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International Arbitration Forum

Roy Revivo, Israeli Football Association (IFA) v. Fédération Internationale de Football Association (FIFA)

Case summary

At a glance

Parties
Israel Football Association (IFA) and Roy Revivo v. Fédération Internationale de Football Association (FIFA); interested parties: Israeli Olympics Association and UEFA
Case no.
CAS OG 24/004
Forum and rules
CAS ad hoc Division (OG Paris), CAS Ad Hoc Rules for the Olympic Games
Instrument
Rule 61.2 Olympic Charter; Regulations – Olympic Football Tournaments Paris 2024 (ROFT)
Panel
Lars Hilliger (President), Song Lu, Leanne O’Leary
Sector
Football; Olympic eligibility
Outcome
Application dismissed. The operative part was issued on 24 July 2024 and the reasoned award on 26 July 2024. The player served UEFA's two-match suspension at the Olympic tournament.
Amount
No monetary claim. No order as to costs (Article 22 CAS Ad Hoc Rules).

The dispute

Roy Revivo, a player in Israel's U23 Olympic football team, received a direct red card on 21 March 2024 in a UEFA Euro 2024 qualifier against Iceland. On 23 April 2024 the UEFA Control, Ethics and Disciplinary Body (CEDB) suspended him for two "UEFA representative team competition matches", and that decision was not appealed. On 16 July 2024 UEFA told FIFA that the suspension had to be served in Israel's first two matches of the Paris 2024 Olympic Football Tournament. The IFA learned this at the Team Arrival Meeting on 21 July 2024 and filed a protest on 22 July 2024. The FIFA Disciplinary Committee declared the protest inadmissible that same day, because it was filed after the deadline in Article 10.3 ROFT. The applicants argued that the wording of the CEDB Decision limited the suspension to UEFA competitions, and in the alternative that a cancelled friendly against Bosnia on 26 March 2024 counted as one match served. FIFA objected to jurisdiction (internal remedies not exhausted; no sufficient connection with the Olympic Games), defended the inadmissibility ruling and questioned whether the case could proceed without UEFA as a respondent.

Key holdings

  1. Jurisdiction upheld by exception. The applicants had not exhausted FIFA's internal remedies (an appeal to the FIFA Appeal Committee). However, the decision came only two days before the first match, so the time needed to exhaust those remedies would have made the CAS appeal ineffective under Article 1 of the CAS Ad Hoc Rules. ¶¶ 38–45
  2. The dispute has a sufficient connection with the Olympic Games under Rule 61.2 of the Olympic Charter, because its subject is the player's eligibility for Olympic tournament matches. ¶ 46
  3. The protest was rightly declared inadmissible as late. The Article 10.3 ROFT deadline was 19 July 2024. The IFA should have known the carry-over rules in Articles 68.1 and 68.4(a) UEFA DR and had time to protest or to ask UEFA when the suspension would be served. The Panel accepted that the protest was filed in good faith. ¶¶ 62–64
  4. Under Article 69 FIFA DC, FIFA only enforces sanctions on information provided by UEFA and is not responsible for its accuracy. Interpreting the CEDB Decision is outside the FIFA Disciplinary Committee's competence. The scope of the sanction, and whether the cancelled Israel v Bosnia match counts as served, are questions for UEFA, so the Panel could not rule on them. ¶¶ 65–69
  5. Because the protest was inadmissible, the Panel left open FIFA's objection on standing to be sued. It dismissed the application with no order as to costs. ¶¶ 70–76

Procedural history

  1. 21 March 2024Revivo receives a direct red card in the Israel v Iceland Euro 2024 qualifier.
  2. 23 April 2024The UEFA CEDB imposes a two-match suspension, which is not appealed.
  3. 16 July 2024UEFA informs FIFA that the suspension is to be served in the Olympic matches on 24 and 27 July 2024.
  4. 22 July 2024The IFA files its protest. The FIFA Disciplinary Committee declares it inadmissible the same day.
  5. 23 July 2024Application filed with the CAS ad hoc Division and the Panel constituted. UEFA is later called as an interested party.
  6. 24 July 2024Hearing held, and operative part issued dismissing the application.
  7. 26 July 2024Reasoned award issued.

Tribunal, counsel and experts

Decided by
For the claimant
IFA Legal Department · Amid Pines · Aviad Gurman
For the respondent
FIFA Litigation

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Keywords

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

Case ID
CAS OG 24/004
Claimant
Roy Revivo, Israeli Football Association (IFA)
Respondent
Fédération Internationale de Football Association (FIFA)

Procedure: Ad hoc
Sport: Football
Matter: Eligibility (except nationality)
Outcome: Dismissed
Panel: Lars Hilliger, Leanne O’Leary, Song Lu
Source: Court of Arbitration for Sport case database.