the amount of PLN 250,000.00 for each match played by Legia Warszawa as the home team at the Municipal Stadium of Legia Warszawa named after Marshal J. Piłsudski at 3 Łazienkowska Street in Warsaw (hereinafter: the “Stadium”), where criterion I.18 has not been met, is sufficient to ensure actual compliance with criterion I.18 and produces an appropriate preventive effect, taking into account the scale, duration, recurrence, and deliberate nature of the non-compliance, while also considering Wisła Kraków’s position that, in the circumstances of this case, the amount of PLN 250,000.00 per match is too low to achieve the required preventive effect on its own; as well as examining whether the decision sets Legia Warszawa a specific deadline for restoring compliance with the said criterion;
3. considering the application - in addition to or instead of the current financial measure, within the limits provided for by the Licensing Manual - of additional control measures or specific prospective obligations leading to restoration of compliance with criterion I.18 as soon as possible, in particular by imposing, pursuant to point 6.1.16 of the Licensing Manual, a specific obligation to restore compliance with criterion I.18, together with setting a deadline for submitting evidence of its performance in accordance with point 6.1.14, an obligation to present and implement for subsequent home matches an alternative solution meeting criterion I.18, and, if the non-compliance continues, considering the application, in relation to subsequent identified violations, of further or additional control measures, including financial measures of a severity that appropriately reflects the repeated nature of the violation, within the limits of points 6.2.4–6.2.6 of the Licensing Manual; if new prospective obligations are imposed as a result of self-monitoring or appeal proceedings, considering making them immediately enforceable pursuant to point 6.2.9 of the Licensing Manual, and, in the case of a decision by the PZPN Club Licensing Committee, also taking point 6.2.5 of the Licensing Manual into account;
4. examining the actual economic balance of excluding the away supporters' section during matches played by Legia Warsaw as the home team at the Stadium, particularly potentially avoided costs of securing the match and handling the organized group of away supporters, the impact on the costs of security and information services, and any changes in the structure of ticketing, catering, and other match-related revenue, as well as taking into account, when assessing the adequacy of the control measure, the sporting asymmetry resulting from the absence of organized support for the away team; as part of the economic analysis, determining whether the content of the permit issued by the Mayor of the Capital City of Warsaw on 8 October 2026, the Police opinion, or other documents indicate that the exclusion of organized groups of away supporters is related to the reclassification of the mass event as a high-risk event (Article 3(5) of the Act on the Safety of Mass Events), on which the minimum number of security and information service personnel depends (Article 6(2) of the Act on the Safety of Mass Events), as does the permissibility of selling alcoholic beverages with an alcohol content of up to 3.5% (Article 8a(1) of the Act on the Safety of Mass Events);
5. continuing effective license control and promptly reassessing the adequacy of the measures applied if the failure to meet criterion I.18 persists, particularly before Legia Warsaw's subsequent home matches (points 6.1.2–6.1.4 and 6.2.6 of the Licensing Manual);
6. examining whether Legia Warsaw fulfilled its obligation to inform the Licensor of a Material Change affecting compliance with the infrastructure criteria within 5 days (point 9.5.2 of the Licensing Manual) and whether – following the exclusion of the existing away supporters' section – it identified a replacement section meeting criterion I.18, and if compliance with the obligation under point 9.5.2 was not covered by the concluded proceedings – considering the initiation of separate explanatory proceedings in this regard pursuant to point 6.2.3 of the Licensing Manual;
7. including this letter and its annexes in the case file so that, in accordance with point 5.1.38 of the Licensing Manual, this material may be taken into account by the PZPN Club Licensing Appeals Committee if an appeal is lodged by any of the entitled entities; if an appeal is lodged by Legia Warsaw – taking Wisła Kraków's position into account in the material submitted to the PZPN Club Licensing Appeals Committee, and if the PZPN Club Licensing Appeals Committee requests further information or documentation pursuant to point 6.1.20 of the Licensing Manual – also presenting the circumstances and materials indicated in this letter;
8. informing Wisła Kraków how this application has been handled.

Wisła Kraków submits this application on the basis of the public statement of the PZPN Club Licensing Committee dated October 9, 2026, and does not have the full text of the decision issued or its grounds. Accordingly, the arguments set out below should be verified by the Head of the PZPN Licensing Department in light of the complete case file. This circumstance further supports the urgent use of the instance-review mechanism provided for in the Licensing Manual, if an analysis of the full decision confirms the concerns described below.

I. CHRONOLOGY AND NATURE OF THE MATTER

The assessment of this matter requires consideration of the sequence and interrelationship of the events that led to the exclusion of the away supporters' section and the subsequent finding by the PZPN Club Licensing Committee that criterion I.18 was not met. For this reason, the most significant circumstances are set out below in chronological order:

1. April 28, 2026 – the PZPN Club Licensing Committee granted Legia Warsaw a license to participate in the PKO BP Ekstraklasa competition in the 2026/2027 season, placing the club under infrastructure supervision,
2. June 11, 2026 – the schedule of fixtures for the 2026/2027 season was published, according to which the Legia Warsaw – Wisła Kraków match was assigned to matchweek 10,
3. August 27, 2026 – The Ekstraklasa S.A. Competition Logistics Department scheduled the match for October 11, 2026. From that point, both parties had more than six weeks to make organizational preparations for the match, including arrangements for the organized group of away supporters,
4. September 9, 2026 – Wisła Kraków placed an order for the full allocation of tickets for its authorized group of supporters. Legia Warszawa allocated 1,700 tickets for distribution; sales began on September 22, 2026, and all tickets had been sold before the decision to take the section out of use was announced. This means that both clubs began the actual implementation of the procedure for the participation of an organized group of away supporters, and that 1,700 people took action in reliance on the sales that had been launched. This allocation met the requirement of at least 5% of the available seats under criterion I.18. Until the decision to take the away-fans' section out of use was made, Legia Warszawa therefore proceeded organizationally on the assumption that it would be used for the match and did not inform Wisła Kraków that it was unavailable,
5. September 23, 2026 – The Warsaw Municipal Greenery Authority called on Legia Warszawa to surrender plot no. 15 in precinct 5-06-10 or submit an application to lease it. Information published later indicated that Legia Warszawa had been using the site without a formal agreement, that talks to regularize the situation had been held earlier, and that the lease application was not submitted until September 29, 2026. The Warsaw Municipal Greenery Authority subsequently stated publicly (October 6, 2026) that, despite the absence of a concluded agreement, Legia Warszawa could use the entrance to the Stadium from Kusociński Street, that it did not plan to fence off or close the area, and that the lease issue was not a reason to close the away-fans' section,
6. September 24-25, 2026 – Legia Warszawa contacted the Warsaw I District Police Headquarters regarding planned infrastructure changes. The police subsequently explained publicly that their letter referred to solutions presented by Legia Warszawa itself, did not constitute an order to close the away-fans' section, was not a response to any specific match or incident, and did not set a work schedule,
7. September 28, 2026 – Legia Warszawa unilaterally announced that the away-fans' section would be taken out of use until the end of 2026, while also indicating that it was preparing documentation and holding talks with contractors. On that day, Legia Warszawa did not yet have a permit to hold mass events without away-team supporters and had not designated a substitute section,
8. September 30, 2026 – Wisła Kraków sent Legia Warszawa, the PZPN, and Ekstraklasa S.A. a comprehensive position outlining a number of possible alternative solutions: carrying out priority works, implementing temporary safeguards, providing an alternative section, temporarily limiting the size of the away group, relocating mobile infrastructure, increasing the number of stewards and spotters, and conducting an urgent site inspection. Wisła Kraków also declared its readiness to cooperate organizationally and discuss participation in the justified costs of temporary solutions concerning Legia Warszawa’s match against Wisła Kraków,
9. October 5, 2026 – The Police’s position was made public, unequivocally indicating that the Police had neither requested nor ordered the closure of the away supporters’ section and that the decision to make it available rested with the organizer. In this position, the Police stated that it “did not request or order the away supporters’ section to be taken out of use,” “did not set deadlines for the modernization works planned by Legia club,” and “did not call on the club to regulate matters concerning ownership rights or the lease of the land,”
10. October 6-7, 2026 – In statements provided to the media, the PZPN indicated that the away supporters’ section at Legia Warszawa’s stadium still met the PZPN’s infrastructure criteria, that “the timing of this decision, made immediately before the match against Wisła Kraków, raises particular concerns,” and that if the existing section was unavailable, the host should designate an alternative section – which Legia Warszawa did not do,
11. October 7, 2026 – Legia Warszawa submitted an application to amend its permit to hold mass events – nine days after announcing the closure of the section; on the same day, the Warsaw I District Police Commander issued a favorable opinion on the possibility of staging matches through the end of 2026 without away supporters,
12. October 8, 2026 – Legia Warszawa announced that it had obtained an amended permit from the Mayor of the Capital City of Warsaw to hold mass events without away supporters until December 31, 2026. On the same day, Ekstraklasa S.A. expressed its “disapproval of the timing and manner in which the club handled this matter” and announced that it would apply to the Licensing Authorities to place Legia Warszawa under infrastructure supervision,
13. October 9, 2026 – The PZPN Club Licensing Committee published a statement imposing a control measure on Legia Warszawa in the amount of PLN 250,000.00 for each match played at home while criterion I.18 remains unmet, and extending infrastructure supervision to monitor progress on work in the away supporters’ section. The statement does not specify the deadline by which Legia Warszawa must restore compliance with criterion I.18.

The above chronology is of fundamental importance. The current state of non-compliance is not solely the result of a sudden external administrative decision that the Licensee could neither have foreseen nor counteracted. On the contrary, the PZPN Club Licensing Commission itself found that the closure of the sector was unauthorised, and that Legia Warszawa had not demonstrated sufficiently early and effective efforts to develop alternative solutions. The subsequent administrative permit, issued only after Legia Warszawa had decided to close the sector and at the organiser's request, does not remove this aspect of the assessment.

II. THE COMMISSION'S FINDINGS CONFIRM THE FAILURE TO MEET THE MANDATORY TYPE A CRITERION

It follows from the public statement of the PZPN Club Licensing Commission dated 9 October 2026 that Legia Warszawa does not meet criterion I.18 of the Licensing Manual. The PZPN Club Licensing Commission expressly stated that the decision resulted from Legia Warszawa's “unauthorised temporary closure” of the sector intended for visiting-team supporters until the end of 2026. The PZPN Club Licensing Commission also emphasised that the administrative permit to organise mass events without visiting supporters, issued at Legia Warszawa's request, does not release the Licensee from the obligation to comply with licensing requirements, and that the failure to demonstrate sufficiently early and effective efforts to develop alternative solutions was of material significance. The PZPN Club Licensing Commission also noted that “responsible management of stadium infrastructure requires not only responding to problems as they arise, but also identifying risks sufficiently early, planning actions and analysing available solutions”.

Criterion I.18 is a type A criterion and requires at least 5% of the total number of available seats to be allocated to visiting-team supporters in a separate sector ensuring their safe and comfortable reception. In the licensing system, this is neither an optional service nor an element of match organisation that a club may forgo after taking a particular cost into account. It is a mandatory condition for participation in the competition..

Pursuant to point 1.4(a) of the Licensing Manual, failure to meet criterion A precludes the granting of a licence, while point 6.1.18 permits - with regard to criterion A whose non-fulfilment results in a licence not being granted - even the suspension or withdrawal of a licence during the season. The Licensing Manual also provides for two formal procedures for departing from infrastructure requirements: a decision by the Licensor to grant a derogation in particularly justified cases (point 9.5.1) and - on safety grounds and only during the construction or modernisation of a facility - a decision by the Licensor to hold matches without spectators (point 9.5.3). None of these procedures provides for the club's unilateral exclusion of only the visiting team's supporters while maintaining full attendance of its own spectators.Regardless, the Licensee is obliged to inform the Licensor of any Material Change affecting compliance with the infrastructure criteria within 5 days (point 9.5.2); it is reasonable to determine whether and when this obligation was fulfilled.

The significance of type A criteria is also emphasized by point 4.3.6 of the Licensing Manual, which provides for the possibility of suspending or revoking a licence if any of the conditions for its issuance ceases to be met or the Licensee breaches an obligation arising from the Licensing Manual designated as a type A criterion. Wisła Kraków does not infer from this provision that such a far-reaching measure must be applied against Legia Warszawa; nevertheless, this regulation demonstrates the systemic importance of a breach of a type A criterion and argues against treating a knowingly and deliberately planned failure to meet it as an irregularity that can be sufficiently compensated for solely by a predictable financial cost incurred for each match.

Point 6.2.4 of the Licensing Manual provides for a broad range of inspection measures in the event of failure to meet criterion A: from a warning, through transfer and financial measures and the deduction of points, to suspension of the licence. The obligation to pay a specified amount may range from PLN 5,000.00 to PLN 1,000,000.00. Point 6.2.5 of the Licensing Manual requires that the severity of the measure applied must not exceed the degree of the violation of the criteria. This regulation protects against an excessive measure; however, it does not mean that every measure falling below that threshold is thereby also a sufficient measure. It follows from the structure of the inspection and supervision procedure, the possibility of applying the measures listed in point 6.2.6 of the Licensing Manual cumulatively, and the powers under point 6.1.16 of the Licensing Manual to impose obligations concerning future conduct, that the instrument applied should also genuinely be capable of achieving the purpose of the inspection: ensuring compliance with the licensing requirements and restoring the compliant state as quickly as possible.In this sense, the Licensing Body should select an instrument that is not only formally permissible and non-excessive, but also appropriate to the nature, scale, and expected duration of the violation.

III. THE MEASURE APPLIED MUST NOT REDUCE A MANDATORY CRITERION TO A “PRICE” FOR FAILING TO MEET IT

The most significant concern concerns the structure and amount of the measure applied: PLN 250,000.00 for each match played as the home team while I.18 is not met. In Wisła Kraków’s assessment, given the circumstances established by the PZPN Club Licensing Committee itself and the announced intention to maintain the breach over subsequent matches, this amount is too low to independently ensure an adequate deterrent effect. It is a nominally burdensome amount, but its nominal size does not in itself establish that the measure performs a control and preventive function. It is necessary to determine whether, for the specific Licensee and the specific match, the actual economic, organizational, and sporting value of the benefits resulting from not admitting visiting fans is not comparable to or greater than the amount imposed.

If the economic balance of a breach is neutral or positive for the Licensee, the control measure ceases to discourage breaches of obligations and begins to function as a cost factored into the match-organization model. In such a situation, the club may rationally conclude that it is more profitable to pay PLN 250,000.00 than to undertake the more difficult organizational and financial measures necessary to admit visiting fans. Such an effect would be contrary to the essence of a type A criterion and the function of the licensing control system.

The fact that, if the breach continues for five consecutive matches, the total amount of the financial measures may reach PLN 1,250,000.00 does not eliminate this problem. Such an amount arises only as a result of five consecutive, predictable cases of failure to meet the criterion. From a preventive perspective, the relevant question is not only what the total sanctions will be at the end of the round, but whether the structure of the measure provides sufficient motivation to avoid each subsequent breach before it occurs.

The assessment should therefore also be carried out at the level of an individual match. If the marginal economic, organizational, or sporting benefit resulting from playing a particular match without the visiting fans is higher than PLN 250,000.00 or close to that amount for the Licensee, payment of the financial measure does not remove the incentive to continue violating the criterion. Moreover, the fixed and predetermined amount of the measure makes it easier to factor into the budget for subsequent events, which may weaken its deterrent effect compared with an instrument whose consequence would be a real deterioration of the Licensee’s situation if the non-compliance continued.

The scale of the anticipated breach further weighs against treating it as a temporary or marginal infrastructure non-compliance. According to the position presented by Legia Warsaw, the away supporters' section is to remain closed until the end of 2026, that is, for a period covering 5 of Legia Warsaw's 9 home matches in the autumn round of the 2026/2027 season. This means that criterion I.18 would remain unmet during more than half - approximately 55.6% - of all of Legia Warsaw's home league matches in that round. Over the entire season, this means 5 of 17 home matches, or approximately 29.4% of all Ekstraklasa matches played by Legia Warsaw as the home team. This is therefore not an isolated or short-term breach related to a single event or a temporary failure, but a situation covering a significant part of the entire league season.

This circumstance should be directly relevant to the assessment of the proportionality and effectiveness of the control measure. The longer and more repetitive the anticipated period of non-compliance with a mandatory type A criterion, the more important it is to consider not only the amount of the financial measure applicable to an individual match, but also its actual ability to bring the breach to an end. Accepting a situation in which the Licensee assumes in advance that it will fail to meet criterion I.18 in more than half of its home matches in one round and nearly one-third of all home matches in the season, while limiting the response primarily to a predetermined financial cost for each such match, may in practice weaken the mandatory nature of a type A criterion.

IV. THE ECONOMIC PROFITABILITY OF THE BREACH SHOULD BE EXAMINED, NOT ASSUMED

Wisła Kraków does not have access to Legia Warsaw's internal financial data and cannot currently determine the actual value of the benefits or savings associated with organizing a match without an organized group of visiting supporters. This is precisely why the matter should be examined by the Licensing Body before PLN 250,000.00 is deemed sufficient. The analysis should include at least the following elements:

1. avoided organizational costs related to serving an organized group of visiting supporters, including the costs of additional security and information services, barriers, buffer zones, deposit and sanitary facilities, personnel, internal transport, and other security measures required when organizing such a match;
2. any potential difference between the costs of securing a high-risk mass event and an event without that status. Article 6(2) of the Act on the Safety of Mass Events provides for significantly higher minimum staffing ratios for security and information services at a high-risk event. If the absence of the visiting group were to affect the classification of a specific event, this could generate measurable savings for the organizer;
3. the impact of excluding the visiting supporters’ sector on ticket sales structure and the use of the remaining sectors, including any possibility of commercializing seats or reducing areas organizationally set aside, insofar as such an effect occurs in the specific case;
4. the impact on catering revenue and other match-day revenue. Pursuant to Article 8a(1) of the Act on the Safety of Mass Events, at a mass event that is not an event of elevated risk, the sale, serving, and consumption of alcoholic beverages containing no more than 3.5% alcohol is permitted, provided the statutory conditions are met. If the permit, the Police opinion, or other documents indicated that excluding organized groups of visiting supporters was connected with changing the classification of the particular event and consequently made such sales possible, the additional catering revenue should be included in the economic balance;
5. any other savings or additional revenue arising solely because the organizer declines to fulfill the obligation to admit an organized group of visiting supporters.

The foregoing does not mean that every benefit listed occurs in every Legia Warsaw match. It means, however, that before PLN 250,000.00 is deemed a properly calibrated control measure, the actual economic balance of organizing a match with and without visiting supporters must be established. In the case of a match with an elevated risk profile, the total costs of additional security, services, and infrastructure may be considerable; it therefore cannot be ruled out that a measure set at PLN 250,000.00 will not fully neutralize the economic incentive to keep the sector closed.

From the standpoint of the measure’s preventive function, it should be designed so that the breach cannot constitute a rationally economical alternative to fulfilling the obligation. Otherwise, the licensing system would in practice create the possibility of “buying out” a temporary departure from a type A criterion without a formal derogation decision as provided for in point 9.5.1 of the Licensing Manual.

V. SPORTING BENEFIT IS INDEPENDENT OF FINANCIAL BENEFIT

Regardless of the financial balance, refusing to admit an organized group of visiting supporters may generate sporting benefits. The home team plays before its own crowd, while the opponent is deprived of organized support and backing from its traveling group. This kind of asymmetry cannot easily be assigned a monetary value, but it remains relevant to the purpose of the licensing system and the principle of fair competition.

This situation is particularly problematic when it is recurrent and covers an entire series of home matches. Legia Warszawa may benefit from visiting supporters' sections in away matches, while its successive opponents are to be deprived of analogous support at the Stadium. This is not a balance that can be restored merely by paying a specified amount of money after each match.

In this case, the issue does not concern a single match - the absence of organized groups of visiting supporters may affect more than half of Legia Warszawa's home matches in the autumn round and nearly one-third of its home matches throughout the league season, which significantly increases the scale of the potential sporting asymmetry relative to the other participants in the competition. This is precisely why the adequacy of the control measure should be assessed not only by reference to its nominal amount, but also by its ability to eliminate the potential sporting advantage resulting from the continued knowing failure to meet a mandatory infrastructure criterion.

This assessment should also take into account the principle of equal treatment of Applicants and Licensees, expressed in point 3.1.3 of the Licensing Manual, as well as one of the fundamental objectives of the licensing system, namely ensuring the continuity and fairness of PZPN Club Competitions. Clubs that bear the costs of maintaining infrastructure and organizing matches in a manner ensuring the continuous fulfillment of criterion I.18 should not be placed in a relatively less favorable position than the Licensee that knowingly maintains a state of non-compliance with this criterion and bears a predetermined financial cost as a result. Otherwise, the control mechanism may lead to the economic privileging of non-compliance over regulatory compliance, which is difficult to reconcile both with the principle of equal treatment and with the objective of ensuring fair competition.

It is also important that the effects of sporting asymmetry are irreversible. After a match has been played without an organized group of supporters of the visiting team, the subsequent payment of a financial measure cannot recreate the conditions in which the match was played or restore the support of its supporters that the opposing team lost. For this reason, with regard to a breach of criterion I.18, ex ante measures, i.e. measures aimed at preventing another breach rather than solely at its subsequent financial settlement, are of particular importance.

VI. RISK OF A PRECEDENT FOR THE ENTIRE COMPETITION

The case has systemic implications. If a standard became established under which a club could independently close the away section for an extended period and then continue playing subsequent matches after paying a predetermined amount for each match, other participants in the competition could interpret this mechanism as an acceptable course of action. Consequently, the control measure would cease to serve a deterrent function and would instead become an element of economic calculation. A club that determined that the cost of admitting an organized group of away supporters - or the organizational or sporting benefit of their absence - exceeded the amount of the financial measure could treat the payment as a cost of doing business. Such a precedent would be particularly dangerous with regard to the Type A criterion of the Licensing Manual, compliance with which is, as a rule, absolute.

The Licensing Manual provides a formal mechanism for waiving the infrastructure criterion in point 9.5.1 and, for situations dictated by safety considerations during the modernization of a facility, a mechanism for matches played without spectators in point 9.5.3. If a waiver is to be permitted, it should be granted through a formalized procedure, following an assessment of its compliance with the objectives of the licensing process, rather than arising de facto through the economic acceptance of successive instances of non-compliance with the criterion.

VII. COMPARISON WITH THE ŚLĄSK WROCŁAW CASE – PUNITIVE AND PREVENTIVE FUNCTION

A particularly important reference point is this year's case involving WKS Śląsk Wrocław S.A., based in Wrocław (hereinafter: “Śląsk Wrocław”), concerning the refusal to admit an organized group of Wisła Kraków supporters to the match of the 24th round of Betclic 1. Liga scheduled for 7 March 2026. By decision of 16 March 2026, the PZPN Disciplinary Committee found Śląsk Wrocław liable and imposed a fine of PLN 1,000,000.00. On 21 May 2026, the PZPN Higher Appeals Committee upheld this penalty, finding the violations egregious and expressly stating that the penalty was to serve a dual function: punitive with respect to the accused party and preventive with respect to the entire sporting community.

Wisła Kraków is aware that the proceedings concerning Śląsk Wrocław were disciplinary in nature, whereas the current decision concerning Legia Warszawa was issued under the licensing control system. This is therefore not about mechanically transferring the amount of the penalty from one regime to the other, nor about claiming that every violation must result in an identical sanction.

The difference between the legal bases of the two proceedings does not, however, eliminate their functional relationship. The disciplinary regime protects the performance of obligations relating to the admission of an organized group of away supporters, whereas the licensing regime concerns the continuous fulfilment of mandatory infrastructure standard I.18. These are separate mechanisms protecting different aspects of the proper conduct of competitions, but they should form a coherent system in which a breach of obligations does not become economically, organizationally, or sportingly advantageous.

The significance of these earlier cases as a reference point for the consistency of the PZPN's regulatory policy is not merely Wisła Kraków's position. In an official statement provided to the media on 7 October 2026, already directly in the context of Legia Warszawa's exclusion of the away-supporters' sector, The PZPN itself recalled both the Association's intervention in the GKS Tychy case, which made it possible to admit Wisła Kraków supporters despite an infrastructure problem, and the Śląsk Wrocław case, as well as the PLN 1,000,000.00 penalty for the unjustified refusal to admit an organized group of Wisła Kraków supporters. This confirms that the Licensor itself also perceives these events as part of a broader problem concerning the application of regulations relating to visiting-team supporters, one requiring a consistent approach.

In this context, the significance of the Śląsk Wrocław case does not lie in the identity of the legal bases or the competences of the authorities, but in the regulatory function of the PZPN's response. In that case, the Highest Appeals Commission held that the response to the unjustified refusal to admit away supporters should not only be punitive toward the accused party, but should also produce a preventive effect across the entire sporting community. The same preventive objective should be taken into account - while maintaining the complete distinctness of the legal bases and within the powers of the Licensing Bodies - when selecting the control measure in the present case, particularly when the Licensing Body already knows before the subsequent matches that mandatory criterion I.18 is to remain unmet for subsequent months.

The comparison with the Śląsk Wrocław case is also gaining additional significance due to the scale of the violation. There, the disciplinary response concerned a specific match, whereas in the case of Legia Warszawa, a failure to meet criterion I.18 is already anticipated for 5 consecutive home matches - approximately 55.6% of the home matches in the autumn round and 29.4% of all home matches in the 2026/2027 season. This makes it all the more justified to ask whether a measure of PLN 250,000.00 per match provides a sufficient deterrent effect in response to a violation of such scale and of a foreseeable, recurring nature.

In this context, PLN 250,000.00 per match represents only 25% of the maximum amount of a single financial measure provided for in point 6.2.4(e) of the Licensing Manual. This ratio alone obviously does not establish that the decision is inadequate, but when considered alongside the findings of the PZPN Club Licensing Committee - the unilateral closure of the section, the deliberate specification of the infringement period as lasting until the end of the year, the lack of sufficiently early alternatives, and the repeated nature of the violation - it requires a specific explanation of why a measure at this level should be sufficient to achieve a deterrent effect.

VIII. A SUBSEQUENT ADMINISTRATIVE PERMIT SHOULD NOT REWARD AN EARLIER VIOLATION

Wisła Kraków fully respects the powers of the Mayor of the Capital City of Warsaw and the organizer's obligation to act in accordance with the current permit to hold a mass event. This application does not seek to challenge the legality of that permit.

However, the sequence of events must be properly observed. Legia Warsaw decided to close the away supporters' section 28 September 2026. Legia Warsaw submitted the application to amend the permit only on 7 October 2026. A new Police opinion positively assessing the holding of matches without away supporters was issued 7 October 2026., while the administrative permit was issued on - 8 October 2026 The PZPN Club Licensing Committee itself stressed that the permit was issued at Legia Warsaw's request and does not release it from its obligation to comply with the licensing criteria.

A subsequent administrative decision may determine how the nearest mass events are organized, but it should not lead to a situation in which the Licensee's earlier unilateral decision is indirectly entrenched as an economically acceptable solutionOtherwise, the club could first create a state of non-compliance, then obtain an administrative decision adapted to that state, and finally invoke that decision as justification for continuing not to meet criterion A.

IX. THE NEED FOR PROSPECTIVE MEASURES AND FURTHER OVERSIGHT

It follows from the public statement that the PZPN Club Licensing Committee expanded its infrastructure oversight and required Legia Warsaw to submit a work schedule and documents confirming that the work had begun. This direction should be viewed positively, but the oversight itself does not yet establish whether the Licensee received an effective incentive to restore compliance with I.18 before the next matches.

Wisła Kraków also draws attention to the specific procedural effect provided for in point 6.1.19 of the Licensing Manual, under which lodging an appeal against a decision issued in the course of the Control and Supervision Procedure stays enforcement of the challenged decision. For this reason, any appeal by the Licensor should be drafted as precisely as possible and - pursuant to point 5.1.34 of the Licensing Manual - limited to those elements of the ruling whose appellate review is actually sought by Wisła Kraków. The purpose of this submission is not to challenge or stay the existing infrastructure supervision, the obligation to submit a work schedule, or the obligations relating to documenting its implementation. On the contrary, Wisła Kraków considers these elements of the decision to serve the ongoing monitoring of the process of restoring compliance with criterion I.18. The requested appellate review should focus primarily on the amount and structure of the financial measure and the need to apply additional forward-looking instruments.

It cannot be ruled out that Legia Warszawa will also exercise its right of appeal, challenging in particular the legitimacy, amount, or structure of the financial measure applied. In such a case, it is particularly important to ensure that the material subject to review by the PZPN Club Licensing Appeals Commission includes not only the arguments presented by the Licensee, but also the complete material concerning the scale and nature of the breach, its anticipated duration, possible economic and sporting benefits, and the circumstances supporting an assessment of the measure's adequacy from the perspective of the objectives of the Licensing System. For this reason, Wisła Kraków also requests that this letter, together with its attachments, be added to the case file so that - within the limits arising from points 5.1.38 and 6.1.20 of the Licensing Manual - the circumstances presented in it may be taken into account if appellate review is initiated.

When assessing the sufficiency of this instrument, it cannot be overlooked that, in Legia Warszawa's case, infrastructure supervision is not a new measure. The Club was placed under it when the licence was granted on 28 April 2026, and the state of non-compliance with criterion I.18 arose during the period in which that supervision was in force.This circumstance does not establish that the institution of supervision itself is ineffective; it does, however, justify asking whether merely extending it - without simultaneously imposing a specific obligation to remedy the situation and a deadline for its performance - constitutes a sufficient response to the identified state of non-compliance. If the breach arose despite supervision already being in place, the appellate review should examine whether continuing to apply the same instrument requires supplementing it with a measure having a greater capacity to influence the Licensee's future conduct.

Criterion I.18 is functional in nature: it requires ensuring a specified number of places in a separate sector meeting the indicated conditions, not maintaining for this purpose one specific, historically used sector of the stadium. The temporary unavailability of the existing area therefore does not in itself result in the expiry of the licensing obligation, but triggers the need to verify the possibility of providing an alternative solution. This is particularly significant in view of the PZPN Club Licensing Committee's finding that Legia Warszawa did not demonstrate that it had sought such solutions sufficiently early and effectively.

Point 6.1.16 of the Licensing Manual allows the PZPN Club Licensing Committee to impose on the Licensee specific obligations concerning its future conduct, while point 6.1.14 allows it to set a final deadline for submitting evidence confirming the fulfilment of those obligations. Point 6.2.6 of the Licensing Manual, in turn, permits the cumulative application of control measures. Therefore, during the appeal review, it is appropriate to consider an instrument that will not be limited to subsequently charging an amount for subsequent matches, but will create a specific prospective obligation. This may include, in particular, an obligation to restore compliance with criterion I.18 and submit evidence of its fulfilment by a specified deadline, an obligation to present and implement an alternative solution meeting criterion I.18, and, in the event of further established violations, the application of further or additional control measures from the catalogue in point 6.2.4 of the Licensing Manual, with severity reflecting the recurring nature of the non-compliant state.

Wisła Kraków does not request the application of a predetermined measure and, in particular, does not assert that suspension of the licence is necessary. The choice of instrument lies with the Licensing Bodies. Wisła Kraków does, however, request that the measure applied actually be capable of achieving its purpose: preventing further violations and restoring compliance with the mandatory type A criterion, rather than merely assigning a specific cost to each subsequent violation.

If, despite the present decision, the state of non-compliance with criterion I.18 continues, it is appropriate to continue exercising the supervisory powers provided for in the Licensing Manual and to re-examine whether the set of measures applied remains adequate. Further violations should not be treated as neutral events merely because their cost was predetermined in the decision of the PZPN Club Licensing Committee of 9 October 2026.

The communication of the PZPN Club Licensing Committee dated 9 October 2026 contains findings of considerable significance: the section was excluded arbitrarily, criterion I.18 is not being met, a subsequent administrative authorization does not release the club from its licensing obligations, and Legia Warszawa failed to demonstrate sufficiently early and effective efforts to find an alternative. In such factual circumstances, the subject of appellate review should not be the justification for the PZPN’s response itself, but rather whether that response is sufficient and appropriately targeted..

A financial control measure should deter breaches of licensing obligations, rather than become a cost that can be factored into non-compliance with them. In Wisła Kraków’s assessment, the amount of PLN 250,000.00 per match is - in light of the circumstances of this case established by the PZPN Club Licensing Committee, including the arbitrary nature of the exclusion, its predetermined multi-month duration, and the failure to demonstrate alternatives sufficiently early - too low a measure to independently ensure a sufficient deterrent effect. Where refusing admission to an organized group of away supporters may generate savings for the organizer in terms of security, additional match-day or catering revenue, and at the same time a sporting benefit resulting from the absence of organized support for the opponent, the amount of the financial measure must also be assessed in light of those benefits. If the measure is lower than, or close to, the economic, organizational, or sporting value of the breach, its deterrent function is significantly weakened.

For this reason, Wisła Kraków requests urgent consideration of lodging, on behalf of the Licensor, an appeal pursuant to point 5.1.30(c) of the Licensing Manual, and requests that the appellate review specifically cover the amount and structure of the financial measure, the need to apply additional control measures, the economic and sporting balance of excluding the away supporters’ section, and the means of ensuring the actual restoration of compliance with criterion I.18 of the Licensing Manual.

Given the short, five-day time limit for lodging an appeal provided for in point 5.1.32 of the Licensing Manual, as well as the need to resolve the matter as quickly as possible before the next matches played while criterion I.18 remains unmet, Wisła Kraków requests that this application be considered without delay and - insofar as this applies to an appeal lodged by the Head of the Licensing Department on behalf of the Licensor - before the applicable deadline for lodging an appeal expires.

Yours faithfully

Jarosław Królewski
President of the Management Board of TS Wisła Kraków S.A.

Attachment:

1. Letter from TS Wisła Kraków S.A. dated 30 September 2026 concerning the exclusion of the away supporters’ section, together with its attachments

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