Recommendations 1/2025 on the 2027 WADA World Anti-Doping Code

• Jurisdiction: European Union
• Year: 2025
• Date: 13 February 2025
• Type of Document: Guidance

Recommendations 1/2025 on the 2027 WADA World Anti-Doping

Code

Adopted on 11 February 2025

Ref. Ares(2025)1113148 - 12/02/2025

Executive Summary

By way of letter dated 2nd October 2024

1

, the European Commission (Directorate-General

for Education, Youth, Sport and Culture) requested the EDPB pursuant to Art. 70 (1) (e) GDPR

to examine the current update of the World Anti-Doping Code (hereinafter the 'Code') and its

complementing International Standards (hereinafter the 'Standards') in order to assess their

compliance with the GDPR. In 2023, the World Anti-Doping Association (hereinafter ‘WADA’)

launched a revision of the Code and its Standards, to be concluded by December 2025, and

to come into effect in January 2027. The Code aims at harmonising anti-doping policies, rules

and regulations internationally and it is complemented by eight International Standards with

the objective of fostering consistency among anti-doping programmes that are implemented

mainly via the National Anti-Doping Organisations (hereinafter the ‘(N)ADOs’). The eight

International Standards refer to the following aspects: data protection; education;

intelligence and investigations; laboratories; results management; testing; therapeutic use

exemptions; and compliance.

The EDPB and its predecessor, the Article 29 Working Party (hereinafter the ‘Art. 29 WP’),

have attentively followed WADA activities over time, when reviewing earlier version of the

Code and its Standards. The Art. 29 WP adopted two Opinions in 2008

2

and 2009

3

on certain

provisions of the Code and its International Standards. Subsequently, in 2013, the Art. 29 WP

sent a letter to WADA

4

containing a number of observations and concerns regarding the

update of these documents. Lastly, in 2019, the EDPB provided its remarks regarding the (at

the time ongoing) revision process of the Code and its Standards in a letter addressed to the

Presidency of the Council of the EU

5

.

The EDPB recalls that the rules of the Code and its Standards have been transposed by

Member States into their national legal order, according to their respective national structure

and organisation of sport. Indeed, as signatories to the 2005 UNESCO International Anti-

Doping Convention and the Anti-Doping Convention of the Council of Europe, Member States

have to adhere to the commitments arising from the ratification of these conventions.

1

European Commission, Request for examination of the draft revised World Anti-Doping Code and the relevant

Standards referring to data protection (Ref. Ares (2024)7027092 - 03/10/2024)

2

Art. 29 WP, Opinion 3/2008 on the World Anti-Doping Code Draft International Standard for the Protection of

Privacy, adopted on 1 August 2008, WP 156.

3

Art. 29 WP, Opinion 4/2009 on the World Anti-Doping Agency (WADA) Internation al Standard for the

Protection of Privacy and Personal Information, on related provisions of the WADA Code and on other privacy

issues in the context of the fight against doping in sport by WADA and (national) anti-doping organizations

adopted on 6 April 2009, WP 162.

4

Letter sent by the Chair of the Art. 29 WP to WADA on 5 March 2013 and its Annex (Ref. Ares (2013)289160 -

05/03/2013).

5

Letter sent by the Chair of the EDPB to the Presidency of the Council of the EU on 9 October 2019 (Ref:

OUT2019-0035).