CAS Case Digest · Verified against the full award text

CAS 2024/A/10662 — Udinese Football School Cartagena v. Watford FC & FCF & FIFA

"Udinese Cartagena" · CAS confirmed that a training compensation claim filed in TMS after the two-year limit is time-barred, even if the club sent it to its national association before expiry.

What happened in Udinese Cartagena

Udinese Football School Cartagena, a Colombian amateur club, trained player Ober Yesid Almanza Sehuanes from December 2018 until July 2021, when he signed his first professional contract with Watford FC. On 10 July 2023 — just within the two-year window — Udinese Cartagena sent its training compensation claim (€172,500) to the Colombian Football Federation (FCF) for upload to FIFA's Transfer Matching System (TMS). The FCF requested additional documentation regarding the club's sporting recognition and league affiliation for 2018–2019, causing delays. The claim was only uploaded to TMS on 10 August 2023, four days after the two-year deadline. The FIFA DRC declared the claim inadmissible on 9 January 2024. On appeal, CAS upheld that decision. The Sole Arbitrator held that under Articles 27–28 of the FIFA Procedural Rules, a training compensation claim is only 'submitted' when registered in TMS; there is no 'constructive filing' date based on delivery to a national association, and no provision in the FIFA framework suspends or interrupts the limitation period upon receipt by the association. The case matters because it clarifies the strict, TMS-anchored nature of the two-year limitation period and highlights the tension between Article 10.4 of the FIFA Procedural Rules (requiring associations to act 'without delay') and associations' obligations to avoid uploading false information.

Procedural history of CAS 2024/A/10662

On 10 July 2023, Udinese Cartagena requested the FCF to submit a training compensation claim against Watford FC in TMS for €172,500 plus 5% interest. The FCF requested additional documentation on the club's sporting recognition and league affiliation for 2018–2019. After protracted correspondence, the FCF uploaded the claim on 10 August 2023. On 14 August 2023, the FIFA DRC informed the Appellant the claim appeared time-barred. On 9 January 2024, the FIFA DRC issued its decision (case ref. TMS 13743) declaring the claim inadmissible and ordering the Appellant to pay procedural costs of USD 17,500. The grounds were communicated on 22 May 2024. On 12 June 2024, Udinese Cartagena filed a statement of appeal at CAS under Article R47 of the CAS Code against Watford, the FCF, and FIFA, seeking annulment of the DRC decision and an order that Watford pay training compensation of €177,039, or alternatively that the FCF be held liable.

Key holdings in CAS 2024/A/10662

• A training compensation claim is only 'submitted' for the purposes of the two-year limitation period when it is effectively registered in TMS; delivery to a national association does not constitute a 'constructive filing' date.
• Neither the act of sending a claim to a national association nor any exchanges between a club and its association suspends or interrupts the two-year limitation period under the FIFA RSTP.
• Article 10.4 of the FIFA Procedural Rules requires member associations to transmit affiliated clubs' TMS communications without delay and without imposing conditions, but does not override the mandatory TMS-filing requirement or alter the limitation period.
• A CAS panel's mandate in appeal proceedings is confined to the subject matter adjudicated by the first-instance body; a claim for damages by a club against its national federation — never submitted to the FIFA DRC and outside FIFA's regulatory competence — is inadmissible before CAS.
• Watford's request for joinder of Udinese Colombia was rejected as it was made after Watford had already filed its Answer, outside the applicable time limit under Article R41.2 of the CAS Code.

How the CAS panel reasoned

The Sole Arbitrator began by confirming that the claim was uploaded to TMS on 10 August 2023, four days after the two-year deadline running from 6 August 2021. He examined Articles 27–28 of the FIFA Procedural Rules, which unequivocally require claims to be 'submitted and managed through TMS', and the FIFA Commentary on the RSTP, which states the time limit is only respected if a complete claim is submitted to FIFA within the timeframe. He found no textual or systematic basis in the FIFA framework for a 'constructive filing' date or for suspension/interruption of the limitation period upon receipt by a national association. He reasoned that accepting such an interpretation would undermine legal certainty, create inconsistent outcomes given varying administrative capacities of associations, and expose respondent clubs to open-ended liability. He acknowledged the tension between Article 10.4's 'without delay' obligation and associations' duty to avoid uploading false data, and noted both parties bore some responsibility for the compressed timeline — the Appellant waited approximately 23 months before filing, while the FCF could have filed preventively with reservations. However, these contextual findings did not alter the outcome required by the strict limitation rule. The claim for damages against the FCF was held outside the Sole Arbitrator's mandate because it was never before the FIFA DRC, FIFA lacked competence to hear it, and no arbitration agreement covering such a dispute between the FCF and the Appellant was identified.

Why Udinese Cartagena matters in CAS jurisprudence

This award provides authoritative CAS guidance that the two-year limitation period for training compensation claims under the FIFA RSTP is strictly anchored to the date of TMS filing, not to the date a club contacts its national association. It also clarifies the limits of Article 10.4 of the FIFA Procedural Rules, acknowledging the tension between the 'without delay' obligation and associations' data-integrity duties, and suggests FIFA should provide further regulatory clarity on the precise scope of associations' verification role. The award also reaffirms that CAS appeal panels cannot extend their mandate to claims never adjudicated at first instance, particularly where the first-instance body lacked competence.

Cases cited in this award

CAS 2014/A/3523 CAS 2007/A/1433 CAS 2006/A/1206 CAS 2007/A/1426 CAS 2012/A/2874 CAS 2021/A/8321 CAS 2019/A/6594 Cardiff City Football Club Limited v. SASP Football Club de Nantes

Frequently asked questions about Udinese Cartagena

Does sending a training compensation claim to your national federation before the two-year deadline count as filing it with FIFA?

No. Under Articles 27–28 of the FIFA Procedural Rules, a training compensation claim is only 'submitted' when it is effectively registered in TMS. In this case, Udinese Cartagena sent its claim to the FCF on 10 July 2023 (within the two-year window), but the FCF only uploaded it to TMS on 10 August 2023, four days after the deadline. CAS confirmed the claim was time-barred because there is no 'constructive filing' date based on delivery to a national association.

Can a national federation delay uploading a club's training compensation claim to TMS while it investigates the club's documentation?

Article 10.4 of the FIFA Procedural Rules requires member associations to transmit affiliated clubs' TMS communications without delay and without imposing conditions, regardless of whether the association agrees with the merits. The Sole Arbitrator acknowledged that associations may conduct limited authenticity checks but must not act as a gatekeeper on substantive merits. In this case, the FCF's prolonged requests for sporting recognition certificates for 2018–2019 were found to have gone beyond purely formal verification, though this did not change the outcome on the limitation period.

Can CAS hear a damages claim by a club against its national federation for mishandling a TMS filing, if that claim was never before the FIFA DRC?

No. The Sole Arbitrator held that the claim for damages against the FCF was outside his mandate because it was never submitted to the FIFA DRC, FIFA has no regulatory competence to hear disputes between a club and its national federation, and no arbitration agreement between the FCF and Udinese Cartagena covering such a dispute was identified. CAS appeal panels cannot extend their mandate to claims that were not adjudicated at first instance.

What practical steps should an amateur club without TMS access take to avoid missing the two-year training compensation deadline?

The Sole Arbitrator noted that Udinese Cartagena waited approximately 23 months before contacting the FCF, and that clubs without direct TMS access must anticipate that involving an intermediary association can introduce delays. The award implies clubs should contact their national association well in advance of the deadline and ensure all required documentation is ready. The Sole Arbitrator also suggested the FCF could have filed the claim preventively with express reservations, which is what it ultimately did on 10 August 2023 — but by then the deadline had already passed.

Topics: Training compensation & solidarity 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.