FIFA - CAS & Football Annual Report 2024
FIFA - Federación Internacional de Fútbol
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- FIFA - CAS & Football Annual Report 2024
- Autor
- FIFA - Federación Internacional de Fútbol
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- Infralegal
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- 2024
CAS & Football Annual Report 2024
FEBRUARY 20252
Contents Foreword 4 01 Overview 5 02 T otal Number of Appeals 8 2.1 Overall appeals 9 2.2 Appeals where FIFA is Not a Party and FIFA’s exclusion 11 2.3 Appeals where FIFA is a Party 12 2.4 Appeals by FIFA body 13 03 CAS Hearings in 2024 15 04 CAS Awards involving FIFA received in 2024 17 4.1 Introduction 18 4.2 Outcome of the Awards on the Merits 20 05 Length of CAS proceedings 21 5.1 Introduction 22 5.2 Average duration of the cases (awards) received in 2024 22 5.3 Average duration of the cases with/without hearing 23 06 CAS Global Football Statistics 24 6.1 Introduction 25 6.2 Evolution of the global CAS caseload 25 6.3 Football-related cases handled by CAS 26 6.4 T ype of procedure 27 6.5 Source of the appealed decisions 28 6.6 Subject of the appealed decisions 29 6.7 Language 303 07 FIFA cases during the Olympic games 31 7.1 Introduction 32 7.2 Summary of the cases 32 08 Leading cases in 2024 in appeals against FIFA decisions 39 8.1 Introduction 40 8.2 Football T ribunal 41 8.3 Judicial Bodies 99 8.4 Other FIFA bodies 120 8.5 Orders on provisional measures 123 09 Swiss Federal T ribunal 125 9.1 Introduction 126 9.2 Appeals filed against CAS awards involving FIFA 126 9.3 Decisions rendered in 2024 in appeals against CAS football decisions 127 10 Arbitrators appointed in 2024 130 10.1 Composition of the Panels in 2024 131 10.2 Appointments in 2024 132 11
9.3 Decisions rendered in 2024 in appeals against CAS football decisions 127 10 Arbitrators appointed in 2024 130 10.1 Composition of the Panels in 2024 131 10.2 Appointments in 2024 132 11 Report on the Football Legal Aid Fund 133 11.1 Introduction 134 11.2 Requests and granted legal aid 134 12 Publication of CAS Awards 136 13 Final Remarks 1384 Foreword Dear readers, We are pleased to present the 3 rd edition of the CAS & Football Annual Report, covering the period from 1 January 2024 to 31 December 2024. Continuing the trend of its first two editions, the CAS & Football Annual Report 2024 outlines FIFA’s workload regarding appeals submitted against its decisions before the Court of Arbitration for Sport (CAS), as well as providing a general overview of football’s involvement in arbitration before CAS during the last year. The purpose of this document remains to highlight the key activities and statistics of the FIFA Legal & Compliance Division for 2024, particularly in relation to CAS appeals. It aims to provide stakeholders and legal practitioners with a comprehensive overview of the most important CAS jurisprudence from this period and to transparently address other relevant issues concerning FIFA, football, and CAS. This Report highlights that, following a significant year for CAS litigation in 2023, the last year has seen a notable decrease in the number of appeals against FIFA decisions, as well as in the cases in which FIFA has been involved as a party. Nevertheless, the number of CAS proceedings in these circumstances remains substantial, consistent with the activity of the FIFA Legal & Compliance Division throughout the year. In addition, the year 2024 has produced a similarly large number of awards that have been notified to FIFA. As always, this report provides summaries of the most significant of these CAS awards related to appeals made against FIFA decisions. We trust that this summary of the main activities of the FIFA Legal & Compliance Division throughout the year will be a useful resource for stakeholders and legal practitioners involved in CAS proceedings. Y ours faithfully,
significant of these CAS awards related to appeals made against FIFA decisions. We trust that this summary of the main activities of the FIFA Legal & Compliance Division throughout the year will be a useful resource for stakeholders and legal practitioners involved in CAS proceedings. Y ours faithfully, Emilio García Silvero FIFA Chief Legal & Compliance Officer Miguel Liétard Fernández-Palacios Director of LitigationOverview 0101 Overview 6 Overview Article 49 of the FIFA Statutes (ed. 2024) recognizes the jurisdiction of Court of Arbitration for Sport (CAS) to handle appeals against final decisions issued by the different bodies of FIFA. The decisions of the different FIFA bodies on several topics are continuously appealed and, therefore, continually reviewed by CAS. The FIFA Legal & Compliance Division plays a crucial role by serving as the primary point of contact between FIFA and CAS. Specifically, the Litigation department handles all appeals submitted to CAS regarding FIFA’s decisions. The CAS & Football Report 2024 offers a comprehensive overview of the CAS appeals against FIFA decisions and other significant issues related to CAS for the period from 1 January 2024 to 31 December 2024. In 2024, CAS notified 326 appeals to FIFA, which had been filed against the latter’s decisions. Naturally, FIFA did not have a legal interest in the majority of these disputes, especially those originating from the FIFA Football Tribunal, as they did not involve FIFA’s prerogatives or disciplinary powers. This meant that FIFA had nothing directly at stake in these cases. Consequently, as in previous editions, these appeals can be categorized into three types: (i) cases in which FIFA was not involved as a party, (ii) cases where FIFA (successfully) requested to be excluded from the proceedings, and (iii) cases in which FIFA was a party. This document also provides a detailed overview of the outcomes of cases involving FIFA, focusing on the awards received during the period under scrutiny. A total of 139 CAS awards/orders in which FIFA was a party were notified in 2024. As always,
and (iii) cases in which FIFA was a party. This document also provides a detailed overview of the outcomes of cases involving FIFA, focusing on the awards received during the period under scrutiny. A total of 139 CAS awards/orders in which FIFA was a party were notified in 2024. As always, it is recalled that not all cases result in awards based on the merits, and we, therefore, distinguish between Awards on the Merits, Awards on Costs, Termination Orders, and Consent Awards. In line with the prevailing trend, in most CAS cases involving FIFA, the appealed decisions are either fully confirmed (meaning the appeal is entirely dismissed) or confirmed on the merits but with amendments made for proportionality or on the basis of new evidence filed for the first time in the CAS proceedings (leading to the relevant appeal being partially upheld).01 Overview 7 In 2024, out of 78 Awards on the merits in cases involving FIFA, 58 (74%) upheld FIFA’s decisions, either dismissing the appeal entirely or partially. Additionally, 15 cases (19%) annulled the appealed decision or sent the case back to the relevant FIFA body, while 5 cases (7%) declared the appeal inadmissible. Additionally, this document presents global statistics on football-related cases held in CAS, which are not directly tied to FIFA decisions (i.e. decisions from member associations and confederations). The CAS & Football Annual Report further provides a summary of the most relevant awards notified in 2024, divided by topics, among them: Football Tribunal Judicial Bodies The Disciplinary Committee and Appeal Committee Ethics Committee Other FIFA Bodies Orders on provisional measures A separate section has been devoted to the first three football-related cases in the history of the Olympic Games, decided by the CAS Ad hoc Division for the Olympic Games Paris 2024. This report also addresses the appeals of CAS Awards related to football before the Swiss Federal Tribunal (SFT) in 2024, along with a summary of the significant cases. FIFA also continues its commitment to transparency by disclosing the names of the arbitrators it has appointed in proceedings before CAS.
This report also addresses the appeals of CAS Awards related to football before the Swiss Federal Tribunal (SFT) in 2024, along with a summary of the significant cases. FIFA also continues its commitment to transparency by disclosing the names of the arbitrators it has appointed in proceedings before CAS. Finally, the report includes updated information about the FIFA-CAS Football Legal Aid Fund (FLAF), which began operating on 1 February 2023. It highlights the number of requests received, the number that were approved and the amounts that have been granted to clubs, players, coaches, officials and agents.T otal Number of Appeals 0202 T otal Number of Appeals 9 2.1 Overall appeals From 1 January 2024 until 31 December 2024, the Football Tribunal, the Judicial Bodies, other FIFA organs and committees and the FIFA General Secretariat alone issued more than 33,000 1 decisions. During the same period, a total of 326 appeals were filed before CAS against various decisions, including those made by other FIFA bodies.
In summary, of the 33,000 decisions issued by FIFA in 2024, only about 1% were appealed to CAS. In 2024, the number of appeals decreased by 24% compared to 2023, which equals 105 less cases. Out of the 326 appeals filed against FIFA decisions in 2024, FIFA was involved in 117 (36%) of them, whereas it was not involved in 209 (64%) cases (183 cases in which FIFA was not called as a respondent, and 26 in which FIFA was initially named as a respondent but was later withdrawn). 1 Including Clearing House decisions or Confirmation Letters derived from Proposals of the FIFA Administration. 326 T otal appeals 2018 2019 2020 2021 2022 2023 2024
Y ear 270 189 545 492 360 431 32602 T otal Number of Appeals 10 FIFA called as a party FIFA not called as a party FIFA excluded T otal Appeals before CAS 183 | 56% 326 | 100% Total 26 | 8% 117 | 36%02 T otal Number of Appeals 11 2.2 Appeals where FIFA is Not a Party and FIFA’s exclusion Of the decisions issued by FIFA bodies that are appealed to CAS, most of those made by the Football Tribunal involve contractual disputes between clubs, players, coaches and/or agents, with FIFA serving only as the deciding body. Most appeals against decisions made by the Football Tribunal are solely directed toward the counterparty involved in the dispute, in which FIFA does not have a legal interest in the so-called ‘horizontal’ dispute. Occasionally, FIFA is named as a respondent even though its participation is not legally required in these cases. In such instances, FIFA requests to be excluded from the proceedings. The exclusion occurs only when the appellant agrees to withdraw its appeal against FIFA, allowing the case to continue between the parties involved in the disputed contract. Over the years, FIFA has been minimally involved in appeals regarding decisions made by the Football Tribunal. As is generally the case, between 60% and 75% of appeals against FIFA decisions do not require FIFA’s presence as a respondent. As advanced, when looking specifically at the year 2024, FIFA was not called or was (successfully) excluded as a party in 64% of the 326 cases filed before CAS against FIFA decisions. In other words, FIFA was actively involved in only 36% of these appeals. The table below shows the number of cases in which FIFA was either not summoned or was eventually excluded from the CAS proceedings in recent years. FIFA not a party
2018 2019 2020 2021 2022 2023 2024 Y ear 19 13 20 30 9 24 26 Exclusion 106 88 324 338 240 232 18302 T otal Number of Appeals 12 2.3 Appeals where FIFA is a Party It is worth recalling that, as described in the CAS & Football Annual Report 2023 , the number of cases in which FIFA has been a party drastically increased that year, in part due to the large number of appeals in the context of the new FIFA Clearing House system. In contrast, in 2024, with the steady resolution of contractual disputes and cases before the Judicial Bodies, the number of cases involving FIFA has significantly decreased by 33% (i.e., 58 fewer cases in which FIFA has been called and maintained as a party). FIFA as a party 2018 2019 2020 2021 2022 2023 2024 Y ear 82 88 201 124 111 175 11702 T otal Number of Appeals 13 2.4 Appeals by FIFA body The majority of appeals to CAS against FIFA decisions have generally come from the Football Tribunal (i.e., the PSC and DRC). In 2024, the appeals where FIFA was a party were filed against decisions issued by the following FIFA bodies and departments 2:
In a surprising turn compared to previous years in which appeals against decisions of the FIFA Football Tribunal and Judicial Bodies constituted the majority of appeals against FIFA decisions as a whole, 2024 has seen decisions from the FIFA Clearing House become the main source of CAS appeals, in line with the increased number of cases arising from that department and with the tendency already seen in 2023, as well as with the lesser number of appeals against Football Tribunal decisions in which FIFA was called as a party in the last year. 2 The 209 cases in which FIFA was not a party relate to appeals against decisions of the Football T ribunal. FIFA Body Cases % Football T ribunal 74 63%
as well as with the lesser number of appeals against Football Tribunal decisions in which FIFA was called as a party in the last year. 2 The 209 cases in which FIFA was not a party relate to appeals against decisions of the Football T ribunal. FIFA Body Cases % Football T ribunal 74 63% Football T ribunal (PSC + DRC) 36 31 Clearing House 38 32 Judicial Bodies 34 29% Disciplinary + Appeal Committees 32 27 Ethics Committee 2 2 Agents 7 6% Other 2 2% To t a l 117 100%02 T otal Number of Appeals 14 63% 65%3% 2% 30% 175 | 100% 117 | 100%2023 2024 Total Total 2% 6% 29% Comparison Judicial Bodies 52 Disciplinary + Appeal Committees 47 Ethics Committee 5 Football T ribunal 114
PSC + DRC 81
Clearing House 33 Institutional Bodies 6 Others (Agents, etc.) 3 Judicial Bodies 34 Disciplinary + Appeal Committees 32 Ethics Committee 2 Football T ribunal 74
PSC + DRC 36
Clearing House 38 Institutional Bodies 7 Others (Agents, etc.) 2 2024202303 CAS Hearings in 202403 CAS Hearings in 2024 16 CAS Hearings in 2024 During 2024, FIFA participated in 72 CAS hearings. Compared to the previous year, the number of hearings in cases in which FIFA was a party doubled (i.e., 36 hearings in 2023). Although the modality of the hearings in which FIFA participated (in-person vs. virtual) was divided evenly in 2023 (50%-50%), hearings by videoconference have clearly been the most common option favoured by CAS in 2024, with almost two-thirds (specifically, 65%) of hearings being held virtually
Although the modality of the hearings in which FIFA participated (in-person vs. virtual) was divided evenly in 2023 (50%-50%), hearings by videoconference have clearly been the most common option favoured by CAS in 2024, with almost two-thirds (specifically, 65%) of hearings being held virtually and the rest being held in-person (29%) or in a hybrid format (6%). Although the move of the FIFA Legal & Compliance Division to Miami, USA, in August 2024 may have contributed to the increase in the number of hearings held online, other factors, such as the larger number of hearings held in 2024, have also played a role in this particular aspect. This has, however, not prevented in-person hearings from taking place (albeit more exceptionally) in cases in which FIFA is a party, including the first hearing held in Miami in November 2024. In addition, in four of the hearings that took place in 2024, FIFA was either excused from attending or voluntarily chose not to attend (as allowed under Article R57 CAS Code) in light of the exclusively “horizontal” nature of the dispute between the parties in which the respective appellants had not agreed to withdraw the appeal against FIFA. 65%50% 50% 36 | 100% 72 | 100% Total Total 5% 29% Comparison 2023 Comparison 2024 In-person 18 Virtual 18 T ype of hearing Number In-person 21 Virtual 47 Hybrid 4 T ype of hearing Number04 CAS Awards involving FIFA received in 202404 CAS Awards involving FIFA received in 2024 18 4.1 Introduction From 1 January 2024 until 31 December 2024, FIFA received 139 decisions from CAS in cases where it was involved as a party. As explained in previous editions, it is important to note that not all cases result in a decision being made on the merits. Many cases are resolved through Termination Orders, Awards on Costs, or Consent Awards, often because the appeals are withdrawn, or the parties involved reach a settlement.
As explained in previous editions, it is important to note that not all cases result in a decision being made on the merits. Many cases are resolved through Termination Orders, Awards on Costs, or Consent Awards, often because the appeals are withdrawn, or the parties involved reach a settlement. With this in mind, we categorize the CAS decisions that FIFA received in 2024 in cases in which it had been a party, into the following groups: The table below shows the number of CAS decisions received since 2018 in which FIFA was a party. 56% 139 | 100% Total 44% T ermination Orders/Awards on Costs/ Consent Awards 61 Awards on the Merits 78 T ype of hearing Number Awards on the merits To t a l 2018 2019 2020 2021 2022 2023 2024 Y ear 84 60 121 144 113 136 139 T ermination Orders/Awards on Costs/ Consent Awards 42 42 27 33 64 57 46 98 61 52 57 79 78 6104 CAS Awards involving FIFA received in 2024 19 It is important to note that although this report refers to the CAS awards received in 2024 in which FIFA was a party, some of these relate to legal proceedings that began already in 2021. Specifically, 5 awards on the merits originated from cases initiated in 2021, while 8 had started in 2022. Additionally, 55 concerned appeals that had been filed in 2023. Finally, 10 of the awards received in 2024 related to cases initiated and resolved in that same year, as illustrated in the graphical representation below. Awards on the merits T otal 78 T ermination Orders/Awards
on Costs/ Consent Awards T otal 61 2021 5 2022 8 3 1 2023 24 55 2024 10 33 Case start T otal 13904 CAS Awards involving FIFA received in 2024 20 4.2 Outcome of the Awards on the Merits Out of the 78 awards on the merits received by FIFA in 2024 in cases in which it had been summoned as a respondent, 58 (74%) either dismissed the appeal and confirmed the FIFA decision, or partially upheld the appeal whilst confirming the underlying reasoning of the challenged decision and amending specific aspects for proportionality. Meanwhile, 15 (19%) annulled the appealed decision or referred the case back to the relevant FIFA body, and 5 (7%) declared the appeal inadmissible. 7% CAS awards received in 2022: 61 AWARDS ON THE MERITS 2023: 79 AWARDS ON THE MERITS Upheld or Referred back Dismissed or Partially Upheld Inadmissible 74% 80%7% 9% 13% 10% 19%81% 2024: 78 AWARDS ON THE MERITSLength of CAS proceedings 0505 Length of CAS proceedings 22 5.1 Introduction In addition to the 78 CAS awards received in 2024, in which FIFA was directly involved, FIFA has also received 117 awards from cases in which FIFA was not a party. Excluding the expedited cases, FIFA has been notified a total of 192 awards on the merits in 2024. As in 2023 , this has allowed FIFA to obtain a general overview of duration of CAS proceedings from the moment that a statement of appeal is filed until a final award is notified to the relevant parties. The findings in the sections below are based on the information contained in the 192 awards that FIFA has received from CAS in 2024. 5.2 Average duration of the cases (awards) received in 2024 According to the relevant CAS awards, the average duration of the cases resolved in 2024 was 430 days.
192 awards that FIFA has received from CAS in 2024. 5.2 Average duration of the cases (awards) received in 2024 According to the relevant CAS awards, the average duration of the cases resolved in 2024 was 430 days. Breaking down this number, the time elapsed from the filing of the statement of appeal until the end of the hearing and/or the closure of the evidentiary part of the proceedings (the “evidentiary phase”) lasted an average of 203 days. However, the time passed between the end of the evidentiary phase and the notification of the arbitral award (i.e. the “resolution phase”) has, on average, been 227 days long. 430 days192 cases 227203 Resolution phase Hearing/closure evidentiary phase Evidentiary phase 202405 Length of CAS proceedings 23 5.3 Average duration of the cases with/without hearing As in 2023 , a comparative analysis is made between the length of cases where a hearing was held in comparison to those resolved solely on the basis of the parties’ written submissions. On average, cases in which a hearing was held took 444 days to conclude. The evidentiary phase in these cases lasted 213 days, while the resolution phase lasted 231 days on average. On the other hand, cases that were decided solely based on the written submissions of the parties lasted approximately 360 days, substantially less than cases in which a hearing was held. In these cases, the duration of the evidentiary phase was around 153 days long, while that of the resolution phase was 207 days long. Closure evidentiary phase 360 days33 cases 207153 Resolution phaseEvidentiary phase 2024 444 days159 cases 231213 Resolution phase Hearing Evidentiary phase 202406 CAS Global Football Statistics06 CAS Global Football Statistics 25 6.1 Introduction The following figures provided by CAS give a detailed summary of all football-related cases presented to this tribunal. These numbers cover not only FIFA-related matters but also decisions from national
Resolution phase Hearing Evidentiary phase 202406 CAS Global Football Statistics06 CAS Global Football Statistics 25 6.1 Introduction The following figures provided by CAS give a detailed summary of all football-related cases presented to this tribunal. These numbers cover not only FIFA-related matters but also decisions from national and regional associations, confederations, and ordinary football arbitration proceedings. This data offers essential insights into the legal challenges affecting football and is a valuable resource for industry stakeholders. 6.2 Evolution of the global CAS caseload The total number of cases registered across all sports and procedure types in 2024 at CAS was: 916. In comparison to 2023 (942), this number decreased by 2.8% (26 less cases in 2024). Appeal procedures continue to make up the majority of the caseload (70%) . T otal cases 2020 2021 2022 2023 2024 Y ear 957 996 830 942 91606 CAS Global Football Statistics 26 6.3 Football-related cases handled by CAS Of the 916 procedures above, 657 were related to - international, continental, and national – football. Football-related cases at CAS in 2024 In 2023, football-related proceedings constituted a significant majority, with 774 out of 942 cases (82%). This trend continued in 2024, with 657 out of 916 cases (72%) being related to football. 657 72%82% 18% 942 | 100% 916 | 100% Total Total 28% Comparison 2023 Comparison 2024 Other sports 168 Football 774 Other sports 259 Football 65706 CAS Global Football Statistics 27 6.4 T ype of procedure Out of the total number of football-related cases heard by CAS in 2024 (657), there were 476 appeals proceedings against decisions from football institutions (including FIFA) and 181 first-instance ordinary proceedings. Put differently, 72% of the football-related proceedings before the CAS in 2024 were appeals, while 28% were ordinary. 72%
there were 476 appeals proceedings against decisions from football institutions (including FIFA) and 181 first-instance ordinary proceedings. Put differently, 72% of the football-related proceedings before the CAS in 2024 were appeals, while 28% were ordinary. 72% 657 | 100% Total 28% Ordinary 181 Appeal 47606 CAS Global Football Statistics 28 6.5 Source of the appealed decisions Examining the appeal procedures more closely, 68% of the contested decisions originated from FIFA bodies while the other 32% were issued by confederations, national or regional football associations. Compared to last year, appeals against FIFA decisions have represented a lesser portion of football-related appeals, as in 2023, 79% of appeals were against FIFA decisions while in 2024, this figure dropped to 68%. 68%79% 21% 100% 476 | 100% Total Total 32% Comparison 2023 Comparison 2024 Other football institutions 21% FIFA 79% Other football institutions 150 FIFA 32606 CAS Global Football Statistics 29 6.6 Subject of the appealed decisions Following the past years’ trend, over half of the football-related appeal proceedings concerned employment-related disputes. Disciplinary matters were again the second most frequent type of football-related appeal procedure. The disciplinary matters can be broken down as follows: Employment-related disputes Disciplinary T ransfer T raining compensation Governance Elegibility / Licensing Other contractual issues Solidarity Contribution Registration of players T ransfer of minor player To t a l 239 476 89 17 46 19 26 31 6 1 2 Overdue payables General Request for sanctions Ethics Doping Behaviour of fans Financial Fair-Play Matchfixing 42 15 4 6 8 8 3 306 CAS Global Football Statistics 30 6.7 Language The data relating to the language of the football proceedings at CAS has practically
General Request for sanctions Ethics Doping Behaviour of fans Financial Fair-Play Matchfixing 42 15 4 6 8 8 3 306 CAS Global Football Statistics 30 6.7 Language The data relating to the language of the football proceedings at CAS has practically remained unchanged in comparison with 2023. In 2024, 73% of football cases were conducted in English (1% more than in 2023), 18% in Spanish (3% more than in 2023), 8% in French, and 1% in any other language. 73% 657 | 100% Total 18% 8% 1% Spanish English French Others07 FIFA cases during the Olympic games07 FIFA cases during the Olympic games 32 7.1 Introduction It is well-known that the CAS Ad hoc Division is a specialized branch of CAS established specifically for solving disputes in an expedited manner during the Olympic Games. This division ensures that any conflicts, such as those involving eligibility, doping, or other regulatory issues, are addressed fairly, allowing the Olympic Games to proceed smoothly. For the first time in history, three football-related cases were dealt with by the Ad Hoc Division during the Paris 2024 Olympics. 7.2 Summary of the cases CAS OG 24/04 Israel Football Association & Mr. Roy Revivo v. FIFA (Award 26 July 2024) During a match between Israel and Iceland in the context of the UEFA Euro 2024 Qualifiers, the player, Roy Revivo, received a red card. As a result, the UEFA imposed a 2-match suspension on the Player (the “UEFA Decision”). The UEFA Decision was never appealed. Ahead of the Olympic Games, FIFA requested UEFA to confirm any pending suspensions. UEFA informed that the Player’s suspension would need to be served “during the next Olympic games” scheduled on 24 July 2024 (“Mali v Israel”) and 27 July 2024 (“Israel v Paraguay”). During the Team Arrival Meeting with the Israeli Football Association (“IFA”)
suspensions. UEFA informed that the Player’s suspension would need to be served “during the next Olympic games” scheduled on 24 July 2024 (“Mali v Israel”) and 27 July 2024 (“Israel v Paraguay”). During the Team Arrival Meeting with the Israeli Football Association (“IFA”) on 21 July 2024, FIFA reported UEFA’s confirmation that the Player was suspended for the first two matches of the Olympic Football Tournament (“OFT”). In other words, FIFA stated it would enforce the UEFA Decision. On the following day, on 22 July 2024, IFA filed a Protest under Article 10(3) Regulations for the OFT (“ROFT”). FIFA declared the Protest inadmissible because it had been submitted later than five days before the OFT’s first match, as required by Article 10(3) ROFT (the “Appealed Decision”). IFA and the Player (the “Applicants”) appealed this decision before the CAS Ad hoc Division.07 FIFA cases during the Olympic games 33 As a preliminary issue, the Panel noted that FIFA had objected to the jurisdiction of the CAS Ad Hoc Division, alleging that (i) the Applicants had not exhausted the applicable internal remedies, as they should have first lodged an appeal against the Appealed Decision before the FIFA Appeal Committee; and (ii) that the dispute did not have sufficient “connection to” the Olympic Games under Rule 61.2 Olympic Charter. The Panel concluded that while the Applicants had not exhausted FIFA’s internal remedies, the urgency of the matter justified immediate recourse to the CAS Ad Hoc Division. Requiring the Applicants to await a decision from the FIFA Appeal Committee would have rendered the appeal ineffective. Furthermore, as the dispute concerned the Player’s eligibility for the OFT matches in Paris, the Panel found a sufficient connection to the Olympic Games and confirmed its jurisdiction. On the merits, the Applicants challenged FIFA’s enforcement of the UEFA Decision in the OFT, arguing that the UEFA Decision only applied to “UEFA representative competitions.”07 FIFA cases during the Olympic games 34
the OFT matches in Paris, the Panel found a sufficient connection to the Olympic Games and confirmed its jurisdiction. On the merits, the Applicants challenged FIFA’s enforcement of the UEFA Decision in the OFT, arguing that the UEFA Decision only applied to “UEFA representative competitions.”07 FIFA cases during the Olympic games 34 The Panel noted that, according to Article 10 ROFT, the Protest should have been filed no later than 5 days before the first match of the OFT, i.e., by 19 July 2024. While the Panel acknowledged that the Protest might have been lodged in “good faith” based on information provided during the Team Arrival Meeting on 21 July 2024, it agreed with FIFA’s decision to declare the Protest inadmissible. Since the UEFA Decision had been issued on 23 April 2024, the Applicants, particularly the IFA, should have been aware
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