The case before the Court of Arbitration for Sport (CAS) involved a dispute between Udinese Calcio S.p.A. and Helsingborgs IF regarding training compensation for a player who transferred from Helsingborgs to Udinese. The FIFA Dispute Resolution Chamber (DRC) had initially ordered Udinese to pay EUR 402,500 as training compensation, prompting Udinese to appeal the decision to CAS. The central issue revolved around whether Helsingborgs was entitled to training compensation under FIFA’s Regulations on the Status and Transfer of Players (RSTP), particularly concerning the formal requirement for a written contract offer to the player 60 days before his contract expired, as stipulated in Article 6(3) of Annex 4 to the RSTP. Udinese argued that Helsingborgs failed to meet this requirement and lacked genuine interest in retaining the player, while Helsingborgs countered that their negotiations and offers demonstrated bona fide intent to keep the player, even if no formal written offer was made.
The CAS panel, composed of Stuart McInnes, José Juan Pintó, and Markus Manninen, examined the case de novo, reassessing both factual and legal arguments. The panel acknowledged the general rule that training compensation is denied if formal requirements are unmet but recognized an exception if the training club can prove genuine interest in retaining the player. Helsingborgs successfully demonstrated this through evidence of early negotiations, multiple verbal and email offers, and proposals exceeding the player’s existing contract terms. The panel also clarified the calculation of training compensation, emphasizing it covers the player’s training period between ages 12 and 21 unless proven otherwise. The burden of proof for early termination of training lies with the claiming club, and regular participation in a club’s "A" team is a key indicator of completed training. The panel determined that while the player’s increased involvement in 2008 suggested his training was complete by the end of 2007, Helsingborgs had not conclusively proven an earlier termination.
The calculation of compensation was based on FIFA’s category system, with clubs classified into four categories (I to IV) with varying training costs. Helsingborgs (Category II) sought compensation from Udinese (Category I), leading to a pro-rated calculation averaging the costs of both clubs for the relevant periods. The panel ruled that Helsingborgs was entitled to EUR 255,000, combining Category IV costs for the player’s younger years and the average of Categories I and II for later years. The CAS partially upheld Udinese’s appeal, setting aside the DRC’s decision but still ordering Udinese to pay the specified amount plus interest. The decision underscored the balance between formal requirements and substantive fairness, ensuring clubs are rewarded for their training efforts while preventing overly rigid interpretations of the rules. The panel dismissed all other claims, reinforcing the importance of clear evidence and adherence to FIFA’s regulatory framework in training compensation disputes.