C.F. Rayo Majadahonda S.A.D. v. Fédération Internationale de Football Association (FIFA), MEE DSSC DRC Dnipro, DIUSC Inter Dnipro, DIUSSH Novomoskovsk

At a glance

Parties

C.F. Rayo Majadahonda S.A.D. (Spain) v. MEE DSSC DRC Dnipro, DIUSC Inter Dnipro and DIUSSH Novomoskovsk (Ukraine), and the Fédération Internationale de Football Association (FIFA)

Case no.

CAS 2024/A/10949

Forum and rules

Court of Arbitration for Sport, appeal arbitration under the 2023 CAS Code. FIFA regulations (RSTP, Clearing House Regulations) applied primarily, Swiss law subsidiarily.

Panel

Prof. Martin Schimke (Sole Arbitrator)

Sector

Football; training compensation; minor player displaced by the war in Ukraine

Outcome

Appeal dismissed (20 February 2026). The FIFA General Secretariat's EPP Decision and Allocation Statement of 1 October 2024 were confirmed.

Amount

Training compensation confirmed: EUR 32,904.10 in total (DIUSSH Novomoskovsk EUR 4,958.90; DIUSC Inter Dnipro EUR 15,068.49; MEE DSSC DRC Dnipro EUR 12,876.71). The costs rulings are redacted in the published award.

The dispute

Illia Voloshyn, a Ukrainian player born on 15 January 2007, trained as an amateur with three Ukrainian clubs. He left Ukraine in April 2022 after Russia's invasion and was registered as an amateur with the Spanish club Novelda Unión C.F. on 29 September 2022. On 10 October 2023 he was registered for the first time as a professional with C.F. Rayo Majadahonda. FIFA's Dispute Resolution Chamber and General Secretariat held that Rayo owed training compensation to the three Ukrainian clubs. Rayo argued that Article 7.3(a) of Annexe 7 to the FIFA RSTP (the temporary rules for the war in Ukraine) exempted it as the "new club", that Novelda's registration did not follow FIFA procedure, that it had relied on assurances from the RFEF, and that DIUSSH Novomoskovsk had waived its share. FIFA argued that the exemption applied only to the first club the player joined on leaving Ukraine and that the document relied on as a waiver was not a valid waiver; the three Ukrainian clubs did not file answers.

Key holdings

1. The player's registration with Novelda was a registration for the purposes of the FIFA RSTP. It was completed through TMS with an ITC issued on 27 September 2022, under a limited minor exemption that the FIFA Players' Status Chamber had granted to the RFEF on 22 August 2022. The case is distinguished from CAS 2020/A/7353-7354, where the registration had not gone through the FIFA framework. ¶¶ 70–72
2. The wording of Article 7.3(a) of Annexe 7 is ambiguous. FIFA uses "a new club" and "the new club" interchangeably. The text does not say whether "after having left the territory of Ukraine" requires an immediate link to the player's first professional registration. The literal reading therefore does not resolve the dispute in Rayo's favour. ¶¶ 80–83
3. Read systematically, teleologically and historically, the Annexe 7 exemption is temporary and strictly limited. The player had lived in Spain and been registered with Novelda for almost a year, which broke the causal link to Annexe 7. A wider reading would favour professional clubs over the small clubs that trained the player and would invite circumvention through interim amateur registrations. ¶¶ 97–101
4. Because the ambiguity is resolved by the ordinary methods of interpretation, there is no need or basis to apply the contra proferentem principle. ¶¶ 77, 101
5. Rayo's reliance on legitimate trust and venire contra factum proprium fails. Its email correspondence with the RFEF contains no confirmation that training compensation was not due. An RFEF email referring to separate contact with FIFA is not a statement by FIFA on which Rayo could rely. ¶ 102
6. Uploading proof of a waiver in TMS (Article 9.7 FIFA CHR) is mandatory, and Novomoskovsk's upload met that requirement. But a valid waiver must also be clear and unequivocal. Its statement that it had "no financial claims against football player" did not mention training compensation or Rayo, so it was not a valid waiver. ¶¶ 107–115
7. The appeal is dismissed and the FIFA General Secretariat's decisions of 1 October 2024 are confirmed. All other prayers for relief are dismissed. Operative part

Procedural history

1. 29 September 2022The player is registered as an amateur with Novelda Unión C.F. after leaving Ukraine.
2. 10 October 2023The player is registered for the first time as a professional with C.F. Rayo Majadahonda. FIFA starts the Electronic Player Passport procedure on 16 October 2023.
3. 24 September 2024A Single Judge of the FIFA DRC decides that training compensation is due to the three Ukrainian clubs.
4. 1 October 2024The FIFA General Secretariat issues the EPP Decision and the Allocation Statement for EUR 32,904.10.
5. 18 October 2024Rayo files its Statement of Appeal with CAS. Its Appeal Brief follows on 26 November 2024.
6. 2 October 2025FIFA files its Answer after a series of extensions. The three Ukrainian clubs file no answer.
7. 6 October 2025Sole Arbitrator Martin Schimke is appointed. On 23 October 2025 he decides to rule on the written submissions without a hearing.
8. 20 February 2026Award: appeal dismissed and the FIFA decisions confirmed.

Tribunal, counsel and experts

Decided by

• Martin Schimke Sole arbitrator — appointed by the institution

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Keywords

• training compensation
• Annexe 7 FIFA RSTP
• war in Ukraine
• Article 7.3 Annexe 7
• new club
• protection of minors
• Article 19.2(d) RSTP
• limited minor exemption
• Electronic Player Passport
• FIFA Clearing House Regulations
• first professional registration
• amateur registration
• contra proferentem
• interpretation of sports regulations
• waiver of training compensation
• venire contra factum proprium
• legitimate expectations

Summary generated with AI from the published documents — refer to the award for the authoritative text.