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CAS 2022 A 9072 (CAS)

Why it matters

This case clarifies the interaction between FIFA disciplinary proceedings and national insolvency regimes, specifically Portuguese Special Revitalization Proceedings (PER). It establishes that a club subject to a homologated payment plan under PER is legally unable to comply with a FIFA decision to pay a debt, triggering the exception under Article 55 FDC and Article 24bis RSTP. The award reinforces that disciplinary proceedings must be closed while the plan is in force, preventing sanctions like transfer bans or fines.

Summary

Leixões, a Portuguese football club, initiated a Special Revitalization Proceeding (PER) under Portuguese law in July 2020. In July 2021, FIFA's Dispute Resolution Chamber ordered Leixões to pay EUR 100,794.52 in training compensation to Barcelona SC. Leixões did not pay, and Barcelona requested disciplinary action. Initially, FIFA closed disciplinary proceedings because Leixões was undergoing insolvency proceedings. However, after the PER was homologated and closed in November 2021, FIFA reopened the case and imposed sanctions: a fine of CHF 15,000 and a threat of a transfer ban. Leixões appealed to CAS, arguing that the PER payment plan, approved before the DRC decision, prevented it from paying Barcelona without violating Portuguese law (which prohibits favoring one creditor). The Sole Arbitrator found that the PER qualifies as an insolvency-related event under Article 55 FDC and Article 24bis RSTP, and that Leixões was legally unable to comply with the DRC decision because paying Barcelona would breach the payment plan and expose Leixões to criminal sanctions. The CAS upheld the appeal, set aside the FIFA Disciplinary Committee decision, and ordered that disciplinary proceedings remain closed while the PER payment plan is in force. The award also ordered Barcelona and FIFA to share the arbitration costs and pay Leixões a contribution to its expenses.

The detail

Parties: Leixões Sport Club Futebol SAD v. Barcelona SC & FIFA

Case number: CAS 2022 A 9072

Outcome: Leixões' appeal upheld; FIFA Disciplinary Committee decision set aside; disciplinary proceedings closed while payment plan under Second PER is in force.

Applicable law: FIFA Disciplinary Code (2019 edition), FIFA Regulations on the Status and Transfer of Players (RSTP), Portuguese Insolvency Code, CAS Code of Sports-related Arbitration

Issues in play: Conflict between FIFA's disciplinary rules requiring compliance with DRC decisions and Portuguese insolvency law (PER) that prohibits a debtor from favoring one creditor over others, raising the question of whether a club undergoing a Special Revitalization Proceeding is legally unable to comply with a FIFA order.

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

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