CAS Case Digest · Verified against the full award text

CAS 2025/A/11209 — Swansea City AFC v. Hatcham FC

"Swansea v. Hatcham" · CAS upheld Swansea's appeal, finding Hatcham's signed waiver letter sufficiently clear to extinguish its FIFA training compensation claim.

Award date	16 September 2026
Panel	Sole Arbitrator: Mr Lars Hilliger, Attorney-at-Law in Copenhagen, Denmark
Outcome	Swansea City AFC won; the FIFA DRC decision of 8 January 2025 awarding EUR 172,168.20 plus 5% p.a. interest from 17 July 2022 was set aside in its entirety.
Provisions	Art. 20 FIFA RSTP Annexe 4, Art. 2(1) FIFA RSTP Annexe 4, Art. 5(2) FIFA RSTP Art. 5(3) FIFA RSTP Art. 7 FIFA RSTP Art. 24 FIFA RSTP Art. 18 Swiss Code of Obligations Art. R47 CAS Code Art. R48 CAS Code Art. R49 CAS Code Art. R51 CAS Code Art. R54 CAS Code Art. R55 CAS Code Art. R56 CAS Code Art. R57 CAS Code Art. R58 CAS Code Art. R64.5 CAS Code Art. 49(1) FIFA Statutes Art. 49(2) FIFA Statutes Art. 50(1) FIFA Statutes

What happened in Swansea v. Hatcham

Wasiri Ola Williams, born 1 April 2000, was registered as an amateur with Hatcham FC from 7 November 2019 to 6 October 2021 (700 days). On 16 June 2022 he signed his first professional contract with Swansea City AFC, a UEFA Category I club. Before signing, Swansea sought waiver letters from all former clubs. Hatcham's Chairman, Mr Ryan Reynolds, signed a letter on club letterhead stating the player was registered 'on a non contract/playing basis only' and that Hatcham would 'not seek compensation for the time he has spent with us.' Hatcham later lodged a FIFA DRC claim for EUR 172,168.20 training compensation plus 5% p.a. interest from 17 July 2022. The FIFA DRC awarded the full sum on 8 January 2025, holding the waiver lacked explicit reference to FIFA training compensation. Swansea appealed to CAS. Sole Arbitrator Lars Hilliger reversed the FIFA DRC, finding that, interpreted under Article 18 of the Swiss Code of Obligations, the waiver was sufficiently clear and unequivocal: training compensation was the only form of compensation Hatcham could possibly have been waiving, and Hatcham produced no evidence of any other intended meaning. The case matters because it confirms that a waiver need not use the literal phrase 'training compensation under the RSTP' to be valid, provided context makes the renounced right unmistakable.

Procedural history of CAS 2025/A/11209

In July 2024 Hatcham FC lodged a claim before the FIFA Dispute Resolution Chamber seeking EUR 172,356.16 training compensation plus 5% p.a. interest from the due date, based on 700 days of amateur registration under Article 20 and Annexe 4 of the FIFA RSTP. On 14 August 2024 the FIFA administration proposed EUR 172,168.20 plus 5% p.a. from 17 July 2022; Hatcham tacitly accepted, Swansea rejected. The FIFA DRC rendered its decision on 8 January 2025, awarding EUR 172,168.20 plus 5% p.a. from 17 July 2022 and ordering Swansea to pay USD 16,000 in procedural costs. Grounds were notified on 4 February 2025. Swansea filed its Statement of Appeal on 25 February 2025 and its Appeal Brief on 7 March 2025. FIFA was excluded from proceedings by agreement. Hatcham filed its Answer on 28 April 2025. A video hearing was held on 28 August 2025. CAS issued its award on 16 September 2026.

Key holdings in CAS 2025/A/11209

A waiver of FIFA training compensation is valid without literally using the phrase 'training compensation under the RSTP', provided the context makes the renounced right clear and unequivocal.
Under Article 18 of the Swiss Code of Obligations, a waiver must be interpreted according to the true and common intention of the parties, and where subjective intent cannot be established, by the principle of mutual trust and good faith.
Where a club was never in a contractual relationship with a player and no solidarity contribution or transfer fee was in issue, the only compensation it could waive upon the player's first professional registration is training compensation, making the scope of a general 'compensation' waiver unmistakable.
The burden of proving a valid waiver lies with the party asserting it (here Swansea), and that burden is discharged when the waiving party produces no evidence of any alternative meaning for the word 'compensation' used in the waiver document.
Implied waivers of training compensation are not recognised; however, a waiver that uses general language is not automatically implied — it may still be sufficiently clear and unequivocal when the surrounding circumstances leave no other plausible interpretation.

How the CAS panel reasoned

The Sole Arbitrator applied Article 18 of the Swiss Code of Obligations, seeking the true and common intention of the parties and, failing that, the meaning they could and should in good faith have attributed to the Waiver. He identified four prerequisites for a valid waiver from CAS 2017/A/5277: the waiver must not be contrary to law or public policy; the issuer must have authority; the waiver must be made clearly; and the waiving party must hold the right renounced. The first, second and fourth prerequisites were undisputed. On the third, the Arbitrator reasoned that: (i) the Waiver was drafted or approved by Hatcham itself, not Swansea; (ii) Swansea's letter of 17 May 2022 expressly requested waivers of 'training compensation', so Hatcham knew the context; (iii) Hatcham requested the Waiver be returned on official letterhead, signalling its material importance; (iv) the Player was never under contract with Hatcham, so no transfer fee or solidarity contribution could arise — training compensation was the only conceivable claim; and (v) Hatcham called no witnesses and offered no evidence of any alternative meaning for 'compensation'. The Arbitrator rejected the FIFA DRC's requirement that the words 'training compensation' appear verbatim, finding that requirement inconsistent with a contextual, good-faith reading of the document.

Why Swansea v. Hatcham matters in CAS jurisprudence

This award clarifies that a training compensation waiver does not require verbatim reference to 'training compensation under the RSTP' to be valid. It establishes that CAS will apply Article 18 of the Swiss Code of Obligations contextually, and that where training compensation is the only conceivable claim a former amateur club could hold, a general 'compensation' waiver on official letterhead will satisfy the clear-and-unequivocal standard. The decision also reaffirms that the waiving party bears the evidential burden of showing any alternative meaning.

Decision: Swansea City AFC won; the FIFA DRC decision of 8 January 2025 awarding EUR 172,168.20 plus 5% p.a. interest from 17 July 2022 was set aside in its entirety.

Cases cited in this award

CAS 2017/A/5277 CAS 2017/A/5172 CAS 2015/A/4214 CAS 2016/A/4604 CAS 2022/A/8829 CAS 2009/A/1893

Frequently asked questions about Swansea v. Hatcham

Did the Hatcham waiver letter need to say 'training compensation under the FIFA RSTP' to be valid?

No. The Sole Arbitrator held that the Waiver — which stated Hatcham would 'not seek compensation for the time he has spent with us' — was sufficiently clear and unequivocal even without those exact words. Because the Player was never under contract with Hatcham, training compensation was the only form of compensation Hatcham could possibly have been waiving, making the scope of the renunciation unmistakable in context.

How much training compensation did FIFA DRC award Hatcham, and why did CAS overturn it?

The FIFA DRC awarded EUR 172,168.20 plus 5% per annum interest from 17 July 2022, calculated on 700 days of amateur registration at Swansea's UEFA Category I rate of EUR 90,000 per year. CAS set aside the entire award because it found the signed waiver letter from Hatcham's Chairman constituted a valid and legally binding renunciation of that right, applying Article 18 of the Swiss Code of Obligations to interpret the document in its full context.

What legal test does CAS apply when deciding whether a training compensation waiver is valid?

CAS applies the four-part test from CAS 2017/A/5277: the waiver must not be contrary to law, public policy or good morals; the issuer must have capacity/authority; the waiver must be made clearly; and the waiving party must actually hold the right renounced. In Swansea v. Hatcham, only the 'made clearly' requirement was contested, and the Sole Arbitrator resolved it by applying the good-faith interpretive principle under Article 18 of the Swiss Code of Obligations rather than requiring literal use of the phrase 'training compensation'.

Can a club challenge the accuracy of a player passport to reduce training compensation at CAS?

The Sole Arbitrator acknowledged CAS jurisprudence (e.g. CAS 2015/A/4214 and CAS 2016/A/4604) that allows amendment of a training period where a player passport is shown to be inaccurate, and that the party alleging inaccuracy bears a high burden of proof. However, because the Waiver was found valid and the training compensation claim was extinguished entirely, the Sole Arbitrator found it unnecessary to rule on Swansea's alternative argument that the 700-day registration period was overstated.

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Topics: Training compensation & solidarity at CAS

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