CAS 2023 A 10208
CAS · Football (FIFA / CAS) · Switzerland · 27 Feb 2025
Why it matters
This case clarifies the starting point of the two-year limitation period under FIFA Match Agent Regulations for claims between match agents. The CAS held that the prescriptive period begins when the claimant becomes objectively aware of the facts giving rise to the dispute, not when damages are quantified in a later award. It reinforces that a party must act promptly once it knows of potential liability, even if the exact amount is uncertain.
Summary
Evgeni Marinov, a Bulgarian FIFA match agent, organized a friendly match between Cameroon and Turkmenistan scheduled for 9 June 2019. The contract was signed on 15 May 2019 between Marinov and Mr Kamga (Cameroon's agent). On 18 May 2019, the Football Federation of Turkmenistan (FFT) cancelled the match. Kamga later sued Marinov before FIFA, and in CAS 2021/A/8368, Marinov was ordered to pay EUR 13,700 compensation. Marinov then sought reimbursement from Kenan Kurtes (Turkmenistan's agent), alleging Kurtes forged the FFT's initial acceptance letter. Marinov filed a claim with FIFA in September 2023, but FIFA's Players' Status Chamber (PSC) declared it inadmissible as time-barred under Article 22.3 MAR, which requires claims to be brought within two years of the facts giving rise to the dispute. Marinov appealed to CAS, arguing the limitation period only started when the CAS award quantified his damages on 4 September 2023. The CAS Sole Arbitrator dismissed the appeal, holding that the prescriptive period began when Marinov became aware of the alleged forgery, which occurred during the earlier PSC proceedings (before 17 August 2021). Since Marinov filed his claim on 20 September 2023, it was beyond the two-year limit. The award confirms that the limitation period runs from objective knowledge of the facts, not from the final quantification of damages.
The detail
Parties: Evgeni Marinov v. FIFA & Kenan Kurtes
Case number: CAS 2023 A 10208
Outcome: Appeal dismissed; FIFA PSC decision confirmed; Appellant ordered to pay CHF 1,000 to Second Respondent for legal costs.
Quantum: CHF 1,000
Applicable law: FIFA Match Agent Regulations (MAR), Swiss law subsidiarily
Issues in play: The two-year limitation period under Article 22.3 MAR versus the Appellant's argument that the prescriptive period started only when the CAS award quantified his damages.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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