CAS 2023/A/10051 Bayelsa United FC v. Maghreb Association Sportive & FIFA
CAS · Football (FIFA / CAS) · Switzerland · 28 May 2025
Why it matters
This case clarifies the procedural limits of CAS's de novo review under the FIFA Clearing House Regulations. It establishes that a club cannot raise a just-cause termination defense for the first time on appeal if it failed to present documentation during the EPP review process. The decision reinforces that the FIFA general secretariat's role is administrative, not adjudicative, and that complex disputes must be referred to the DRC before appeal.
Summary
Bayelsa United FC appealed a FIFA decision requiring it to pay USD 37,232.88 in training compensation to Maghreb Association Sportive (MAS) for the international transfer of player Saviour Egah. The player had terminated his contract with MAS, claiming just cause due to unpaid salaries and a signing fee. Bayelsa argued that under Article 2(2) Annex 4 RSTP, training compensation is not due if the former club terminates without just cause (or the player terminates with just cause). However, the player had withdrawn his FIFA claim after settling with MAS, so no tribunal had ruled on whether the termination was with just cause. During the FIFA Clearing House process, Bayelsa was invited to submit documentation relevant to training rewards but did not do so. The CAS Sole Arbitrator held that under the FCHR, the FIFA general secretariat has no competence to decide contractual termination disputes; its role is limited to processing EPPs. Since Bayelsa failed to raise the just-cause issue during the EPP review, CAS could not consider it on appeal. The appeal was dismissed, and the allocation statement confirmed.
The detail
Parties: CAS 2023/A/10051 Bayelsa United FC v. Maghreb Association Sportive & FIFA
Outcome: Appeal dismissed; FIFA's determination and allocation statement confirmed; Bayelsa United FC ordered to pay CHF 1,500 to Maghreb Association Sportive for legal costs.
Quantum: USD 37,232.88 (training compensation) plus CHF 1,500 (costs)
Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), FIFA Clearing House Regulations (FCHR), CAS Code of Sports-related Arbitration, Swiss law
Issues in play: The collision was between the exception to training compensation under Article 2(2) Annex 4 RSTP (no compensation if former club terminates without just cause or player terminates with just cause) and the procedural limitation that CAS cannot review issues not raised before FIFA's general secretariat under the FCHR.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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