CAS Case Digest · Verified against the full award text

CAS 2024/A/10949 — C.F. Rayo Majadahonda S.A.D. v. MEE DSSC DRC Dnipro & DIUSC Inter Dnipro & DIUSSH Novomoskovsk & Fédération Internationale de Football Association (FIFA)

"Rayo Majadahonda v. FIFA (Voloshyn)" · CAS dismissed Rayo Majadahonda's appeal, confirming EUR 32,904.10 training compensation was owed to three Ukrainian clubs for player Illia Voloshyn.

What happened in Rayo Majadahonda v. FIFA (Voloshyn)

This case concerned whether Spanish club C.F. Rayo Majadahonda S.A.D. owed training compensation to three Ukrainian clubs — DRC Dnipro, Inter Dnipro, and Novomoskovsk — upon registering Ukrainian minor Illia Voloshyn (born 15 January 2007) as a professional for the first time on 10 October 2023. The player had fled Ukraine in April 2022 following Russia's invasion, obtained temporary residence in Spain on 26 July 2022, and was registered as an amateur with Spanish club Novelda FC on 29 September 2022 under FIFA's minor exception (Article 19.2(d) RSTP via an LME). Rayo Majadahonda argued it was the 'new club' under Article 7.3(a), Annexe 7 FIFA RSTP and therefore exempt from paying training compensation. FIFA's DRC and General Secretariat had determined training compensation totalling EUR 32,904.10 was due. CAS upheld those decisions. The Sole Arbitrator found that the player's prior amateur registration with Novelda FC through FIFA's formal regulatory framework broke the causal link to Annexe 7's exemption, and that a document uploaded by Novomoskovsk in TMS did not constitute a valid waiver of training compensation. The case is significant for clarifying the temporal and contextual limits of Annexe 7's training compensation exemptions for Ukrainian war-displaced players.

Procedural history of CAS 2024/A/10949

On 16 October 2023, FIFA initiated the Electronic Player Passport (EPP) procedure for Illia Voloshyn. Due to legal and factual complexity under Article 10(3) FIFA Clearing House Regulations (FIFA CHR), the matter was referred to the FIFA Dispute Resolution Chamber. On 24 September 2024, a Single Judge of the FIFA DRC issued a decision finding that Article 7.3, Annexe 7 FIFA RSTP did not exempt Rayo Majadahonda from paying training compensation, concluding that Novelda FC — not Rayo Majadahonda — was the 'new club' under that provision. On 1 October 2024, the FIFA General Secretariat issued the EPP Decision and Allocation Statement requiring Rayo Majadahonda to pay EUR 32,904.10 in total: EUR 4,958.90 to Novomoskovsk, EUR 15,068.49 to Inter Dnipro, and EUR 12,876.71 to DRC Dnipro. On 18 October 2024, Rayo Majadahonda filed a Statement of Appeal with CAS under Articles R47 and R48 of the CAS Code, challenging both the EPP Decision and the Allocation Statement and requesting a finding that no training compensation was payable.

Key holdings in CAS 2024/A/10949

• The Player was validly registered with Novelda FC for the purposes of the FIFA RSTP on 29 September 2022 as an amateur player, as the ITC was issued on 27 September 2022 and the transfer was completed through FIFA's TMS system under the LME granted to the RFEF on 22 August 2022 pursuant to Article 19.2(d) FIFA RSTP.
• Article 7.3(a), Annexe 7 FIFA RSTP does not exempt a professional club from paying training compensation where the player had already been registered as an amateur with another club for approximately one year following departure from Ukraine, as this breaks the causal link to the provision's limited and temporary humanitarian purpose.
• The Annexe 7 training compensation exemption was intended as a strictly limited, temporary measure to balance the interests of all stakeholders, and extending it to cover professional registrations occurring well after a player's departure from Ukraine would create a manifest risk of circumvention and undermine the training compensation system.
• A document uploaded in TMS's 'waiver section' stating 'we have no financial claims against football player: ILLIA VOLOSHYN' does not constitute a clear and unequivocal waiver of entitlement to training compensation, as it refers to claims against the player rather than against the registering club and does not mention training compensation or training rewards.
• The contra preferentum principle does not apply where the systematic, teleological, and historical interpretation of the disputed provision resolves the ambiguity, rendering the principle unnecessary.

How the CAS panel reasoned

The Sole Arbitrator applied the four coequal Swiss law methods of regulatory interpretation — grammatical, systematic, historical, and teleological — as summarised in CAS 2025/A/11604. On literal interpretation, he acknowledged that the use of 'the new club' and 'a new club' in Article 7.3(a) could suggest two different clubs, but found the text insufficiently clear to resolve the dispute in the Appellant's favour alone, noting FIFA regulations frequently use both formulations interchangeably. Turning to systematic, teleological, and historical interpretation, the Sole Arbitrator emphasised that Annexe 7 was adopted on 7 March 2022 as an urgent, temporary response to Russia's invasion of Ukraine, explicitly described as proportionate and balanced. He accepted FIFA's argument that extending the exemption indefinitely until a player's first professional registration — regardless of how long after departure from Ukraine — would contradict the legislative intent to facilitate players' possible return to Ukraine, create unjustified long-term disparities in training compensation, and risk strategic circumvention by placing players with amateur clubs as an interim step. The player had been residing in Spain and registered with Novelda FC for approximately one year before signing professionally with Rayo Majadahonda, breaking the causal link to Annexe 7. The Appellant's good-faith reliance argument was rejected because the email correspondence with RFEF contained no confirmation from FIFA or any regulatory authority that training compensation was not due.

Why Rayo Majadahonda v. FIFA (Voloshyn) matters in CAS jurisprudence

This award establishes that the Annexe 7 FIFA RSTP training compensation exemption for Ukrainian war-displaced players has a temporal limit: once a player has been formally registered as an amateur with a club outside Ukraine through FIFA's regulatory framework, the causal link to the exemption is broken and a subsequent professional club cannot invoke Article 7.3(a). The award also reinforces that a valid waiver of training compensation requires clear, unequivocal language specifically referencing training compensation, not merely a general statement of no financial claims against the player.

Cases cited in this award

CAS 2009/A/1810 & 1811 CAS 2020/A/7353-7354 CAS 2022/A/9016 CAS 2025/A/11604 CAS 2021/A/8392 CAS 2023/A/9975-9976

Frequently asked questions about Rayo Majadahonda v. FIFA (Voloshyn)

Did Rayo Majadahonda have to pay training compensation for Illia Voloshyn under Annexe 7 FIFA RSTP?

Yes. CAS confirmed that Rayo Majadahonda must pay a total of EUR 32,904.10 in training compensation to three Ukrainian clubs. The Sole Arbitrator held that Article 7.3(a), Annexe 7 FIFA RSTP did not exempt Rayo Majadahonda because the player had already been registered as an amateur with Novelda FC for approximately one year after leaving Ukraine, breaking the causal link to the provision's limited humanitarian purpose.

Does Annexe 7 FIFA RSTP exempt a club from training compensation if a Ukrainian war-displaced player was previously registered as an amateur with another club before signing his first professional contract?

No, according to this award. The Sole Arbitrator found that where a player had been formally registered as an amateur with a third-party club through FIFA's regulatory framework for approximately one year following departure from Ukraine, the Annexe 7 exemption no longer applies to the subsequent professional club. The exemption was intended as a strictly temporary and limited measure, and extending it indefinitely would contradict its legislative intent and risk circumvention of the training compensation system.

Was Novelda FC's registration of Voloshyn valid under FIFA RSTP, or was it only based on the Spanish Royal Decree?

CAS found the registration was valid under FIFA RSTP. FIFA presented evidence that the ITC was issued on 27 September 2022 and the transfer was completed through FIFA's TMS system, with the RFEF using a Limited Minor Exemption (LME) granted on 22 August 2022 under Article 19.7 FIFA RSTP with reference to Article 19.2(d). The Sole Arbitrator distinguished this from CAS 2020/A/7353-7354, where a registration had not been completed through the FIFA regulatory framework.

Did Novomoskovsk's TMS document stating 'no financial claims against football player Illia Voloshyn' constitute a valid waiver of training compensation?

No. The Sole Arbitrator held the document was not a substantively valid waiver because it did not specifically mention training compensation or training rewards, referred to claims against the player rather than against Rayo Majadahonda, and did not contain a clear and unequivocal statement of intention to waive training compensation entitlement. Applying CAS 2021/A/8392 and CAS 2023/A/9975-9976, the language was more naturally interpreted as a statement that Novomoskovsk had no outstanding financial claims against the player himself.

Topics: Training compensation & solidarity at CAS

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