CAS Case Digest · Verified against the full award text

CAS 2025/A/11780 — Willem II Tilburg B.V. v. C.D. Mirandés S.A.D & FIFA

"Willem II v. Mirandés" · Training compensation claim dismissed as time-barred by one day because TMS record, not RFEF player passport, governs registration date.

What happened in Willem II v. Mirandés

Willem II Tilburg loaned Greek player Nikolaos Michelis (born 23 March 2001) from A.C. Milan from July 2021 to June 2022 under a loan agreement with a purchase option, which Willem II did not exercise. A.C. Milan then permanently transferred the player to C.D. Mirandés on 30 July 2022. The RFEF confirmed receipt of the player's ITC in FIFA TMS on 4 August 2022, completing registration. Willem II lodged a claim for EUR 61,680.00 in training compensation before the FIFA DRC on 5 September 2024 — one day after the two-year limitation period expired on 4 September 2024. The FIFA DRC Single Judge declared the claim inadmissible and ordered Willem II to pay USD 10,000 in procedural costs. Willem II appealed to CAS, arguing the player was registered on 5 August 2022 per the RFEF player passport, making its claim timely. CAS dismissed the appeal, confirming that the TMS record is the authoritative and primary source for establishing a player's international registration date, and that the RFEF player passport — dated 3 December 2024 and reflecting only license activation — cannot supersede TMS data. The case matters because it definitively establishes TMS as the exclusive evidentiary reference for registration dates in training compensation limitation-period calculations.

Procedural history of CAS 2025/A/11780

On 5 September 2024, Willem II Tilburg B.V. filed a claim before the FIFA Dispute Resolution Chamber against C.D. Mirandés seeking EUR 61,680.00 in training compensation plus 5% p.a. default interest, arising from the permanent transfer of player Nikolaos Michelis from A.C. Milan to C.D. Mirandés in August 2022. On 12 March 2025, the Single Judge of the FIFA DRC declared the claim inadmissible (case TMS 14594), finding it was lodged one day after the two-year limitation period under Article 23 paragraph 3 of FIFA RSTP, which expired on 4 September 2024 based on the player's TMS-confirmed registration date of 4 August 2022. The Single Judge also ordered Willem II to pay USD 10,000 in procedural costs. The grounds of the decision were communicated on 8 September 2025. Willem II filed its Statement of Appeal with CAS on 19 September 2025, requesting the Appealed Decision be set aside and the claim declared admissible. The matter was decided on written submissions without a hearing.

Key holdings in CAS 2025/A/11780

• The FIFA TMS record is the primary and authoritative source for establishing a player's registration date following an international transfer, as registration is mandatorily handled and completed via TMS under Articles 5.2 paragraph 4 and 8.2 paragraph 5 of Annexe 3 of FIFA RSTP.
• A player passport issued by a national association reflects only the date of license activation for federative purposes and does not constitute definitive or binding evidence of the registration date under the FIFA RSTP international transfer procedure.
• Where TMS data and a national association's player passport conflict on registration date, TMS data prevails and cannot be superseded by the passport.
• The two-year limitation period under Article 23 paragraph 3 of FIFA RSTP begins on the 31st day following the player's registration, when the training compensation obligation becomes overdue, and must be applied strictly without reference to subjective considerations.
• A party's acknowledgment during proceedings of a particular registration date is irrelevant to establishing that date, which must be determined by reference to objective facts and data.

How the CAS panel reasoned

The Sole Arbitrator identified the central issue as purely factual: whether the player was registered on 4 or 5 August 2022. He began by examining Articles 5.2 paragraph 4 and 8.2 paragraph 5 of Annexe 3 of FIFA RSTP, which mandate that the new association confirm and complete player registration information in TMS upon ITC receipt. Supported by the FIFA Commentary on RSTP (2023 edition), he concluded that registration in international transfers is invariably finalized in TMS, making TMS the direct and exclusive record of that procedure. Since Willem II did not contest the accuracy of the TMS record — which showed RFEF confirmation on 4 August 2022 — the Arbitrator found no basis to depart from it. He rejected the RFEF player passport as merely an internal administrative document reflecting license activation, noting it was dated 3 December 2024 and thus could not have been relied upon when the claim was filed. He dismissed the Electronic Player Passport (EPP 28990) as irrelevant because it was generated after the transfer in question and did not reflect contemporaneous TMS data. He also rejected the contra proferentem argument, finding no ambiguity in the term 'registration.' Finally, invoking the principle of procedural predictability, he held that Willem II had two years and thirty-one days from registration to file its claim — ample time to verify the facts — and that deadlines must be applied strictly.

Why Willem II v. Mirandés matters in CAS jurisprudence

This award establishes a clear evidentiary hierarchy for training compensation disputes: the FIFA TMS record is the sole authoritative reference for determining a player's international registration date, overriding national association player passports. It also confirms that the two-year limitation period under Article 23 paragraph 3 of FIFA RSTP is applied strictly, with no equitable relief for clubs that rely on unofficial documents, and that procedural predictability demands diligence in verifying registration dates through official FIFA channels.

Frequently asked questions about Willem II v. Mirandés

Why was Willem II's training compensation claim dismissed in Willem II v. Mirandés?

The claim was filed on 5 September 2024, one day after the two-year limitation period under Article 23 paragraph 3 of FIFA RSTP expired on 4 September 2024. The expiry date was calculated from 4 August 2022, the date the RFEF confirmed receipt of the player's ITC in TMS, which the Sole Arbitrator held was the player's registration date. Because the claim was lodged one day late, it was declared inadmissible.

Does a national association player passport prove a player's registration date for training compensation purposes?

No. In Willem II v. Mirandés, CAS held that a player passport issued by a national association — in this case the RFEF — is merely an internal administrative document reflecting the date of license activation, not the date of registration under the FIFA RSTP international transfer procedure. Where the passport conflicts with the TMS record, the TMS record prevails as the primary and authoritative source.

What is the authoritative source for a player's registration date in an international transfer under FIFA rules?

The FIFA TMS record is the authoritative source. Under Articles 5.2 paragraph 4 and 8.2 paragraph 5 of Annexe 3 of FIFA RSTP, the new association must confirm and complete player registration information in TMS upon ITC receipt. The Sole Arbitrator in Willem II v. Mirandés confirmed that registration is mandatorily handled and finalized in TMS, making the TMS record the direct and exclusive evidence of that date.

Can a club rely on the contra proferentem rule to argue ambiguity in the word 'registration' under FIFA RSTP training compensation provisions?

No. In Willem II v. Mirandés, CAS rejected the contra proferentem argument, finding there was no ambiguity in the term 'registration' as used in Article 3 of Annexe 4 of FIFA RSTP. The Sole Arbitrator held that because registration in international transfers is unambiguously completed via TMS, there was no need to interpret the term or to apply any rule resolving ambiguity in favour of the claiming party.

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.