Mark Roberts celebrates his cheeky "goal"
Mark Roberts, from Liverpool, who is known as the UK's most notorious streaker, appeared at Glasgow Sheriff Court.
SFA spokesman Andy Mitchell described the fine as "deplorable" and said Roberts should have been given more than "a slap on the wrist".
Real Madrid fan, Joe Beriro, who ran onto the pitch wearing a kilt, was admonished after apologising for his behaviour.
Roberts of Toxteth in Liverpool, who streaked onto the pitch and kicked the ball into the Bayer Leverkusen goal, was warned that his behaviour could have landed him in jail.
He has performed 211 streaks at major events throughout the UK.
He became notorious after streaking during the general election, on Richard and Judy's This Morning show, and at Wimbledon and Crufts.
Last year, his antics landed him in court after he streaked at half-time in the FA Cup Final at the Millennium Stadium.
A court in Cardiff banned from football matches for five years after streaking during the match between Liverpool and Arsenal.
No malice intended
He admitted committing a breach of the peace at Wednesday's Champions League final in which Real Madrid beat Bayer Leverkusen.
His solicitor Andrew Gallen said Roberts was "something of a celebrity" for raising money for charity by streaking.
Sheriff Taylor told Roberts he commended his desire to raise money for charity, but not his methods.
He said: "Although some people at the match may have been amused by your actions, others would have been offended."
The sheriff warned Roberts that if he continued to streak the courts would eventually become "fed up" with him and might send him to prison.
Outside the court Roberts described his naked exploits as "a bit of harmless fun".
The Scottish Football Association's director of communications, Andy Mitchell, said he doubted whether or not the Cardiff court had the power to ban Roberts from matches in Scotland.
He said the SFA tried to keep a record of everyone who was banned from football grounds across the UK but he admitted it was "very difficult to cross-check ticket purchases with miscreants".
Slap on the wrist
Mr Mitchell went on to describe the £200 fine as "deplorable" for such an offence that occurred before a worldwide television audience.
"If someone chooses to disrupt an event then we feel that there should be a more heavy punishment than a slap on the wrist," he added.
The two incidents marred an otherwise blemish-free night, raising hopes that Scotland's bid to co-host Euro 2008 will be successful.
Uefa chief executive Gerhard Aigner praised Glasgow but referred to the pitch incursions when he said: "It didn't spoil things but it was the one little criticism I would have."
Officials at Glasgow Sheriff Court rushed through the case against 44-year-old Beriro, a nightclub owner from Gibraltar to enable him to catch his flight home from Glasgow Airport.