2027 WADA code: key changes & legal analysis

2027 WADA code: key changes
2027 WADA code: key changes
2027 WADA code: key changes
2027 Wada Code Key Changes
2027 WADA code: key changes
2027 Wada Code Key Changes

2027 WADA code: key changes in the fourth and final draft. Summary of major changes

The World Anti-Doping Agency has published the final drafts of the 2027 World Anti-Doping Code (Code) and International Standards (Standards) as part of the final stage of the 2027 Code and Standards Update Process.

This update process will culminate in the presentation and endorsement of these proposed versions during the 2025 World Conference on Doping in Sport, which will take place during the week of 1–5 December 2025 in Busan, Republic of Korea, prior to the final approval of the Code and Standards at a joint meeting of WADA’s Executive Committee (ExCo) and Foundation Board (Board) on 5 December.

Let’s look at the 2027 WADA Code key changes that were discussed in the preparation of the final draft. Please note that we summarize only the changes in the WADA Code and not those in the related International Standards.

1. Independent review expert (IRE)

A major innovation is the creation of the Independent Review Expert, who must review any attempt by an Anti-Doping Organization (ADO) to close an Adverse Analytical Finding without proceeding to results management. The IRE provides an opinion on whether such a departure is justified. Failure to involve the IRE appropriately may lead to non-compliance consequences for the ADO.

2. Minors

Special protections for Minors are strengthened and, in some cases, extended beyond Protected Persons to all athletes aged 16-17. Mandatory Public Disclosure of anti-doping rule violations is not required in cases where the violator is a Minor, and any optional Public Disclosure shall take into consideration the best interests of the individual. Violations involving Minors, particularly trafficking or complicity, are treated as especially serious and may lead to harsher sanctions for those involved.

3. Athlete support personnel

The Code reinforces obligations of Athlete Support Personnel (ASP). Anti-Doping Organizations are now required to automatically investigate ASP when a Minor or Protected Person they support commits a violation. ASP must also attend anti-doping education and provide accurate information. Violations of these duties may trigger disciplinary action even when they do not rise to the level of an anti-doping rule violation.

4. Public disclosure

Important refinements were made to balance transparency with athlete protection. Public disclosure after final decisions remains mandatory, but not when athletes are found to have committed no violation or bear No Fault—unless the identity is already public, consequences must be explained, or compelling circumstances justify disclosure. Statistical, anonymized reporting of No Fault cases is required annually.

5. Uniform appeal deadlines

Among the 2027 WADA Code key changes, a new uniform appeal deadline applies to all parties other than WADA: 21 days after receipt of a decision or 21 days after receiving the full case file when requested. This ensures consistency across jurisdictions and improves procedural fairness.

6. Retired athletes

Retired athletes returning to competition must now not only enter the testing pool but also agree to be bound by anti-doping rules during their waiting period. Additionally, retired athletes who tamper with ongoing results-management procedures remain subject to sanctions.

7. Activities allowed during suspension

Article 10.14.1 provides expanded clarification. Suspended individuals may not hold positions involving athlete contact, doping control, or senior leadership roles within Signatories. However, employment in unrelated roles and continued salary payments under athletic contracts are permitted, provided prohibited activities are avoided.

8. Therapeutic use exemptions (TUEs)

A significant unresolved issue was sanctioning flexibility in retroactive TUE situations. The final draft introduces Article 10.2.4.1, which imposes a flat two-month period of Ineligibility (not subject to further reduction) where the Athlete can establish that when they used the Prohibited Substance or Method, that use would have met the TUE criteria set forth in the International Standard for Therapeutic Use Exemptions.

9. Substances of abuse

The revised approach introduces a standardized two-month sanction for first violations, without mandatory treatment programs. Second violations may result in a four-month sanction, reducible if treatment is entered when appropriate.

10. New article 10.7.2 – Other valuable information

This new article allows up to a 15% reduction in sanction for valuable information that does not meet the threshold of Substantial Assistance – for example, insight into methods of avoiding detection without implicating others.

11. New article 10.9.3.4 – Multiple violations

This addition handles cases where a second positive test results solely from residual presence from the same ingestion as the first. No additional sanction applies; only results from the second finding are disqualified, and the multiple-violation rule is not triggered.

12. Provisional suspensions

The process for challenging decisions related to Provisional Suspensions has been modified. Challenges must be heard first in the ADO process before an appeal to CAS. This gives Athletes the opportunity to challenge a Provisional Suspension quickly and in their own language.

The final draft reflects WADA’s intention to modernize the global system by strengthening protections and improving fairness. As the Code progresses toward final approval in December 2025, stakeholders should prepare for these 2027 WADA Code key changes, which aim to protect the integrity of competition while respecting athlete rights.

In managing anti-doping cases, improvisation leads to irreversible situations. As a sports lawyer, your ability to protect an athlete’s career hinges on your anticipation and technical mastery.

Don’t wait for new regulations to catch you off guard. Specialize, stay updated, and bulletproof your strategy with our Executive Program on Anti-doping: Strategy, Defense & CAS Jurisprudence.

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