CAS 2020 A 7150
CAS · Football (FIFA / CAS) · Switzerland · 1 Feb 2021
Why it matters
This case clarifies the strict application of FIFA's protection of minors rule (Article 19 RSTP). It sets a high evidentiary standard for the 'non-football reasons' exception, requiring the player to prove beyond reasonable doubt that football was not even one of the reasons for the family's relocation. The decision reinforces FIFA's policy against circumvention of transfer restrictions for minors.
Summary
Ryoga Fujita, a Japanese minor footballer, moved to Barcelona with his father in June 2019. His father claimed the move was for a business venture (a real estate company) and not for football. However, the father had emailed a law firm in 2018 stating he wanted a visa so his son could play football in Spain. The Spanish club Sant Cugat FC sought an International Transfer Certificate (ITC) under the exception in Article 19.2(a) of the FIFA Regulations on the Status and Transfer of Players (RSTP), which allows transfers of minors if the family moves for non-football reasons. FIFA's Sub-Commission refused the ITC, finding the move was likely football-motivated. The player appealed to CAS. The Sole Arbitrator applied a 'beyond reasonable doubt' standard, requiring the player to prove football was not even an accessory reason. The Arbitrator found multiple inconsistencies: the father's 2018 email, the company being incorporated five months after the move, the mother staying in Japan, and the lack of evidence of a genuine business. The appeal was dismissed, and the ITC was denied.
The detail
Parties: Ryoga Fujita v. FIFA
Case number: CAS 2020 A 7150
Outcome: Appeal dismissed; FIFA's decision refusing the International Transfer Certificate (ITC) for the minor player confirmed.
Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), particularly Article 19.2(a); Swiss law subsidiarily.
Issues in play: The case concerned the exception under Article 19.2(a) RSTP for international transfers of minors when the move is for non-football reasons. The burden of proof was on the player to show the transfer was not motivated by football.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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