The announcement that UTMB Mont-Blanc will significantly expand anti-doping controls during the 2026 race week is, at first sight, very good news. More testing, independent sample collection and a greater emphasis on athlete education should be welcomed in a rapidly professionalising sport.
Yet the UTMB anti-doping programme raises a fascinating question that deserves more attention: who actually has the authority to regulate and sanction athletes in this system?
UTMB is not an International Federation, a National Anti-Doping Organization or a World Anti-Doping Code Signatory. In fact, UTMB’s own Anti-Doping Rules explicitly acknowledge this:
“UTMB, while not being a signatory to the Code, has voluntarily decided to accept and adopt the provisions of the Code…”
The Rules go even further, recognising that because UTMB is not a Code Signatory, certain operational mechanisms of the World Anti-Doping Code may be “inapplicable or not fully enforceable”.
This distinction is important.
Under the World Anti-Doping Code, an Anti-Doping Organization is WADA or a Code Signatory responsible for initiating, implementing or enforcing part of the doping-control process. UTMB does not fall into that category merely because it has chosen to reproduce the Code in its own regulations.
So how can the system work?
The answer appears to be contractual jurisdiction rather than jurisdiction derived from the World Anti-Doping Code.
By registering for a UTMB event, an athlete expressly agrees to be bound by the UTMB Anti-Doping Rules, accepts UTMB’s authority to conduct in-competition and out-of-competition testing, and accepts the possibility of sanctions. UTMB has then delegated most of the operational programme to the International Testing Agency.
This distinction is essential. ITA does not give UTMB jurisdiction over athletes. UTMB obtains that jurisdiction through the conditions under which athletes enter its events; ITA provides the expertise and operational independence required to implement the programme.
There is nothing inherently improper about such an arrangement. ITA has previously provided anti-doping services to organisations that were not yet World Anti-Doping Code Signatories. A private sports organiser can establish rules governing participation in its events, provided that athletes validly agree to those rules and appropriate procedural safeguards are respected.
UTMB has gone considerably further than simply organising occasional drug tests. Its Anti-Doping Rules closely reproduce the architecture of the World Anti-Doping Code: the eleven anti-doping rule violations, strict liability, the WADA Prohibited List, Therapeutic Use Exemptions, whereabouts, the Athlete Biological Passport, results management and Code-based periods of ineligibility.
First-instance anti-doping cases are referred to an International Hearing Panel, while decisions involving what UTMB defines as International-Level Athletes or International Events may be appealed to the Court of Arbitration for Sport. CAS jurisdiction itself is not necessarily problematic: CAS rules allow sports-related disputes to be submitted to arbitration where the parties have agreed to this through a contract or applicable regulations.
The more difficult issue concerns the reach of a UTMB sanction.
Within the UTMB ecosystem, the position seems straightforward. An athlete who accepts UTMB’s rules can be disqualified, lose prize money and be prevented from competing in future UTMB events.
The position outside UTMB is more nuanced.
A sanction issued by a World Anti-Doping Code Signatory normally has automatic effects throughout the Code system. UTMB, however, is not a Signatory. Article 15.3 of the World Anti-Doping Code specifically addresses decisions made by non-Signatory bodies. Such a decision can be implemented by Code Signatories if they determine that the body acted within its authority and that its anti-doping rules are otherwise consistent with the Code.
Therefore, a UTMB sanction may ultimately have consequences outside the UTMB World Series, but this should not be confused with UTMB itself possessing universal anti-doping jurisdiction.
This makes some of UTMB’s public language potentially misleading. Its anti-doping information states that a sanction may range from a warning to a lifetime ban “from all sport”, and suggests that an athlete banned in trail running may also be prohibited from participating in another sport. Such an outcome may indeed follow if the relevant Code Signatories recognise and implement the decision, but UTMB, as a non-Signatory commercial organiser, cannot simply create worldwide Code ineligibility by itself.
There is another interesting issue. UTMB’s Rules define athletes competing in UTMB events as “International-Level Athletes”. Under the World Anti-Doping Code, however, International-Level Athletes are normally defined by the relevant International Federation. UTMB is not an International Federation. The definition may be perfectly functional within UTMB’s contractual regulatory system, but it should not be confused with international-level status within the formal WADA framework.
This becomes particularly relevant as UTMB expands testing beyond elite podium contenders to age-group, recreational and younger participants. Testing a professional athlete competing for substantial prize money and testing a recreational runner whose primary ambition is simply to finish the race are not necessarily the same regulatory problem. Proportionality, TUE requirements, out-of-competition jurisdiction, privacy, whereabouts obligations and access to affordable legal remedies deserve careful consideration.
None of this diminishes the value of what UTMB is trying to achieve. On the contrary, entrusting testing and results management to an independent and highly experienced organisation such as ITA is arguably much better than having a commercial race organiser investigate and adjudicate doping cases itself.
But precision matters in anti-doping.
There is a significant legal and governance distinction between being aligned with the World Anti-Doping Code and being a recognised Signatory governed by the World Anti-Doping Code.
UTMB represents an intriguing new model: a powerful private sports-event company voluntarily importing the WADA regulatory framework and using contractual participation rules to create what is, in practical terms, an international anti-doping system.
That model may prove highly effective. It may even become increasingly common as commercially organised sports and competition circuits grow outside traditional federation structures.
But it also raises an important question for the future of global anti-doping:
If a private commercial organiser can reproduce the World Anti-Doping Code, appoint an independent agency to test athletes, create an international testing pool, impose Code-equivalent sanctions and send appeals to CAS, at what point does it effectively become an anti-doping regulator — and who then regulates the regulator?
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