CAS 2020 A 7353
CAS · Football (FIFA / CAS) · Switzerland · 1 Jun 2021
Why it matters
This case clarifies that for international transfers of minors under Article 19(2)(b) RSTP, the 'former association' must be a FIFA member national association, not a regional federation. It reinforces strict compliance with the protection of minors principle and confirms that a player moving from a non-EU/EEA country cannot benefit from the intra-EU exception.
Summary
Eldar Taghizada, an Azerbaijani minor, played for a Spanish club registered with the Catalan Football Federation (FCF), a regional body under RFEF. He then signed with French club Clermont Foot. Clermont sought FIFA approval for an international transfer under Article 19(2)(b) RSTP (intra-EU exception). RFEF disputed, claiming the player was not registered with them. FIFA's Disciplinary Committee found RFEF had de facto registered the player, but FIFA's Players Status Sub-Committee declared the transfer request inadmissible because the player was not formally registered with RFEF. The CAS Panel upheld this decision, reasoning that only national associations (FIFA members) can be 'former associations' for international transfers. Since the player was never registered with RFEF, and his original registration was in Azerbaijan (non-EU/EEA), the intra-EU exception did not apply. The Panel emphasized strict interpretation of Article 19 to protect minors and prevent circumvention.
The detail
Parties: & 7354 Eldar Elxan Oglu Taghizada & Clermont Foot 63 SASP v. FIFA & RFEF
Case number: CAS 2020 A 7353
Outcome: Appeals dismissed; FIFA's decision that the minor transfer request was inadmissible confirmed.
Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), Article 19 (protection of minors)
Issues in play: Whether a player registered only with a regional federation (FCF) is considered registered with the national association (RFEF) for purposes of an international transfer under Article 19(2)(b) RSTP.
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