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Football-legal
24
Jun
2025
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Football Legal
CAS
Cases
International

Training Compensation: CAS 2024/A/10694 JSC FC Lokomotiv v. FC Mariupol


CAS 2024/A/10694 JSC FC Lokomotiv v. FC Mariupol
Date of the decision: 2025-05-22
Arbitrator(s): Oliver Jaberg
Waiver clauses in loan agreements do not bind third parties due to the principle of privity of contract, which also reaffirms that training compensation remains payable unless a player’s training is evidently terminated before age 21, which was not proven here. Therefore, this award aligns with legal predictability in football transfers, upholding FIFA's regulatory standards and promoting consistency between contractual conduct and legal arguments.

Facts and Procedure


On 11 February 2021, FC Mariupol (Ukraine) and Shakhtar Donetsk (Ukraine) entered into a loan agreement for a player (First Loan Agreement). An identical clause (Clause 5) waived FC Mariupol’s right to claim training compensation from Shakhtar or “any new club” for the Player’s training period at FC Mariupol during the loan. A second loan agreement (Second Loan Agreement) with an identical waiver...

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Topics
  • CAS
  • Player Transfer
  • Solidarity mechanism
Related Regulation(s)
  • FIFA RSTP (incl. Interim Regulatory Framework) - Ed January 2025
Keywords
  • FIFA
  • CAS proceedings
  • Court of Arbitration for Sport (CAS)
  • FIFA Regulations
  • Player loan
  • Player transfer
  • Training compensation
  • Transfer fee
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