Ruud van Nistelrooy may face action for confronting referee Anders Frisk after Holland’s Euro 2004 defeat to Portugal.
Van Nistelrooy was angered by what he perceived to be an inpartial performance by referee Anders Frisk.
If Frisk reports the incident to Uefa, disciplinary charges against Van Nistelrooy are likely.
The Dutch striker accused Frisk of ruling “everything in favour of Portugal” and of being a “home whistler”.
He added: “Every 50-50 situation went for them, but we cannot do anything about it.
“They had the better chances, it’s tough losing like this but we had problems playing our own game.”