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CAS 2023 A 10009 (CAS)

Why it matters

This case clarifies the strict procedural requirements under the FIFA Clearing House Regulations for submitting waivers of training compensation. It confirms that failure to upload a waiver during the EPP review process, even if the waiver is valid, results in the waiver being disregarded. The decision also underscores the importance of joining all potentially interested parties (like the training club) as respondents in CAS appeals, as failure to do so can lead to dismissal of the appeal.

Summary

FK Liepāja, a Latvian football club, registered Ghanaian player Ibrahim Issah in March 2023. Under FIFA's RSTP, this triggered training compensation obligations to Dreams FC, the player's former club. The FIFA Clearing House generated an Electronic Player Passport (EPP) and opened a review process. FK Liepāja failed to upload a waiver from Dreams FC (dated January 2023) within the prescribed deadline. FIFA issued a final decision ordering FK Liepāja to pay EUR 108,410.96 in training compensation. FK Liepāja appealed to CAS, arguing that the waiver was valid and that FIFA should have considered it under Article 10.2 FCHR. The Sole Arbitrator dismissed the appeal primarily because FK Liepāja did not join Dreams FC as a respondent, depriving Dreams of the opportunity to contest the waiver's validity. The Arbitrator held that Dreams had a direct and legitimate interest in the dispute, and without joining them, the appeal could not succeed. The decision confirms that procedural deadlines under the FCHR are strict and that parties must ensure all interested parties are included in CAS proceedings.

The detail

Parties: FK Liepāja v. FIFA

Case number: CAS 2023 A 10009

Outcome: Appeal dismissed; FIFA's decision requiring FK Liepāja to pay EUR 108,410.96 training compensation to Dreams FC confirmed.

Quantum: EUR 108,410.96

Applicable law: FIFA Clearing House Regulations (October 2022 edition), FIFA Regulations on the Status and Transfer of Players (RSTP), Swiss law subsidiarily

Issues in play: Procedural rules on timely submission of waivers under FCHR Article 9.7 vs. substantive contractual freedom and pacta sunt servanda under Swiss law.

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

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