The Court of Arbitration for Sport (CAS) ruled on February 2, 2015, in the dispute between MFK Dubnica and FC Parma concerning training compensation for the transfer of player Pavol Bajza. The case centered on whether Dubnica had complied with FIFA regulations to claim compensation after Bajza moved to Parma. The FIFA Dispute Resolution Chamber (DRC) initially rejected Dubnica's claim, citing insufficient evidence that the club had offered Bajza a new contract before his transfer, as required under Article 6(3) of Annex 4 to the FIFA Regulations on the Status and Transfer of Players (RSTP). This provision mandates that the former club must offer a written contract via registered mail at least 60 days before the current contract expires, with terms at least equivalent to the existing agreement.
Dubnica appealed to CAS, presenting additional evidence, including a postal confirmation dated March 13, 2012, to prove it had sent the contractual offer. Parma contested the claim, arguing Dubnica failed to prove the player received the offer and that Bajza had already completed his training before turning 21, thus exempting Parma from compensation. The CAS panel, composed of arbitrators Manfred Nan, Alasdair Bell, and Efraim Barak, reviewed the case de novo, admitting new evidence to ensure a fair assessment. The panel found Dubnica's postal confirmation credible, concluding the club had met its burden of proof under FIFA regulations. It also dismissed Parma's argument about the player's training status, noting that Bajza's inconsistent performances and the Slovak league's lower competitive level indicated his training was not complete before joining Parma.
The panel determined that Bajza's training period ended at the start of the 2011/2012 season, making Dubnica eligible for compensation. The calculation was based on the average training costs of both clubs, considering their respective categories during the relevant seasons. Dubnica, a Category III club, was awarded EUR 219,897, with interest at 5% per annum starting 30 days after Bajza's registration with Parma. The panel dismissed Dubnica's request for reimbursement of administrative costs but upheld its appeal, overturning the FIFA DRC's decision and ordering Parma to pay the compensation. The case highlights the complexities of training compensation disputes, emphasizing the importance of procedural compliance and evidentiary standards under FIFA's regulatory framework. The CAS ruling ensures consistency with prior jurisprudence and reinforces the principle of fair review in sports arbitration.