The Court of Arbitration for Sport (CAS) case 2016/A/4604 involved a dispute between Ängelholms FF, a Swedish football club, and Kwara Football Academy, a Nigerian youth football academy, regarding training compensation for a player who had trained with Kwara before signing a professional contract with Ängelholms. The case centered on determining whether the player had prior professional contracts, which would affect the compensation owed under FIFA regulations. The player was registered with Kwara as an amateur from January 2008 to August 2012, during which he also signed sports training contracts with SL Benfica in Portugal. These contracts provided monthly subsidies for educational and living expenses but were deemed amateur in nature, as they focused on training rather than professional play. The player's first professional contract was recognized as the one signed with Ängelholms in August 2012, triggering the obligation to pay training compensation to Kwara.
Kwara initially claimed EUR 117,424 in compensation, but the FIFA Dispute Resolution Chamber (DRC) partially accepted the claim, ordering Ängelholms to pay EUR 110,000 plus interest. Ängelholms appealed to CAS, arguing that the player's contracts with SL Benfica and other clubs should be considered professional, thereby reducing or negating the compensation owed. The CAS Sole Arbitrator, Mr. Mark Hovell, reviewed the case de novo, examining all evidence and arguments anew. The arbitrator admitted new evidence, including a witness statement from the player, to ensure a fair and comprehensive resolution, despite objections from Kwara about its late submission.
The arbitrator concluded that the player's contracts with SL Benfica were amateur, as the payments were for educational and living expenses, not professional remuneration. Similarly, claims of professional contracts with Nigerian clubs were dismissed due to insufficient evidence. The player's passport, issued by the Nigerian Football Federation, confirmed his amateur status during the disputed periods. The arbitrator calculated the training compensation based on the player's age and the training costs of Ängelholms, pro-rating the amounts for partial training periods. For the 2007/08 and 2008/09 seasons, when the player was 14 and 15, compensation was based on UEFA category 4 club costs (EUR 10,000 per season). For the 2009/10 season, it was based on Ängelholms' category 3 costs (EUR 30,000). The total compensation awarded was EUR 31,986.38, plus 5% annual interest from June 2015 until payment.
The CAS partially upheld Ängelholms' appeal, amending the FIFA DRC's decision to reflect the recalculated compensation and dismissing all other claims. The ruling emphasized the importance of distinguishing between amateur and professional contracts and highlighted the arbitrator's discretion in evaluating evidence. The case reinforced the principles of fairness and consistency in resolving disputes over training compensation in football, ensuring that clubs are compensated appropriately for their role in player development.