CAS Case Digest · Verified against the full award text

CAS 2025/A/11897 — Asociatia Club Sportiv Fotbalistic Oradea v. Ober Yesid Almanza Sehuanes & FIFA

"ACSF Oradea v. Almanza & FIFA" · CAS dismissed as inadmissible a Romanian club's appeal against a FIFA DRC compensation award and registration ban, because the club failed to monitor its own TMS-registered email address and filed its appeal outside the 21-day deadline.

What happened in ACSF Oradea v. Almanza & FIFA

ACSF Oradea, a Romanian football club, signed Colombian player Ober Yesid Almanza Sehuanes to an employment contract on 24 July 2024, valid until 30 June 2027. The player lodged a claim before the FIFA Dispute Resolution Chamber (DRC) on 2 February 2025. FIFA notified the club via the FIFA Legal Portal and courtesy emails to caoradea@gmail.com — the email address registered in the Transfer Matching System (TMS) for the club. The club never responded. On 8 August 2025, the DRC ordered the club to pay EUR 3,000 in outstanding remuneration and EUR 87,000 in compensation for breach of contract, both with 5% interest p.a. from 2 February 2025. The club did not comply, and on 7 October 2025 the Head of FIFA Disciplinary imposed a registration ban. The club filed its CAS appeal on 29 October 2025, claiming it had never been properly notified because caoradea@gmail.com belonged to a different club. CAS held that FIFA's notifications were valid under the Procedural Rules, that TMS-registered contact details are binding and create an irrebuttable presumption of notification, and that the appeal was filed after the 21-day deadline for both decisions. The appeal was declared inadmissible. The case underscores clubs' strict obligation to keep TMS contact details current and to monitor the FIFA Legal Portal daily.

Procedural history of CAS 2025/A/11897

On 2 February 2025, the player filed a claim before the FIFA DRC (reference FPSD-18048). FIFA notified the club via the FIFA Legal Portal and courtesy emails to caoradea@gmail.com, the address registered in TMS. The club never responded. On 8 August 2025, the DRC issued its decision ordering the club to pay EUR 3,000 in outstanding remuneration and EUR 87,000 in compensation, both with 5% interest p.a. from 2 February 2025. The decision was notified on 18 August 2025; neither party requested the grounds. On 4 October 2025, the player notified the FIFA Disciplinary Committee of non-compliance. On 7 October 2025, the Head of FIFA Disciplinary imposed a registration ban (reference FDD-25517), notified on 7 October 2025. The club learned of the ban from the Romanian Football Federation on 8 October 2025. On 29 October 2025, the club filed a Statement of Appeal with CAS against both decisions, one day after the 21-day deadline for the FDD Decision and well after the deadline for the DRC Decision.

Key holdings in CAS 2025/A/11897

• FIFA's notifications via the FIFA Legal Portal to the email address registered in TMS constituted valid notification under Article 10 of the Procedural Rules Governing the Football Tribunal, regardless of whether the club actually accessed the communications.
• Article 10(3) of the Procedural Rules creates an irrebuttable presumption of notification: once a decision is communicated through the Legal Portal to TMS-registered contact details, the party is deemed to have received it.
• Under Article 7 of Annex 3 of the RSTP, clubs bear sole responsibility for ensuring their TMS contact details are accurate and up to date; failure to do so cannot excuse non-compliance with appeal deadlines.
• The 21-day appeal deadline under Article 50(1) of the FIFA Statutes runs from the date of valid notification and cannot be extended; the club's appeal filed on 29 October 2025 was out of time for both the DRC Decision (notified 18 August 2025) and the FDD Decision (notified 7 October 2025).
• A club's claim that it was unaware of FIFA proceedings is undermined where it never demonstrated daily monitoring of TMS or the FIFA Legal Portal as required by Article 10(3) of the Procedural Rules.

How the CAS panel reasoned

The Sole Arbitrator first confirmed that FIFA had correctly applied its notification rules: all communications were sent via the FIFA Legal Portal, supplemented by courtesy emails to caoradea@gmail.com, the address the club itself had registered in TMS. The club's own TMS Manager acknowledged this address on 28 October 2025 when requesting its change, which the arbitrator treated as a clear admission that it was the operative address throughout the proceedings. The arbitrator applied the principle, confirmed in CAS 2023/A/9780 and consistent with Swiss law, that notification is complete when the party has the opportunity to access the communication, not when it actually reads it. He rejected the club's argument that the address belonged to a different club, noting the address was unambiguously linked to Club ID 69577 in TMS. He also dismissed the club's diligence argument: the player's letter of 6 February 2025, copied to FIFA and FIFPro, should have prompted the club to check the Legal Portal systematically. The arbitrator further noted that even after learning of the FDD Decision on 8 October 2025, the club still missed the 28 October 2025 deadline by one day. The player's alleged bad faith in not disclosing his FIFA claim was rejected because the player had no reason to believe the club was unaware of proceedings it had been formally notified of.

Why ACSF Oradea v. Almanza & FIFA matters in CAS jurisprudence

This award reinforces the strict, irrebuttable nature of TMS-based notification in FIFA proceedings and confirms that clubs cannot escape adverse decisions by neglecting to maintain accurate TMS contact details or to monitor the FIFA Legal Portal daily. It aligns with the line of CAS authority holding that the relevant moment for notification is receipt, not actual knowledge, and that 21-day appeal deadlines are absolute. The case serves as a cautionary precedent for clubs operating with outdated or incorrectly registered TMS email addresses.

Cases cited in this award

CAS 2025/A/11192 CAS 2024/A/10880 CAS 2024/A/10325 CAS 2023/A/9780 CAS 2022/A/9010 CAS 2019/A/6294

Frequently asked questions about ACSF Oradea v. Almanza & FIFA

Why was ACSF Oradea's CAS appeal against the FIFA DRC decision declared inadmissible?

The club filed its Statement of Appeal on 29 October 2025, which was after the 21-day deadline under Article 50(1) of the FIFA Statutes for both the DRC Decision (notified 18 August 2025, deadline 8 September 2025) and the FDD Decision (notified 7 October 2025, deadline 28 October 2025). CAS held that FIFA had validly notified both decisions via the FIFA Legal Portal to the email address caoradea@gmail.com, which was the address registered in TMS for the club, and that this created an irrebuttable presumption of notification under Article 10(3) of the Procedural Rules.

Can a club argue it was not properly notified because FIFA used the wrong email address?

Not if that email address was the one the club itself registered in TMS. In this case, CAS found that caoradea@gmail.com was unambiguously linked to ACSF Oradea's Club ID 69577 in TMS, and the club's own TMS Manager confirmed this by requesting a change to that address on 28 October 2025. Under Article 10(3) of the Procedural Rules, TMS-registered contact details are binding on the party that provided them, and clubs bear sole responsibility under Article 7 of Annex 3 of the RSTP for keeping those details accurate and up to date.

What did the FIFA DRC award the player against ACSF Oradea?

On 8 August 2025, the DRC ordered ACSF Oradea to pay EUR 3,000 as outstanding remuneration and EUR 87,000 as compensation for breach of contract, both amounts carrying 5% interest per annum from 2 February 2025 until the date of effective payment. When the club failed to pay within 45 days, a registration ban was imposed on 7 October 2025 pursuant to Article 24 of the RSTP.

Does a club have to monitor the FIFA Legal Portal and TMS even if it believes proceedings have not been started against it?

Yes. Article 10(3) of the Procedural Rules requires parties to review TMS and the FIFA Legal Portal at least once per day and holds them responsible for any procedural disadvantages arising from failure to do so. In this case, CAS noted that the player's letter of 6 February 2025, copied to FIFA and FIFPro, should have alerted the club to check the Legal Portal systematically, and that the club never claimed to have done so or demonstrated any technical obstacle to access.

Topics: Transfers, agents, TPO & sell-on clauses at CAS

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