CAS 2025 A 11689
CAS · Football (FIFA / CAS) · Switzerland · 18 May 2026
Why it matters
This case clarifies the procedural requirement of passive mandatory joinder in CAS appeals: an appellant must name all necessary respondents (including the buying club) in its statement of appeal, or the appeal will be dismissed. It also highlights the administrative function of FIFA's Clearing House in assessing training rewards, and the limits of CAS's power to join parties after the appeal deadline.
Summary
AS Saint Etienne (ASSE) transferred player Mathis Amougou to Chelsea FC for €15 million. The transfer agreement stated that solidarity contributions to third clubs were included in the fee and Chelsea could deduct them. During the FIFA Clearing House review, Chelsea uploaded the agreement as a waiver of training rewards. ASSE's employee then confirmed via TMS that ASSE waived training compensation and solidarity for this transfer. FIFA's General Secretariat determined that no solidarity contribution was due to ASSE because it was included in the transfer fee. ASSE appealed to CAS, arguing the waiver was submitted in error and that FIFA misinterpreted the agreement. However, ASSE only named FIFA as respondent, not Chelsea FC. FIFA raised a preliminary objection that Chelsea was a necessary co-respondent. The Sole Arbitrator agreed: under Swiss law and CAS jurisprudence, an appeal must be dismissed if it affects the rights of a third party not named as respondent. Chelsea FC was informed but chose not to intervene. The CAS Code does not allow the appellant to add a respondent after the appeal deadline, nor can the CAS compel joinder. Therefore, the appeal was dismissed on procedural grounds, and the FIFA decision was confirmed. The case underscores the strict procedural requirements for CAS appeals and the importance of identifying all necessary parties at the outset.
The detail
Parties: AS Saint Etienne v. FIFA
Case number: CAS 2025 A 11689
Outcome: Appeal dismissed; FIFA's determination on EPP 56025 confirmed; costs borne by AS Saint Etienne.
Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), FIFA Clearing House Regulations (FCHR), CAS Code of Sports-related Arbitration (2023 edition), Swiss law
Issues in play: The case involved the interpretation of a waiver of training compensation and solidarity contribution in a transfer agreement, and the procedural requirement of mandatory joinder of the buying club (Chelsea FC) as a necessary respondent in CAS proceedings.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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