CAS Case Digest · Verified against the full award text

CAS 2025/A/11852 — FC Olexandriya v. FC Polissya

"Olexandriya v. Polissya" · CAS overturned UAF DRC's dismissal and awarded FC Olexandriya UAH 4,610,965.20 in outstanding training compensation for player Mustafayev.

What happened in Olexandriya v. Polissya

FC Olexandriya claimed training compensation from FC Polissya after player Emil Ramil Ogli Mustafayev (born 24 September 2001) was registered with Polissya on 1 July 2023, triggering an obligation under the UAF RSTP. Olexandriya calculated compensation at UAH 5,954,892.00 (total remuneration of UAH 1,488,723.00 multiplied by the age coefficient of 4), later reduced to UAH 4,610,965.20 after Polissya's partial payment of UAH 1,343,927.80 on 2 November 2023. The UAF DRC dismissed Olexandriya's claim in full on 28 May 2025, holding that the contested remuneration had not been proven by primary accounting documents compliant with Ukrainian law. Olexandriya appealed to CAS. The Sole Arbitrator held that the UAF RSTP establishes no hierarchy of evidence and does not preclude reliance on other credible documentation where primary accounting records are absent. Reviewing the full evidentiary record — salary certificates, banking records, handwritten ledgers, cash vouchers, expert handwriting reports, witness testimony, and bonus payments corroborated by publicly verifiable match data — the Sole Arbitrator was comfortably satisfied that the Player's remuneration for the relevant twelve months was at least UAH 1,488,723.00. The appeal was partially upheld, the UAF DRC decision set aside, and Polissya ordered to pay UAH 4,610,965.20 plus interest. The case matters because it clarifies that absence of primary accounting documents does not automatically bar a training compensation claim under the UAF RSTP.

Procedural history of CAS 2025/A/11852

On 19 October 2023, FC Olexandriya filed a claim before the UAF Dispute Resolution Chamber (case No. 362/11/2023) seeking training compensation following the Player's registration with Polissya on 1 July 2023. Polissya made a partial payment of UAH 1,343,927.80 on 2 November 2023. Olexandriya reduced its claim to UAH 4,610,965.20. After extensive proceedings including hearings, witness evidence and supplementary submissions, the UAF DRC rendered its decision on 28 May 2025, dismissing Olexandriya's claim in full on the ground that the contested remuneration had not been proven by primary accounting documents under Ukrainian law. The grounds were communicated on 25 September 2025. Olexandriya filed a Statement of Appeal with CAS on 16 October 2025 under Articles R47 and R48 of the CAS Code, initially against both the UAF and Polissya, withdrawing the appeal against the UAF on 2 November 2025. The Appeal Brief was filed on 6 November 2025 and Polissya's Answer on 27 November 2025. A videoconference hearing was held on 4 March 2026, and evidentiary proceedings closed on 7 April 2026.

Key holdings in CAS 2025/A/11852

• The UAF RSTP establishes no hierarchy of evidence and does not require training compensation claims to be proven exclusively by primary accounting documents as defined under Ukrainian law.
• Article 4 para. 5 of Annex 1 to the UAF RSTP grants the UAF DRC a discretion to request primary accounting documents; the UAF DRC's failure to exercise that discretion before dismissing the claim on that very ground was problematic and most likely violated the Appellant's right to be heard.
• The 'inner conviction' standard in the UAF DRC Regulations is equivalent to the 'personal conviction' standard in the FIFA Disciplinary Code and is akin to the CAS standard of comfortable satisfaction, which applies to training compensation disputes.
• A holistic assessment of multiple corroborating evidentiary elements — including salary certificates, banking records, handwritten ledgers, cash vouchers, expert handwriting reports, witness testimony, and bonus payments linked to objectively verifiable sporting events — can satisfy the comfortable satisfaction standard even in the absence of primary accounting documents.
• Applying the ne ultra petita principle, the Sole Arbitrator was bound by the Appellant's prayer for relief and awarded UAH 4,610,965.20 rather than the arithmetically higher figure of UAH 4,624,154.22 that the panel's own calculation produced.

How the CAS panel reasoned

The Sole Arbitrator first resolved the standard of proof dispute by tracing the UAF DRC Regulations' 'inner conviction' language to the 'personal conviction' standard in the FIFA Disciplinary Code, which CAS jurisprudence (including CAS 2021/A/7630) treats as equivalent to comfortable satisfaction. He rejected the Appellant's argument for a balance of probabilities standard, noting that CAS panels regularly apply comfortable satisfaction in football regulatory compensation disputes. On the evidentiary framework, the Sole Arbitrator disagreed with the UAF DRC's formalistic approach: Article 4 of Annex 1 to the UAF RSTP lists documentary examples without creating a hierarchy, and Article 4 para. 5 gives the DRC a discretion — not a duty — to request primary accounting documents, meaning their absence cannot automatically preclude other evidence. The panel then conducted a holistic review, finding that the Appellant's evidence was internally consistent, detailed, and covered multiple players rather than being tailored to one individual, making retrospective fabrication implausible. Bonus payments were cross-checked against publicly available match data. The cashier's testimony was found genuine. The Respondent offered no positive counter-evidence of fabrication. The panel was further comforted by the Player's salary at Polissya (UAH 5,661,838 gross in 2023/2024), finding it implausible that remuneration would have jumped from UAH 276,687.29 to that figure in a single season.

Why Olexandriya v. Polissya matters in CAS jurisprudence

This award establishes that under the UAF RSTP the absence of primary accounting documents does not automatically defeat a training compensation claim; a holistic, multi-source evidentiary record can satisfy the comfortable satisfaction standard. The Sole Arbitrator also flagged a regulatory gap, expressly inviting the UAF to amend its rulebook to clarify the evidentiary framework for training compensation disputes, signalling that the current rules are insufficiently clear on the interplay between primary accounting documents and other evidence.

Cases cited in this award

CAS 2021/A/7630

Frequently asked questions about Olexandriya v. Polissya

Why did CAS overturn the UAF DRC decision in Olexandriya v. Polissya?

The UAF DRC dismissed Olexandriya's claim solely because the contested remuneration was not proven by primary accounting documents compliant with Ukrainian law. The CAS Sole Arbitrator held that the UAF RSTP establishes no hierarchy of evidence and does not preclude reliance on other credible documentation. He also found it problematic that the UAF DRC had not exercised its discretion under Article 4 para. 5 of Annex 1 to the UAF RSTP to request such documents before dismissing the claim on that ground.

How was training compensation calculated in the Olexandriya v. Polissya case?

Under Article 4 para. 1 of Annex 1 to the UAF RSTP (2021 edition), compensation equals total salary and bonuses accrued during the last 12 months of contractual employment multiplied by the applicable age coefficient. The Sole Arbitrator found the Player's remuneration for the relevant period to be UAH 1,488,723.00 and applied the undisputed coefficient of 4, yielding UAH 5,954,892.00 in total training compensation. After deducting Polissya's partial payment, the outstanding balance awarded was UAH 4,610,965.20.

What standard of proof applies to training compensation disputes at CAS under UAF regulations?

The Sole Arbitrator held that the 'inner conviction' language in Article 20.6 of the UAF DRC Regulations is equivalent to the 'personal conviction' standard in the FIFA Disciplinary Code, which CAS jurisprudence (citing CAS 2021/A/7630) treats as akin to comfortable satisfaction. The panel therefore applied the comfortable satisfaction standard rather than the balance of probabilities standard advocated by Olexandriya.

Can handwritten notebooks and cash vouchers be used as evidence in a UAF training compensation dispute?

Yes, according to this award. The Sole Arbitrator held that the UAF RSTP does not establish a hierarchy of evidence or exclude non-primary-accounting documents. Handwritten ledgers, cash payment vouchers, expert handwriting reports, and witness testimony can all be considered, though their weight depends on internal consistency and corroboration. In this case, those documents were accepted because they were internally consistent, covered multiple players, and were corroborated by banking records and publicly verifiable match data confirming the sporting events linked to bonus payments.

Topics: Training compensation & solidarity at CAS

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