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CAS 2021 A 7694 (CAS)

Why it matters

This case clarifies the burden of proof for a dual-national coach seeking to establish an international dimension under FIFA RSTP Article 22(c). It confirms that mere expiry of identification documents does not prove loss of citizenship; the coach must provide conclusive evidence of renunciation or revocation under national law. The award also reinforces that the relevant time for assessing nationality is when the dispute arises, and that a coach's subjective intent or use of a foreign passport is insufficient to override objective citizenship status.

Summary

Tamás Bódog, a Hungarian-born football coach who also acquired German nationality, signed an employment contract with Hungarian club Honvéd FC. The contract included a clause allowing termination if the team was in the relegation zone for five consecutive matches. On 6 December 2020, Honvéd terminated the contract, claiming the condition was met. Bódog filed a claim with FIFA's Players' Status Committee (PSC) seeking compensation for termination without just cause. The FIFA PSC declared the claim inadmissible, finding no international dimension because Bódog held Hungarian citizenship and the dispute was therefore domestic. Bódog appealed to the CAS. The central issue was whether the dispute had an international dimension under Article 22(c) RSTP, which requires that the coach and club have different nationalities. Bódog argued he was solely German, as his Hungarian documents had expired and he had lived in Germany. He also claimed he was hired as a German citizen, pointing to his use of a German passport and a work certificate referencing his German passport number. Honvéd and FIFA contended Bódog remained a Hungarian citizen under Hungarian law, which provides that citizenship is lost only by formal renunciation or revocation, not by document expiry. The CAS Sole Arbitrator applied Hungarian law and found that Bódog had not proven loss of Hungarian citizenship. The Hungarian Citizenship Act requires a formal renunciation procedure, which Bódog had not undertaken. The expiry of his Hungarian passport and identity card did not terminate his citizenship. The Arbitrator also rejected Bódog's argument that he was hired as a German, noting that the contract did not mention his nationality and that the club's internal datasheet listed him as 'Hungarian-German'. The work certificate was insufficient to override the objective fact of dual citizenship. Since Bódog was a Hungarian national at the relevant time, the dispute lacked international dimension, and FIFA PSC correctly declined jurisdiction. The appeal was dismissed, and the FIFA decision upheld.

The detail

Parties: Tamás Bódog v. Honvéd FC & FIFA

Case number: CAS 2021 A 7694

Outcome: Appeal dismissed; FIFA PSC decision upheld; claim inadmissible for lack of international dimension.

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), Swiss Civil Code, Hungarian Law on Citizenship

Issues in play: Hungarian citizenship law vs. FIFA's international dimension requirement; whether dual-national coach could establish international dimension by proving loss of Hungarian citizenship or hiring as German.

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

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