CAS Case Digest · Verified against the full award text

CAS 2025/A/11294 — Urawa Red Diamonds v. Per-Mathias Høgmo

"Urawa Red Diamonds v. Høgmo" · CAS annulled a FIFA PSC compensation award against Urawa Red Diamonds after finding the club had already paid all sums owed under the correct contract before the decision was issued.

What happened in Urawa Red Diamonds v. Høgmo

Urawa Red Diamonds, a Japanese J1 League club, hired Norwegian coach Per-Mathias Høgmo under a contract running 1 February 2024 to 31 December 2024, with an optional second year contingent on a top-10 J1 finish by end of October 2024. On 26 August 2024, the club offered mutual termination following poor sporting results (13th place); the coach refused, and on 3 September 2024 the club confirmed unilateral termination in writing. The club continued paying monthly salaries, including the November 2024 salary (paid 25 November 2024) and December 2024 salary (paid 23 December 2024), before any FIFA decision was issued. The coach filed a FIFA PSC claim in November 2024 without properly notifying the club. On 28 January 2025 the PSC awarded EUR 72,014.50; the grounds issued on 7 March 2025 stated a different figure of EUR 183,274.50, covering November and December 2024 salaries plus a January 2025 salary derived from the pre-employment agreement rather than the actual contract. Urawa appealed to CAS. The Sole Arbitrator found that the governing contract was the 31 January 2024 employment contract (not the pre-contract), that its term ended 31 December 2024 with no January 2025 obligation, and that the club had already discharged all financial obligations before the FIFA decision was rendered. The Decision was annulled. The case matters because it illustrates how a respondent's failure to disclose prior payments to FIFA can lead to a fundamentally flawed compensation award, and confirms that the supersession clause in a final contract displaces any pre-employment agreement.

Procedural history of CAS 2025/A/11294

On 9 November 2024, Høgmo filed a claim before the FIFA Players' Status Committee (PSC). Due to the coach allegedly submitting outdated contact details for the club, Urawa was not notified through the FIFA Legal Portal and had no opportunity to respond. On 28 January 2025, the PSC rendered a decision (FPSD-17012) awarding EUR 72,014.50 to the coach. On 7 March 2025, the PSC notified the grounds of its decision, which stated a materially different figure of EUR 183,274.50 as compensation for breach of contract plus 5% interest p.a. from 27 August 2024. The grounds relied on the pre-employment agreement rather than the final contract and included November and December 2024 salaries already paid, plus a January 2025 salary. Urawa was first notified of the claim on 31 January 2025 by the JFA. On 27 March 2025, Urawa filed a Statement of Appeal with CAS within the 21-day limit under Article 50.1 of the FIFA Statutes. CAS was asked to annul the Decision and dismiss all of the coach's claims.

Key holdings in CAS 2025/A/11294

• The employment contract executed on 31 January 2024 supersedes the pre-employment agreement by virtue of its entire-agreement clause (Article 29 of the Contract), and therefore governs the parties' relationship.
• The Appellant's offer of mutual termination on 26 August 2024 constituted a 'point-of-no-return' equivalent to a formal act of unilateral termination, making that date the operative termination date rather than 3 September 2024.
• Poor sporting performance does not constitute just cause for unilateral termination of a coaching contract under the FIFA RSTP.
• The residual value of the Contract ran only to 31 December 2024; the FIFA PSC erred in including a January 2025 salary derived from pre-contract language that had been superseded.
• Because the club had already paid all compensation owed (November and December 2024 salaries) prior to the FIFA decision being issued, and the coach failed to notify FIFA of those payments, the FIFA PSC decision must be annulled.

How the CAS panel reasoned

The Sole Arbitrator conducted a de novo review under Article R57 of the CAS Code. He first determined which contract governed: the pre-employment agreement's own preamble anticipated a future coaching agreement, and the Contract executed on 31 January 2024 contained an explicit entire-agreement/supersession clause, making the Contract the operative instrument. The FIFA PSC had relied exclusively on the pre-contract, which contained the phrase defining a contract year as running to 31 January of the following year — language absent from the Contract. The Arbitrator then confirmed termination without just cause was undisputed. On compensation, Article 23(2) of the Contract provided a contractual compensation clause (cross-referencing Article 6 despite a typographical error citing Article 5) that replicated the residual-value formula in Article 6.2(a) of Annexe 2 to the FIFA RSTP. The Arbitrator found this clause reasonable and proportionate. Since the Contract's term ended 31 December 2024, no January 2025 salary was owed. The Arbitrator rejected the Respondent's attempt to revive the optional-year claim, noting the coach had not appealed and had expressly waived it. Crucially, the club had paid the November and December 2024 salaries before the FIFA decision was issued; the coach admitted receipt but characterised them as compliance with the Decision rather than the Contract. The Arbitrator rejected that characterisation and held the club had discharged all obligations, warranting annulment of the Decision.

Why Urawa Red Diamonds v. Høgmo matters in CAS jurisprudence

The award reinforces that a final employment contract containing an entire-agreement clause conclusively displaces any prior pre-employment agreement, even where the coach submits only the pre-contract to FIFA. It also establishes that a coach's failure to disclose to FIFA that contractually owed salaries have already been paid — prior to the issuance of a decision — can vitiate the entire compensation award, warranting annulment at CAS. The case further confirms the 'point-of-no-return' doctrine for determining the operative date of unilateral termination in coaching disputes.

Cases cited in this award

CAS 2007/A/1394 CAS 2015/A/3999 & 4000 CAS 2019/A/6626 CAS 2017/A/5481 CAS 2017/A/5336 CAS 2022/A/8963

Frequently asked questions about Urawa Red Diamonds v. Høgmo

Why did CAS annul the FIFA PSC decision in Urawa Red Diamonds v. Høgmo?

The Sole Arbitrator found that the club had already paid the November 2024 salary (25 November 2024) and December 2024 salary (23 December 2024) to the coach before the FIFA PSC decision was issued on 28 January 2025. The coach admitted receiving those payments but failed to notify FIFA, causing the PSC to include them in its compensation calculation. Because the club had discharged all financial obligations prior to the decision, the award of EUR 183,274.50 was annulled.

Which contract governed in Urawa v. Høgmo — the pre-employment agreement or the final contract?

The final employment contract executed on 31 January 2024 governed the relationship. Its Article 29 contained an entire-agreement clause expressly stating it 'supersedes any prior written or oral agreements.' The pre-employment agreement's own preamble anticipated that a future coaching agreement would be entered into, and the Sole Arbitrator held that the Contract had clearly superseded the Pre-Contract. The FIFA PSC had erroneously relied solely on the pre-contract.

Was Høgmo entitled to a January 2025 salary as part of his compensation for wrongful termination?

No. The Sole Arbitrator held that the Contract's term ran only from 1 February 2024 to 31 December 2024, with no January 2025 obligation under the governing contract. The January 2025 salary had been included by the FIFA PSC based on language in the pre-employment agreement — specifically the phrase defining a contract year as running to 31 January of the following year — which did not appear in the final Contract. The PSC therefore erred in including it.

What was the operative termination date in Urawa v. Høgmo and why does it matter?

The Sole Arbitrator fixed the termination date as 26 August 2024 — the date of the meeting at which the club offered mutual termination — rather than 3 September 2024 when the club confirmed termination in writing. Applying the 'point-of-no-return' doctrine, the offer of mutual termination was treated as a formal act of unilateral termination after which the coach could not reasonably be expected to continue the employment relationship. This meant the residual value of the Contract ran from 27 August 2024 to 31 December 2024.

Topics: Art. 17 RSTP & contract termination at CAS

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