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CAS 2016A4573 Kees Ploegsma v PFC CSKA Moscow (CAS)

Why it matters

This case clarifies that oral agency contracts in football can be valid under Swiss law even if they do not comply with FIFA's written form requirements, as the FIFA PAR does not prescribe invalidity as a sanction. It also establishes that the two-year limitation period under FIFA PAR can be interrupted by a debtor's acknowledgment of debt, applying Swiss law subsidiarily to fill a lacuna in the regulations.

Summary

Kees Ploegsma, a Dutch football agent, helped transfer Japanese player K. from VVV-Venlo to PFC CSKA Moscow in 2009-2010. Ploegsma and CSKA orally agreed on a EUR 750,000 commission, payable in instalments. CSKA later asked Ploegsma to sign an agreement with Fileca Trading Limited, a BVI company, which mirrored the payment terms. Fileca paid the first two instalments (EUR 500,000) but failed to pay the remaining EUR 250,000. Ploegsma filed a claim with FIFA, which rejected it because there was no written contract as required by the FIFA Players' Agents Regulations (PAR). Ploegsma appealed to CAS. The CAS panel found that under Swiss law, contracts do not need a specific form unless required by law, and the FIFA PAR does not invalidate oral agreements; it only lists sanctions for non-compliance. The panel also held that the two-year prescription period under FIFA PAR was interrupted when CSKA's sporting director acknowledged the debt via email in May 2013, starting a new limitation period. Thus, Ploegsma's claim was timely. The panel ordered CSKA to pay the outstanding EUR 250,000 plus interest.

The detail

Parties: CAS 2016A4573 Kees Ploegsma v PFC CSKA Moscow

Outcome: Appeal upheld; CSKA Moscow ordered to pay Ploegsma EUR 250,000 plus interest.

Quantum: EUR 250,000

Applicable law: FIFA Players' Agents Regulations (2008 edition); Swiss Code of Obligations (subsidiary)

Issues in play: Whether an oral agency contract is valid despite FIFA PAR requiring written form; whether the two-year prescription period under FIFA PAR can be interrupted by acknowledgment of debt under Swiss law.

Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗

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