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CAS 2022 A 8682 (CAS)

Why it matters

This case clarifies the starting point of the two-year limitation period for claims related to solidarity contributions under FIFA RSTP. The CAS Sole Arbitrator held that the objective due date (30 days after player registration) triggers the limitation period, not the subjective date when the new club chooses to pay. This promotes legal certainty and procedural economy, ensuring all related claims are brought within the same timeframe.

Summary

Pyramids FC (formerly Al-Assiouty) bought player Lucas Ribamar from Athletico Paranaense for USD 2.5 million, with the transfer fee inclusive of solidarity contributions. Under FIFA rules, Pyramids had to pay solidarity contributions to the player's training clubs within 30 days of registration (by 29 August 2018). Pyramids failed to pay Botafogo until 30 March 2020, after FIFA ordered it. Pyramids then sought reimbursement from Paranaense, arguing the transfer fee included solidarity contributions. FIFA's Players' Status Chamber dismissed the claim as time-barred under the two-year limitation period (Art. 23 para. 3 RSTP). Pyramids appealed to CAS. The Sole Arbitrator confirmed that the limitation period started on 30 August 2018 (the day after the due date), not when Pyramids actually paid. Since Pyramids filed its claim on 2 November 2021, over three years later, it was time-barred. The appeal was dismissed, and Pyramids was ordered to pay CHF 3,000 towards Paranaense's legal costs.

The detail

Parties: Pyramids FC v. Athletico Paranaense & FIFA

Case number: CAS 2022 A 8682

Outcome: Appeal dismissed; FIFA PSC decision confirmed; Pyramids FC ordered to pay CHF 3,000 to Paranaense for legal costs.

Quantum: CHF 3,000

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), particularly Art. 21 (solidarity contribution), Art. 23 para. 3 (limitation period), and Annex 5; CAS Code of Sports-related Arbitration.

Issues in play: The collision was between the contractual freedom of clubs to allocate the burden of solidarity contributions and the mandatory two-year limitation period under FIFA RSTP Art. 23 para. 3. The key issue was whether the limitation period started from the due date for solidarity payment (30 days after registration) or from the date the new club actually paid a training club.

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

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