Caoimhin Kelleher recently commented that referees could help better protect goalkeepers. What actually are the laws of the penalty box?
Header image: Alamy via The Sun
On a cold January night at London Stadium, the penalty area became a place of argument rather than certainty. West Ham United were clinging to a lead against Nottingham Forest, two clubs staring anxiously at the bottom end of the Premier League table. The tension was already thick enough to distort judgement when a late free-kick dropped into the box.
Alphonse Areola did what modern goalkeepers are trained, coached and expected to do. He came. He committed. He went to punch. In the collision that followed, Morgan Gibbs-White took a blow to the face. VAR intervened. The referee went to the screen. A penalty was awarded. Forest scored. The stadium reacted in disbelief.
What followed was less a dispute about one decision than a wider sense of confusion. West Ham midfielder Tomáš Souček called the call ‘a joke’. Manager Nuno Espírito Santo, himself a former goalkeeper, admitted he 'didn’t quite understand' how Areola could stop his momentum once committed to the action. Areola, visibly bemused, appeared unsure who had even fouled whom. This was not outrage so much as disorientation.
Moments like this expose something deeper than a single refereeing judgement. They reveal a growing fault line in the modern game: the widening gap between what goalkeepers are asked to do, and how their actions are ultimately judged.
The penalty against Areola was not born of recklessness or malice. It emerged from a split-second decision made under pressure, noise and expectation, then assessed slowly, clinically, and without the context of consequence. The question, then, is not simply whether the referee was ‘right’ or ‘wrong’. It is a more uncomfortable one: what rights does a goalkeeper actually have when defending their own box – and what precedent does a decision like this set for those who follow?
To answer that, it is necessary to step beyond the incident itself and into the laws, interpretations and evolving ecosystem that now governs the most exposed position on the pitch. To understand why incidents like this keep occurring, it helps to look at what the modern game now demands of its goalkeepers. Coming for crosses is no longer framed as bravery or initiative; it is treated as competence.
Goalkeepers are coached to dominate their penalty area, to punch through traffic if a clean catch is not possible, and to resolve danger decisively rather than passively. A goalkeeper who hesitates, who stays rooted to their line as the ball drops into a crowd, is now more likely to be criticised than one who commits and gets it wrong.
This is the environment Alphonse Areola was operating in. The delivery into the box was not slow or isolated. It was contested, crowded, and urgent. Choosing to come for the ball was not an optional flourish, but a professional expectation shaped by years of tactical evolution. The modern goalkeeper is expected to act early, loudly and physically – to impose themselves on space before an opponent can. That expectation has consequences.
Once a goalkeeper leaves their line and commits to an aerial intervention, there is little room for adjustment. Momentum carries them forward. Arms are raised not to strike, but to clear space and reach the ball. Decisions are made in fractions of a second, guided by instinct, training and the knowledge that inaction is often punished more harshly than error.
This is where the disconnect begins to form. Goalkeepers are encouraged to be proactive, yet increasingly judged through a lens that isolates outcome from context. A punch that arrives a fraction late, or makes incidental contact after the ball has been played, can now be reframed not as a failed solution, but as a punishable offence. The action is scrutinised without the weight of expectation that produced it. In Areola’s case, the action itself was familiar.
What felt new was the severity of the consequence. The decision suggested that the margin for error in the air – once understood as an occupational hazard of goalkeeping – is narrowing. That shift forces a difficult question onto those tasked with defending the box: if decisive intervention carries this level of risk, what behaviour is the game actually incentivising?
Before answering that, it is worth returning to the framework that ultimately governs these moments – the Laws of the Game themselves – and how they are applied to goalkeepers in situations like this. If the emotional logic of the moment feels murky, the legal one is, at least on paper, far clearer. Under Law 12 of the IFAB Laws of the Game, a direct free kick – and therefore a penalty if committed inside the area – is awarded if a player “strikes or attempts to strike an opponent in a manner considered by the referee to be careless, reckless or using excessive force.”
Intent is not required. Accidental contact does not exempt the action. The judgement rests on the manner of the challenge, not the motivation behind it. In that context, the decision against Areola becomes easier to understand, if no less contentious. A raised arm that makes contact with an opponent’s head can be interpreted as striking. If the referee deems that action careless – defined in the law as showing “a lack of attention or consideration” – the threshold for a penalty is met.
Crucially, the protections often associated with goalkeepers are narrower than commonly assumed. The Laws are explicit that a goalkeeper “cannot be challenged by an opponent when in control of the ball with their hand(s)/arm(s).” That protection applies only once control has been established. It does not extend to attempted punches, aerial claims, or moments of shared contest before possession is secured. In those situations, goalkeepers are judged as any other player would be.
Their unique privilege – the use of their hands – does not come with a corresponding exemption from responsibility. From a legal standpoint, the act of attempting to clear danger does not outweigh the outcome if that action endangers an opponent.
This is where the fault line widens. The Laws are designed to prioritise safety and consistency. But they are increasingly applied in a game that asks goalkeepers to operate at speed, in traffic, and with authority. VAR, with its ability to slow moments down and isolate points of contact, further sharpens that tension. What unfolds in real time as a necessary intervention can, on review, be reclassified as a punishable act.
The law, then, is not ambiguous – but its application sits uneasily alongside the expectations placed on modern goalkeepers. They are encouraged to dominate the air, yet judged harshly when that dominance carries physical consequence. The question is no longer whether the law has been followed, but whether the framework it provides is fully compatible with the role goalkeepers are now required to perform. If the law explains how the decision can be made, it does not settle the deeper question of whether the framework serves the modern goalkeeper particularly well.
There is a strong case, made quietly but consistently within the game, that goalkeepers require a degree of contextual leeway when operating in the air. They are asked to act in the most congested area of the pitch, often with bodies moving unpredictably beneath them and the ball arriving at speed. Unlike outfield players, they cannot pull out of a challenge without conceding territory, pressure, or a clear scoring opportunity. Hesitation is not neutral; it is punished.
From this perspective, incidents like Areola’s feel less like individual errors and more like structural traps. Goalkeepers are trained to commit early, to impose themselves on space before an attacker can. Once committed, they have limited capacity to adjust their body position or momentum. Contact, while not inevitable, is a recognised occupational risk – one historically absorbed by the game as part of the role’s physical reality.
VAR complicates this further. Slow motion dissects actions that were never designed to be precise. Frames freeze limbs mid-swing, stripping movement of context and compressing instinct into something that can resemble intent. In doing so, the technology risks judging outcomes rather than decisions, and consequences rather than necessity. The goalkeeper’s action may be technically lawful in real time, yet rendered punishable once slowed, isolated and replayed.
Those who argue for greater goalkeeper leeway are not asking for immunity. They are asking whether the game still understands the conditions it places goalkeepers in, and whether its systems of judgement have kept pace with those demands. Yet the counter-argument is equally compelling – and harder to dismiss.
The Laws of the Game are explicit in their priority: player safety. A blow to the head is treated seriously regardless of position or intention. From this angle, the goalkeeper’s privilege of using their hands is not a mitigating factor but an added responsibility. Maybe, with greater power comes greater duty of care. D0es allowing goalkeepers latitude simply because they are ‘doing their job’ risk normalising dangerous contact in the most volatile area of the pitch?
This is why incidents like the one involving Areola feel so unresolved. The law is applied correctly, yet the outcome still jars. Not because it is wrong, but because it exposes a mismatch between expectation and consequence. Goalkeepers are encouraged to be assertive, proactive and physically commanding, yet are increasingly penalised when those qualities intersect with modern interpretations of safety and control. The result is a role caught in transition.
The historical image of the goalkeeper as aerial enforcer has not fully disappeared, but the conditions that once supported it have. What remains is a position asked to solve problems decisively, while operating under ever-narrowing margins for error.
Seen in that light, the penalty at London Stadium was not an aberration. It was a symptom. A moment where the laws, the technology and the expectations of the position briefly collided – leaving confusion in their wake. Until those elements are better aligned, goalkeepers will continue to step into these moments carrying the weight of contradiction. Asked to dominate, yet judged for dominance. Expected to act, yet punished for the consequences of action.
In the modern penalty area, certainty is rare. For those tasked with defending it, the rules have never felt more exacting.
