CAS 2024 A 10414
CAS · Football (FIFA / CAS) · Switzerland · 22 Jan 2025
Why it matters
This case clarifies that a party cannot extend the 21-day CAS appeal deadline by requesting clarifications or reconsideration from FIFA. The Panel held that the public interest in finality and procedural certainty outweighs an appellant's private interest in seeking further explanations. It reinforces strict adherence to appeal deadlines in CAS proceedings.
Summary
Alejandro Gustavo Camano Tolosa, a FIFA pre-2015 licensed football agent, attempted to obtain a FIFA agent license under the new FFAR via the 'legacy path' and 'national law path'. He faced technical issues registering on the FIFA Agent Platform and missed the 30 September 2023 deadline for the legacy path. FIFA rejected his national law path application on 1 November 2023 because he did not hold a French license. On 17 January 2024, FIFA confirmed the legacy path window had closed. On 20 February 2024, FIFA reiterated its position. Camano appealed the 20 February letter to CAS on 12 March 2024. The Panel found that the 1 November 2023 and 17 January 2024 letters were appealable decisions, and the 20 February letter merely repeated them. Since the appeal was filed more than 21 days after those earlier decisions, it was inadmissible. The Panel emphasized that requesting further clarifications does not extend the appeal deadline, and dismissed the appeal without examining the merits.
The detail
Parties: Alejandro Gustavo Camaño Tolosa v. FIFA
Case number: CAS 2024 A 10414
Outcome: Appeal dismissed as inadmissible; Appellant bears full arbitration costs; each party bears own legal fees.
Applicable law: FIFA Football Agent Regulations (FFAR); CAS Code of Sports-related Arbitration (2023 edition); Swiss law
Issues in play: The case concerned whether FIFA's 20 February 2024 letter was an appealable 'decision' or merely a confirmation of earlier decisions, and whether the appeal was timely under the 21-day deadline.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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