CAS Case Digest · Verified against the full award text

CAS 2021/A/8085 — FK Bunyodkor v. Jovlon Ibrokhimov & the Uzbekistan Football Association

"Bunyodkor v. Ibrokhimov" · CAS dismissed Bunyodkor's appeal, confirming the player's signing-fee claim of UZS 200,000,000 was not time-barred under Uzbek law.

What happened in Bunyodkor v. Ibrokhimov

Bunyodkor FK and Uzbekistani professional footballer Jovlon Ibrokhimov signed an employment contract on 4 January 2018, valid until 1 December 2018. Article 6.2 of the contract entitled the player to a signing fee of UZS 200,000,000, which the club never paid. After the Union of Football Players of Uzbekistan (UFPU) sent a payment demand on 13 September 2019, the UFPU filed a formal claim with the UFA Committee on Status and Transfer of Football Players on 3 December 2020. The UFA Committee ordered payment by 1 March 2021; the UFA Appeals Committee upheld that decision on 25 May 2021. Bunyodkor appealed to CAS, arguing the claim was time-barred under FIFA RSTP Article 25(5) (two-year limit) or, alternatively, under Article 217 of the Uzbek Labour Code (three-month limit), and that the UFPU lacked a power of attorney. The Sole Arbitrator held that FIFA RSTP Article 25(5) and the FIFA Procedural Rules were inapplicable to a purely domestic dispute; the applicable limitation period was three years under Article 150 of the Uzbek Civil Code. Even taking the earliest possible trigger date — the contract-signing date of 4 January 2018 — the player's claim filed on 3 December 2020 fell within the three-year window. The appeal was dismissed and the UFA Appeals Committee decision confirmed. The case matters because it clarifies that FIFA RSTP limitation provisions do not automatically apply to domestic disputes between parties of the same nationality.

Procedural history of CAS 2021/A/8085

On 4 January 2018, Bunyodkor FK and Jovlon Ibrokhimov signed an employment contract. The club never paid the UZS 200,000,000 signing fee stipulated in Article 6.2. On 13 September 2019, the UFPU demanded payment on the player's behalf. On 3 December 2020, the UFPU filed a formal claim with the UFA Committee on Status and Transfer of Football Players. Following a meeting on 23 January 2021, the UFA Committee ordered Bunyodkor to pay UZS 200,000,000 by 1 March 2021, with a disciplinary penalty threatened for non-compliance. On 22 February 2021, Bunyodkor appealed to the UFA Appeals Committee. On 25 May 2021, the UFA Appeals Committee dismissed the club's appeal and confirmed the UFA Committee's decision (the 'Appealed Decision'). On 14 June 2021, Bunyodkor filed a Statement of Appeal with CAS under Article R47 of the CAS Code, asking CAS to annul the UFA Committee decision and reject the player's claim in full.

Key holdings in CAS 2021/A/8085

• FIFA RSTP Article 25(5) (two-year limitation period) is not applicable to a purely domestic dispute between Uzbekistani parties, as it is not among the provisions that FIFA RSTP Articles 1-3 require national associations to incorporate into their own regulations.
• The FIFA Rules Governing the Procedures of the Players' Status Committee and the Dispute Resolution Chamber apply solely to FIFA's internal tribunals and are not applicable to proceedings before national association bodies.
• In the absence of a relevant UFA regulation on time-barring, the applicable limitation period is three years under Article 150 of the Uzbek Civil Code.
• Under Article 154 of the Uzbek Civil Code, the limitation period for an obligation with a determined period of performance commences at the end of that period; even using the earliest possible trigger date (contract signature, 4 January 2018), the player's claim filed on 3 December 2020 was within the three-year period.
• A club's unsubstantiated reliance on a statutory provision — without submitting the text of the article or any interpretive argument — is insufficient to discharge its burden of proof, and such claims will not be further considered.

How the CAS panel reasoned

The Sole Arbitrator began by identifying the applicable law. Article 9(4) of the contract directed the parties to Uzbek legislation and UFA regulations, and the Appealed Decision was rendered on that basis. Although UFA must comply with mandatory FIFA regulations per FIFA Statutes Article 14(1)(a), the Arbitrator found that FIFA RSTP Article 25(5) is not listed among the provisions in FIFA RSTP Articles 1-3 that member associations must incorporate, and the FIFA Procedural Rules by their own terms govern only FIFA's internal bodies. Both FIFA-based arguments therefore failed at the threshold. The Arbitrator then rejected the club's alternative argument under Article 217 of the Uzbek Labour Code as entirely unsubstantiated — no exhibit, no wording, no interpretive argument was provided. Turning to the merits, the Arbitrator applied Article 150 of the Uzbek Civil Code (three-year general limitation) and Article 154 (running from end of performance period for fixed-term obligations). The Arbitrator noted that even accepting the club's own preferred trigger date — contract signature on 4 January 2018, the earliest of the three dates argued — the three-year period would have expired on 4 January 2021, and the player filed on 3 December 2020, comfortably within time. Because the claim was timely under every scenario, the Arbitrator declined to determine which trigger date was legally correct. The club had not contested the quantum, so the UFA decisions were confirmed.

Why Bunyodkor v. Ibrokhimov matters in CAS jurisprudence

This award establishes that FIFA RSTP Article 25(5)'s two-year limitation period does not automatically govern domestic disputes between parties of the same nationality, because it is not among the provisions FIFA mandates national associations to incorporate. It also confirms that FIFA's internal procedural rules have no extraterritorial reach over national association tribunals. For purely domestic disputes, the applicable national civil law limitation period — here three years under Uzbek law — controls, and clubs cannot invoke FIFA rules selectively to defeat otherwise valid player claims.

Frequently asked questions about Bunyodkor v. Ibrokhimov

Did the Bunyodkor v. Ibrokhimov CAS case apply the FIFA two-year limitation period to the player's signing-fee claim?

No. The Sole Arbitrator held that FIFA RSTP Article 25(5) was inapplicable because it is not listed among the provisions in FIFA RSTP Articles 1-3 that national associations are obliged to incorporate into their own regulations. Since both parties were Uzbekistani and the dispute lacked an international dimension, the applicable limitation period was three years under Article 150 of the Uzbek Civil Code.

Was the player's claim for UZS 200,000,000 time-barred in the Bunyodkor v. Ibrokhimov case?

No. The Sole Arbitrator found that even using the earliest possible trigger date — the contract-signing date of 4 January 2018 — the three-year limitation period under Article 150 of the Uzbek Civil Code would have expired on 4 January 2021. The player filed his claim with the UFA Committee on 3 December 2020, which was within that period. The claim was therefore not time-barred under any of the three trigger dates argued by the parties.

Can a club in a domestic football dispute rely on the FIFA Procedural Rules to challenge the authority of a players' union representative appearing without a power of attorney?

Not according to this award. The Sole Arbitrator held that the FIFA Rules Governing the Procedures of the Players' Status Committee and the Dispute Resolution Chamber apply solely to FIFA's own internal tribunals, as stated in Article 1 of those rules. They are not applicable to proceedings before national association bodies such as the UFA Committee. The club's power-of-attorney argument, being based exclusively on those inapplicable rules, was rejected as unsubstantiated.

What happened to Bunyodkor's late-filed 'Final Appeal Brief' in CAS 2021/A/8085?

The Sole Arbitrator ruled it inadmissible. Under Article R51 of the CAS Code, the club had already designated its Statement of Appeal (filed 14 June 2021) to serve as its Appeal Brief. The subsequently filed 'Final Appeal Brief' of 28 June 2021 was submitted after the ten-day deadline under Article R49, and the Respondents did not consent to its admission. The Arbitrator found no exceptional circumstances under Article R56 of the Code to justify the late submission, so only the original Statement of Appeal was considered.

Topics: Art. 17 RSTP & contract termination at CAS

Source: official award. This digest was generated by LexXi from the full award text and machine-verified against it — every figure, article and citation above appears in the source. It is an editorial summary, not legal advice. See how ElevenLex verification works.