The Court of Arbitration for Sport (CAS) issued a ruling on March 14, 2014, in a dispute between Bradford City Football Club and Falkirk Football Club concerning training compensation for the player Mark Stewart. The case revolved around whether Falkirk was entitled to compensation following Stewart's transfer to Bradford City after his 23rd birthday. The key issues included the definition of a football season, the conditions for training compensation eligibility, and the burden of proof regarding the completion of a player's training before age 21. Falkirk claimed EUR 330,000 in compensation, arguing that Stewart was still under contract and below 23 at the start of the 2011/2012 season, as recorded in FIFA's Transfer Matching System (TMS). Bradford City contested this, asserting that the transfer occurred after the season of Stewart's 23rd birthday, exempting them from payment. The dispute hinged on differing interpretations of the season's duration, with Falkirk using TMS dates (1 June to 31 May) and Bradford City relying on the English Football Association's definition (1 July to 30 June).
The CAS panel clarified that national associations have discretion in defining their seasons, even if this leads to inconsistencies with FIFA's Regulations on the Status and Transfer of Players (RSTP). It ruled that a club is entitled to training compensation if it offered the player a new contract with improved terms before the end of the season of his 23rd birthday. The panel also emphasized that the burden of proof regarding early termination of training (before age 21) lies with the club seeking to reduce compensation. Factors such as the player's talent, first-team participation, and market value were deemed relevant in such assessments. The panel upheld FIFA's decision that Falkirk was entitled to compensation, rejecting Bradford City's arguments about the season's definition and the player's training completion. However, it adjusted the compensation amount, reducing it by EUR 65,000 to account for the period when Stewart's training was deemed complete before turning 21, resulting in a final award of EUR 185,000. Bradford City was also ordered to pay interest at 5% from August 29, 2013.
The case highlighted the complexities of training compensation rules and the importance of clear contractual and regulatory frameworks in football transfers. It underscored discrepancies in how national associations define seasons and the need for FIFA to provide clearer guidelines to prevent future disputes. The panel's decision reinforced the role of TMS in resolving transfer-related conflicts and the necessity for clubs to verify season dates before completing transfers. Ultimately, the ruling partially upheld Bradford City's appeal, modifying the FIFA DRC's original decision while affirming Falkirk's entitlement to compensation. The case serves as a precedent for interpreting training compensation regulations and the procedural responsibilities of clubs in international player transfers.