The case before the Court of Arbitration for Sport (CAS) involved a dispute between Calcio Catania S.p.A. (Catania) and Montevideo Wanderers FC (Montevideo) concerning training compensation for a young Uruguayan footballer who moved from Montevideo to Catania. The player, born in 1996, was registered as an amateur with Montevideo from February 2012 to July 2014. He signed his first professional contract with Catania on January 31, 2014, and was registered as a professional on July 3, 2014. Montevideo sought training compensation, arguing it was owed for the player's development during his time with the Uruguayan club. The dispute centered on the interpretation of FIFA's Regulations on the Status and Transfer of Players (RSTP), particularly whether the triggering event for training compensation was the signing of the first professional contract or the player's registration as a professional. CAS panels have consistently ruled that the signing of the contract is the decisive moment. Training compensation is designed to promote solidarity in football by rewarding clubs for developing young players, functioning as an incentive rather than a reimbursement of actual costs. The compensation period is based on the time a player was effectively trained by a club, with partial months counted as full months if training occurred for more than half the month. The burden of proof lies with the club seeking to extend the recognized training period.
The FIFA Dispute Resolution Chamber (DRC) initially awarded Montevideo €210,000 in training compensation, calculated based on the player's registration periods with Montevideo and Catania's club category at the time. The DRC also imposed a 5% annual interest rate starting from August 3, 2014. Catania appealed to CAS, arguing the compensation period should be reassessed and the procedural costs reduced. CAS clarified that any challenge to procedural costs must also be directed against FIFA, as the DRC operates under FIFA's authority. The case highlighted the complexities of training compensation, emphasizing the need for consistency in interpreting FIFA regulations and ensuring fair compensation for clubs investing in youth development.
The CAS proceedings involved written submissions from both parties, with Montevideo agreeing to a sole arbitrator and English as the language of arbitration. The sole arbitrator requested additional documents, including the player's employment contract and FIFA's categorization of Catania. After reviewing the submissions, the arbitrator deemed a hearing unnecessary. Catania sought the annulment of the DRC's decision, a recalculation of the training compensation, and a reassessment of the procedural costs, while Montevideo defended the original ruling. The key issues were the correct timing for assessing Catania’s category, the period for which training compensation was due, the amount owed, and whether the procedural costs should be adjusted.
The Sole Arbitrator aligned with previous CAS rulings, determining that the signing of the first professional contract, not registration, triggers training compensation. This prevents potential abuses, such as clubs delaying registration to avoid immediate compensation. The arbitrator adjusted the training period to February 2012 to December 2013, as Montevideo failed to prove it trained the player in 2014. The compensation was recalculated to €165,000, based on Catania's category I status at the time of signing. The 5% interest rate from August 3, 2014, was upheld, as neither party contested it. The CAS also upheld the DRC's procedural costs, as FIFA was not a party to the arbitration, and the Sole Arbitrator lacked jurisdiction to modify this portion. The final ruling partially reformed the DRC's decision, adjusting the compensation to €165,000 plus interest, while confirming the remainder of the original decision and dismissing all other claims. The case underscores the importance of clear regulatory frameworks to prevent disputes over player development rights and the procedural steps in resolving such disputes within international football governance.