CAS 2024/A/10795 Fodboldalliancen AC Horsens A/S & Tudor-Stefan Cocu v. FIFA
CAS · Football (FIFA / CAS) · Switzerland · 5 May 2025
Why it matters
This award reinforces FIFA's strict protection of minors in international transfers, even within the EU/EEA. It clarifies that clubs must provide not only adequate football training but also a structured, in-person academic education. Relying solely on online education is insufficient. The decision also confirms that the training category system (Annexe 4) is a key objective measure for assessing football education standards.
Summary
The case concerns a 16-year-old Romanian footballer, Tudor-Stefan Cocu, who sought to transfer from FC Player (Romania) to AC Horsens (Denmark). Under FIFA's RSTP Article 19, international transfers of minors are generally prohibited unless an exception applies. The relevant exception (Article 19.2(b)) allows transfers of players aged 16-18 within the EU/EEA if the new club meets four requirements: (iii) adequate football education/training in line with highest national standards, (iv) academic/vocational education enabling a non-football career, (v) proper accommodation, and (vi) arrangements for the player's welfare. AC Horsens applied to FIFA's Players' Status Chamber (PSC) for prior approval. The PSC rejected the application, finding that AC Horsens did not meet the football education requirement because it was classified in training category III (second lowest) by the Danish FA, not the highest category. AC Horsens and the player appealed to CAS. The CAS Sole Arbitrator upheld the PSC decision. He found that while the accommodation was excellent, the club failed on two key points: (1) football education: AC Horsens was not among the elite Danish clubs in youth development, as shown by its category III classification and the DBU's own ranking; (2) academic education: the club only offered online schooling, which the arbitrator deemed inadequate for a minor moving to a new country, as it deprived him of in-person interaction, language acquisition, and social integration. The appeal was dismissed, and the transfer was blocked. The award was issued on 5 May 2025.
The detail
Parties: CAS 2024/A/10795 Fodboldalliancen AC Horsens A/S & Tudor-Stefan Cocu v. FIFA
Outcome: Appeal dismissed; FIFA PSC decision to reject the international transfer of the minor player confirmed.
Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), Article 19 (protection of minors) and Annexe 4; CAS Code of Sports-related Arbitration
Issues in play: The exception for intra-EU transfers of minors (Article 19.2(b) RSTP) requires the new club to provide football education in line with highest national standards and adequate academic education. The case examined whether AC Horsens met these requirements.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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