Sporting Club Accra v. Leicester City FC, Fédération Internationale de Football Association (FIFA)

At a glance

Parties

Sporting Club Accra (Ghana) v. Leicester City FC (England) and Fédération Internationale de Football Association (FIFA)

Case no.

CAS 2025/A/11117

Forum and rules

Court of Arbitration for Sport, appeal arbitration under the Code of Sports-related Arbitration (2023 edition); FIFA Regulations on the Status and Transfer of Players (October 2022) and FIFA Clearing House Regulations (October 2022), with Swiss law applying subsidiarily

Panel

Fabio Iudica (Sole Arbitrator)

Sector

Football; training compensation

Outcome

Appeal dismissed and the FIFA Clearing House decision of 12 December 2024 closing the club's training compensation claim confirmed (11 November 2025).

Amount

Claimed: EUR 335,232.87 in training compensation plus 5% interest from 31 January 2023, after an earlier request of EUR 274,082. Leicester argued in the alternative that any award could not exceed EUR 274,070. Awarded: nothing. The Appellant received legal aid. The costs rulings are not reproduced in the published award.

The dispute

Sporting Club Accra, a Ghanaian category IV club, registered the player A. as an amateur from 5 August 2016. On 31 January 2023 the player was transferred as a professional from Field Master Sporting Club (FDM) to Leicester City FC, after a ten-day professional registration with FDM. The Transfer Matching System generated Electronic Player Passport (EPP) 17167, and Sporting Club Accra took part in the review process. FIFA's final determination of 13 July 2023 gave it only solidarity contribution, not training compensation, and the club did not appeal. On 26 November 2024 it filed a claim under Article 18(2) of the FIFA Clearing House Regulations. It argued that the FDM registration was a bridge transfer and that the Leicester registration was the player's first professional registration. FIFA closed the claim on 12 December 2024. Leicester argued that the appeal was inadmissible because FIFA's letter was not a decision and that no bridge transfer had occurred. FIFA argued that the final EPP was binding and that the claim did not meet Article 18(2).

Key holdings

1. The appeal is admissible. FIFA's letter closing the claim was a decision under Article R47 of the CAS Code, although it had the form of a letter. It rejected the claim on stated grounds and affected the club's legal position. The appeal of 2 January 2025 was filed within 21 days. ¶¶ 107–120
2. The allegations of denial of justice and breach of the right to be heard are moot. Under the Panel's full power of review (Article R57), a CAS appeal cures procedural irregularities that occurred at first instance. ¶¶ 141–143
3. The club took part in the relevant EPP review process, so the condition in Article 18(2)(a) CHR was not met and it could not bring a claim before the Dispute Resolution Chamber. EPP generation is a one-time process for each reward trigger. If the trigger is wrongly identified, the provisional EPP is corrected in the review; no new EPP is generated. FIFA was therefore right to decline the claim. ¶¶ 147–151
4. The club stayed passive during the inspection and review periods. It did not appeal the final EPP, notified on 13 July 2023, by the deadline of 3 August 2023. Under Article 10.5 CHR the EPP became final and binding, and the club must bear the consequences of its negligence. ¶¶ 152–162
5. Obiter: no bridge transfer was shown. Even on the club's own dates, the player was not registered with any club between 4 September 2020 and his registration with FDM on 20 January 2023. The requirement of two consecutive transfers in FIFA definition #24 was therefore not met. ¶¶ 163–164
6. Both late filings were admitted under Article R56: Leicester's e-mail from FDM's owner dated 14 May 2025, and the club's witness statement from the GFA Head of TMS. Neither introduced a new argument, and each side could comment on the other's filing. ¶¶ 125–132

Procedural history

1. 31 January 2023The player is transferred from FDM to Leicester and provisional EPP 17167 is generated.
2. 13 July 2023FIFA's final EPP determination: no club is entitled to training compensation; Sporting Club Accra is entitled to solidarity contribution. No appeal is filed.
3. 26 November 2024Sporting Club Accra files a training compensation claim under Article 18(2) CHR (TMS claim 14791).
4. 12 December 2024The FIFA Clearing House Department, on behalf of the Football Tribunal, closes the claim.
5. 2 January 2025Statement of Appeal filed with CAS.
6. 27 March 2025The Appellant's request for legal aid is granted.
7. 13 May 2025Fabio Iudica is appointed Sole Arbitrator.
8. 8 August 2025The Sole Arbitrator decides to rule on the written submissions, without a hearing.
9. 11 November 2025Award: appeal dismissed and FIFA decision confirmed.

Tribunal, counsel and experts

Decided by

• Fabio Iudica Sole arbitrator, Court of Arbitration for Sport

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Keywords

• training compensation
• bridge transfer
• FIFA Clearing House Regulations
• Electronic Player Passport
• EPP review process
• solidarity contribution
• Article 18(2) CHR
• appealable decision
• Article R47 CAS Code
• denial of justice
• curing effect
• de novo review
• Article 5bis RSTP
• Annex 4 RSTP
• Transfer Matching System
• Leicester City
• Ghana
• legal aid

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