CAS Case Digest · Verified against the full award text

CAS 2025/A/11117 — Sporting Club Accra v. Leicester City FC & FIFA

"Sporting Club Accra" · CAS dismissed Ghanaian academy's training compensation claim after it failed to challenge the FIFA Electronic Player Passport within prescribed deadlines.

What happened in Sporting Club Accra

Sporting Club Accra, a Ghanaian Category IV club, trained player Nathaniel Opoku Onyina (born 22 July 2001) from 5 August 2016 until at least 31 December 2019. On 31 January 2023, the player was transferred from Ghanaian club FDM Field Masters Sporting Club to Leicester City FC as a professional, triggering EPP nr. 17167 under the FIFA Clearing House Regulations. The FIFA General Secretariat conducted an EPP review process in which Sporting Club Accra participated, ultimately determining that the club was entitled only to solidarity contribution, not training compensation, because it was not the player's 'former club' under Annex 4 RSTP. The FIFA Determination was notified on 13 July 2023. Sporting Club Accra did not appeal within the 21-day deadline. Over a year later, on 26 November 2024, it filed a DRC claim under Art. 18(2) CHR alleging a 'bridge transfer' between FDM and Leicester. FIFA closed the claim on 12 December 2024 because the club had participated in the EPP process. CAS upheld that closure, finding the club had participated in the relevant EPP review process and therefore failed the first cumulative condition of Art. 18(2) CHR. The panel also noted, incidentally, that the bridge transfer allegation was unsubstantiated because the two-consecutive-transfers requirement was not met given a gap of over three years between the player's last registration and his signing with FDM.

Procedural history of CAS 2025/A/11117

On 31 January 2023, the player's transfer from FDM to Leicester City FC triggered EPP nr. 17167 under the FIFA Clearing House Regulations. The FIFA General Secretariat conducted the EPP review process under Art. 9 CHR, in which Sporting Club Accra participated. On 13 July 2023, FIFA issued its final Determination, granting the club only solidarity contribution and notifying all parties via TMS. The club did not appeal within the 21-day deadline (by 3 August 2023). On 26 November 2024, the club filed TMS claim nr. 14791 before the FIFA Football Tribunal under Art. 18(2) CHR, seeking EUR 242,082 (later amended to EUR 335,232.87) in training compensation, alleging a bridge transfer. On 12 December 2024, the FIFA Clearing House Department, on behalf of the FIFA Football Tribunal, closed the claim because the club had participated in the EPP process. The club appealed to CAS on 2 January 2025, filing its Appeal Brief on 7 February 2025. Both respondents filed Answers on 30 April 2025. The Sole Arbitrator decided on written submissions alone.

Key holdings in CAS 2025/A/11117

• The FIFA Clearing House Department's letter closing TMS claim nr. 14791 constitutes a 'decision' within the meaning of Art. R47 of the CAS Code because it produces legal effects and reflects an animus decidendi, regardless of its letter-like form.
• A club that participated in the EPP review process fails the first cumulative condition of Art. 18(2)(a) CHR and is therefore not entitled to lodge a claim before the DRC on the basis of that provision.
• The EPP review process under Arts. 8 and 9 CHR is the correct procedural vehicle for raising objections — including bridge transfer allegations — regarding registration information; failure to do so during that process bars subsequent claims.
• Failure to appeal the final EPP within the 21-day deadline under Art. 10(5)(b) and (c) CHR renders the EPP and Allocation Statement final and binding, and the appellant must bear the consequences of that omission.
• A bridge transfer under FIFA definition #24 requires two consecutive transfers connected to each other; where the player was unregistered for more than three years before signing with the alleged 'middle club', the requirement of consecutive transfers is not met.

How the CAS panel reasoned

The Sole Arbitrator first confirmed that the FIFA closure letter qualified as an appealable decision because it rejected the club's claim and affected its legal position, satisfying the animus decidendi criterion drawn from CAS jurisprudence. On the merits, the panel focused on Art. 18(2)(a) CHR, which requires non-participation in the relevant EPP review process as a threshold condition. The Appellant argued that because FIFA misidentified the reward trigger (treating the transfer as an international professional transfer rather than a first professional registration), no 'relevant' EPP process ever took place, so it could not have participated. The Sole Arbitrator rejected this as misleading: the CHR generates one EPP per triggering event, and any errors in identifying the trigger are corrected through the review process itself — not by generating a new EPP. Since the club undisputedly participated in EPP nr. 17167, the first condition of Art. 18(2) was not met. The panel further held that any procedural irregularities at first instance were cured by CAS's full power of review under Art. R57. It dismissed the denial-of-justice argument as moot. Incidentally, the panel found the bridge transfer allegation substantively unproven because the player had been unregistered for over three years before joining FDM, making consecutive transfers impossible under FIFA definition #24.

Why Sporting Club Accra matters in CAS jurisprudence

This award clarifies the strict gateway conditions of Art. 18(2) CHR: a club that participated in the EPP review process — even passively — cannot later invoke that provision to re-litigate training reward entitlements. The panel reinforces that the EPP review process under Arts. 8–10 CHR is the exclusive and time-limited forum for correcting registration information, including bridge transfer allegations, and that failure to act within the 21-day appeal deadline renders the EPP final and binding. The decision also confirms that a FIFA Clearing House closure letter can constitute an appealable 'decision' under Art. R47 CAS Code.

Cases cited in this award

CAS 2018/A/5933 CAS 2004/A/659 CAS 2016/A/4817 CAS 2024/A/10470 CAS 2024/A/10525 CAS 2020/A/7590 & CAS 2020/A/7591

Frequently asked questions about Sporting Club Accra

Did Sporting Club Accra win training compensation from Leicester City in the CAS 2025/A/11117 case?

No. CAS dismissed Sporting Club Accra's appeal in full. The Sole Arbitrator confirmed the FIFA Clearing House Department's decision of 12 December 2024 closing the club's claim, meaning no training compensation was awarded. The club had sought EUR 335,232.87 but failed the threshold condition of Art. 18(2)(a) CHR because it had participated in the EPP review process.

What is a bridge transfer and why did it matter in the Sporting Club Accra v Leicester case?

A bridge transfer under FIFA definition #24 involves two consecutive transfers of the same player connected to each other, with a registration at a 'middle club' designed to circumvent regulations. Sporting Club Accra argued that the player's 10-day registration with FDM before joining Leicester was a bridge transfer, which would have made Leicester's registration the player's first professional registration and triggered training compensation. The Sole Arbitrator rejected this incidentally, finding the two-consecutive-transfers requirement was not met because the player had been unregistered for over three years before joining FDM.

What happens if a club misses the 21-day deadline to appeal a FIFA Electronic Player Passport determination?

Under Art. 10(5)(b) and (c) of the FIFA Clearing House Regulations, failure to appeal within the 21-day deadline set in the FIFA Statutes renders the EPP and any Allocation Statement final and binding. In this case, the FIFA Determination was notified on 13 July 2023, meaning the appeal deadline was 3 August 2023. Sporting Club Accra did not appeal, and CAS held it must bear the consequences of that omission and cannot cure the failure through a later DRC claim.

Can a club that participated in the FIFA EPP review process still file a claim under Art. 18(2) CHR?

No. Art. 18(2)(a) CHR requires, as a cumulative threshold condition, that the club 'did not take part in the relevant EPP review process.' In CAS 2025/A/11117, the Sole Arbitrator found that Sporting Club Accra had participated in EPP nr. 17167 and therefore failed this first condition, making its DRC claim inadmissible regardless of the merits of its bridge transfer allegation. The panel emphasised that the EPP review process itself — not a subsequent DRC claim — is the correct forum for raising objections about registration information.

Topics: Training compensation & solidarity at CAS

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