Training Compensation (TMS claims)
Texto da decisão
Dispute Resolution Chamber
Date: 20 March 2026
Sent to:
Respondent:
Charlotte MLS
NOTIFICATION OF THE GROUNDS OF THE DECISION
TRAINING COMPENSATION FOR THE PLAYER
Jean-Aniel Eclesiaste ASSI
TMS Ref. Nr. 15539
Dear Sirs,
Please find attached the grounds of the decision passed in the aforementioned
matter.
We kindly invite you to take note of this decision.
We remain at your disposal.
Yours faithfully,
FIFA
Copy for information (VIA EMAIL):
US Soccer Federation
CONCACAF
Fédération Internationale de Football Association
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
[email protected] Tel: +41 43/222 7777
REF TMS 15539
Decision of the
Dispute Resolution Chamber
passed on 9 March 2026
regarding training compensation for the player
Jean-Aniel Eclesiaste ASSI
BY:
Mr. Stefano Sartori (Italy), Single Judge
CLAIMANT:
Cavalry FC, Canada
RESPONDENT:
Charlotte MLS, USA
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REF TMS 15539
I. FACTS OF THE CASE
Player:
Jean-Aniel Eclesiaste ASSI
Date of birth:
12 August 2004
Player passport (s): issued by the Canada Soccer Association (CSA):
Year
Birthday
Club(s)
Registration dates
2020/21
16th - 17th
2022
2023
2024
Status
CF Montreal
04/12/20
31/12/21
Professional
18
th
Cavalry
25/02/22
30/12/22
Pro (on loan)
19
th
CF Montreal
04/01/23
13/02/23
Professional
19
th
Atletico Ottawa
14/02/23
14/03/23
Pro (on loan)
20
th
Charlotte MLS
15/03/24
30/08/24
Professional
Date of registration:
15 March 2024 with Charlotte MLS (USA)
Claimant club:
Cavalry FC (Canada)
Respondent club:
Charlotte MLS (USA)
CONCACAF, category IV (USD 2,000.00 per year of training)
Claim and response:
1.
On 10 February 2026, the Claimant requested re-categorizing the Respondent under
CONCACAF Category II and sentencing it to pay to the Claimant training compensation for the
above-mentioned player in the amount of USD 33,863 or subsidiarily in the amount of USD
8,465,75 (based on category III CONCACAF) plus 5% p.a. interest as of the due date, until the
date of effective payment .
2.
The Claimant based its claim on the subsequent registration of the player as a
professional with the Respondent before the end of the calendar year of his 23rd
birthday.
3.
In this respect, the Claimant argued that it held the player s registration, while on loan
from the former club, for 309 days before the end of the calendar year of the player s
21st birthday.
4.
The Claimant is aware that the FIFA Clearing House Regulations (FCHR) set up the
framework for the distribution of any training rewards in the sense of articles 20 and 21,
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REF TMS 15539
as well as Annexes 4 and 5 of the FIFA Regulations on the Status and Transfer of Players
(RSTP), by a transfer that took place as from 16 November 2022 onwards.
5.
As such, any training reward generated by the registration of the player (cf. art. 5 and 6
FCHR) would have triggered an EPP process (cf. art. 8 FCHR) through which the training
reward(s) entitlement of training club(s) would have been conducted.
6.
However, as the Respondent was placed by its Member Association under category IV,
no EPP process took place vis-à-vis this registration. The Claimant argues the claim
should be admissible and accepted based on art. 18.2 FCHR.
7.
The Claimant argues the Respondent should be recategorized to CONCACAF category II.
8.
The Claimant pointed out that Crown Legacy FC is the same entity as the Respondent, a
club participating in the national first division, the Major League Soccer (MLS), and that,
Respondent should be classified as a CONCACAF category II club.
9.
Thus, since training categories II, III and IV are available in the USA, the Claimant
considered that the Respondent should be reclassified under training category II in
CONCACAF for the purpose of training compensation, in line with the jurisprudence of
the Dispute Resolution Chamber (DRC) and Court of Arbitration for Sport (CAS).
10.
The Claimant added that the FIFA Circular 1249, allows the DRC to recategorize a club by
establishing that when assigning their clubs to the various training categories available
and that football associations should proceed in full respect of its criteria.
11.
The Claimant provides online sources, such as the Respondent s website, to affirm the
existence of a pathway towards the Respondent s A team involving Crown Legacy FC and
Charlotte FC Academy.
12.
The Claimant sustained that the evidence it provided, such as the monetary level of
investments, high standard infrastructure, and specialized staff, demonstrates that the
Respondent shall be considered a CONCACAF category II club even if currently
categorized by its member association as a CONCACAF category IV club
13.
The Respondent is of the opinion that the claim should be rejected under the argument
that Crown Legacy FC was the one to hold the player s registration and not the
Respondent itself.
14.
The Respondent confirms Crown Legacy is under its TMS account but that the
Respondent s team and Crown Legacy, with which the player was registered, are
different entities.
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REF TMS 15539
15.
It also argues that the player exclusively played official matches of the MLS NEXT Pro
league, division in which Crown Legacy FC plays, and that he never played an MLS match.
16.
In addition, the Respondent states that MLS Next Pro would be equivalent to the national
third division so Crown Legacy FC being placed by its Member Association under
CONCACAF category IV would be accurate.
17.
The Respondent emphasizes the player exclusively provided services to Crown Legacy
FC and that it was the latter, and not the Respondent itself, to celebrate a transfer
agreement with Marbella FC SAD (Spain) for the subsequent transfer of the player.
II. LEGAL CONSIDERATIONS
Applicable law:
Regulations on the Status and Transfer of Players (RSTP): July 2024
edition
the Dispute Resolution Chamber (Procedural Rules): March 2023 edition
Jurisdiction:
Yes, uncontested
Admissible:
Yes, uncontested
Decision:
1.
As the Respondent was categorized by its Member Association as category IV when
registering the player, no EPP was generated as determined by the FCHR.
2.
The FCHR set up the framework for the distribution of any training rewards in the sense
of articles 20 and 21, as well as Annexes 4 and 5 RSTP for transfers that take place after
16 November 2022.
3.
Notwithstanding the above, art. 18 paragraph 2 FCHR stipulates that a club that did not
take part in the relevant EPP process and meets certain criteria can lodge a claim,
following art. 27 of the Procedural Rules.
4.
Art. 18, par. 2 FCHR determines that:
a) did not take part in the relevant EPP review process; and
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REF TMS 15539
b) considers, as a result of a bridge transfer (cf. article 5bis of the RSTP), exchange of
players or information declared by the new club or its member association (including
the training category of the club), that:
i.
it was incorrectly not entitled to any training rewards, or entitled to a lesser
amount than should have been calculated; or
ii.
an EPP review process should have taken place; and
c) considers that it is entitled to receive training rewards, may lodge a claim against
the relevant clubs in accordance with article 27 of the Procedural Rules. The Dispute
5.
In casu, the Claimant:
a. Did not take part in the EPP process since no EPP was generated;
b. Is of the opinion that an EPP process should have taken place following the
player s registration as a professional with the Respondent; and
c. Is of the opinion that due to the above, it was deprived of training
compensation.
6.
Based on the above, it is determined that the requirements of art. 18.2 FCHR are met,
and the claim of the Claimant is admissible.
7.
The parties are in dispute as to the question whether Crown Legacy FC and Respondent
are to be considered the same entity.
8.
On the one hand, Crown Legacy FC and Respondent share a TMS account, website,
facilities and staff.
9.
On the other hand, the Respondent argues they are separate entities and provides as
evidence player s match reports exclusively with Crown Legacy FC in the league MLS
NEXT Pro, as well as a transfer agreement celebrated by the latter for the subsequent
transfer of the player.
10.
Against the above positions, the Single Judge is aware that players may either celebrate
direct employment agreements with teams in the United States or MLS contracts if they
are to act within this specific league.
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REF TMS 15539
11.
However, the Single Judge emphasizes that prevailing DRC jurisprudence on such
matters shows a connection within MLS clubs, as the Respondent, involving their A
teams and the pathway towards it, in the present case with Crown Legacy FC and
Charlotte FC Academy.
12.
The Single Judge refers to jurisprudence of the CAS, such as CAS 2014/A/3710, providing
clarity to cases as the present one and the previously mentioned ones, in which it is
team is
part of only one club. The calculation of the amount of training compensation due in
international transfers is based on the categorisation of the club in question, and thus not on
13.
108. The intention behind the
categorisation of clubs in the FIFA Regulations is to classify clubs in four different categories,
depending on the total investments made by the club in youth development in general.
s A team or in any other team of the club does not
influence the total investment made by the club and, as such, does not alter the category in
which the club is classified
14.
In light of the above, the Single Judge considers Crown Legacy FC and Respondent to be
the same club.
15.
The Claimant argues that the Respondent was wrongly classified by its Member
Association under CONCACAF Category IV, and it should be placed under CONCACAF
Category II.
16.
FIFA Circular 1249 of 6 December 2010 stipulated that in principle, clubs shall be
categorized by their respective member associations according to the following
principles:
a. Category I (top-level, high-quality training centre): All first-division clubs of
member associations investing, on average, a similar amount in training
players;
b. Category II (still professional, but at a lower level): All second-division clubs of
member associations in category I and all first-division clubs in all other
countries with professional football;
c. Category III: All third-division clubs of member associations in category I and all
second-division clubs in all other countries with professional football; and
d. Category IV: All fourth- and lower-division clubs of the member associations in
category I, all third- and lower-division clubs in all other countries with
professional football and all clubs in countries with only amateur football.
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REF TMS 15539
17.
in such a case of manifest discrepancy,
the DRC normally applies the training categories in accordance with the guidelines, despite
the fact that the member association concerned had indicated a different categorisation
18.
According to FIFA Circular 1763 of 1 July 2021, the US Soccer Federation (USSF) may
classify their clubs between three training categories, i.e.: II, with training costs of USD
40,000.00 per year; III, with training costs of USD 10,000.00 per year; and IV, with training
costs of USD 2,000.00 per year.
19.
In that regard, the DRC is aware that there are precedents where clubs have been "recategorised" on the basis of that provision.
20.
recategorize
effective usurp of a power conferred to the national associations by art. 4 par. 1 of
Annexe 4 RSTP, which, for obvious reasons, are better placed than the DRC to determine
what are the training and education costs of their member clubs.
21.
In fact, the referred FIFA Circular 1249, which establishes certain parameters and
guidelines for national associations to categorise their clubs, states that the DRC will
intervene only in cases of manifest discrepancy between the categorisation assigned by
the national association and the actual training costs of a club.
22.
recategorization
an effective usurp of a power conferred to the national associations art. 4 par. 1 of
Annexe 4 of the RSTP, which, for obvious reasons, are better placed than the DRC to
determine what are the training and education costs of their member clubs.
23.
In fact, the referred FIFA Circular 1249, which establishes certain parameters and
guidelines for national associations to categorise their clubs, states that the DRC will
intervene only in cases of manifest discrepancy between the categorisation assigned by
the national association and the actual training costs of a club.
24.
On the present case, in light of the evidence provided by the Claimant, the Respondent,
participating in one of the elite competitions in CONCACAF, cannot be at the same time
classified at the lowest training category available in the USSF.
25.
For the Single Judge of the DRC, the allegations and arguments presented by the
Claimant, in and of themselves, can meet, on an exceptional basis, the standard of
"manifest discrepancy" between the category given by the USSF and that requested by
the Claimant if supported by solid and conclusive evidence.
26.
In view of the foregoing considerations, the Single Judge decided to accept the Claimant's
recategorize
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REF TMS 15539
27.
As to the training category to be assigned to the Respondent for training compensation
purposes, the Respondent has continuously been a member of the MLS. As such, the
Respondent is to be considered a well-established MLS club.
28.
The MLS is the highest professional division in North America, falling under CONCACAF
category II.
29.
Based on all the above, it is determined that the Respondent is to be considered a
CONCACAF training category II club for training compensation purposes, that is with
yearly training costs of USD 40,000.00.
30.
Based on all the above, it is established that training compensation is due.
31.
Art. 20 and Annexe 4 RSTP stipulates that training compensation is due to the previous
club, for the training provided until the calendar year of the 21st birthday, when a player
is registered as a professional before the end of the calendar year of his 23rd birthday.
32.
The prevailing DRC jurisprudence determines that the registration period with the
former club and the one with clubs that receive the player on loan from the latter, such
as the Claimant, are considered as a single timeframe.
33.
In this respect, the Claimant held the player s registration, while on loan from the former
club, for 309 days, between 25 February 2022 and 30 December 2022, calendar year of
his 18th birthday.
34.
Moreover, the player was registered with the Respondent on 15 March 2024, calendar
year of his 20th birthday.
35.
Consequently, for the 309 days in which it held the player s registration, the Claimant is
entitled to receive from the Respondent the amount of USD 33,863.00 as training
compensation.
36.
Furthermore, the Claimant requested to be awarded interest amounting to 5% per
annum as from the due date of payment, i.e. 31 days after registration, i.e. as from 15
April 2024.
37.
art. 3 par. 2 of Annexe 4 RSTP,
the Respondent has to pay, in conformity with the longstanding practice of the DRC,
interest of 5% p.a. over the amount payable as training compensation as of 31 days after
the registration of the player with it, i.e. as from 15 April 2024 until the date of effective
payment.
38.
In view of the above, the claim of the Claimant is accepted and the Claimant is entitled
to receive from the Respondent the amount of USD 33,863.00 as training compensation
plus 5% interest p.a. as from 15 April 2024.
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REF TMS 15539
39.
According to art. 25 par. 2 of the Procedural Rules, procedural costs are payable for
disputes between clubs regarding the payment of training rewards.
40.
The Claimant claimed the amount of USD 33,863.00.
41.
Thus, the amount claimed by the Claimant corresponds to an amount lower than
USD 49,999.99. Therefore, procedural costs levied in this respect are fixed at USD
5,000.00 (cf. art. 2 of Annexe 1 to the Procedural Rules).
42.
According to art. 25 par. 5 of the Procedural Rules, the Single Judge will decide the
and their conduct during the procedure, as well as any advance of costs paid. In
exceptional circumstances, the DRC may order that FIFA assumes all procedural costs.
43.
In view the specific circumstances of the case, procedural costs shall be set at
USD 5,000.00.
44.
In view of the outcome of the claim, said costs shall be borne by the Respondent in full.
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REF TMS 15539
III. DECISION
1. The claim of the Claimant, Cavalry FC, is accepted.
2. The Respondent, Charlotte MLS, shall pay to the Claimant the amount of
USD 33,863.00 as training compensation plus 5% interest p.a. from 15 April 2024
until the effective date of payment.
3. Full payment (including all applicable interest) shall be made to the bank account
indicated in the enclosed Bank Account Registration Form.
4. Pursuant to article 24 of the Regulations on the Status and Transfer of Players if
full payment (including all applicable interest) is not paid within 45 days of
notification of this decision, the following consequences shall apply:
1. The Respondent shall be banned from registering any new players, either
nationally or internationally, up until the due amount is paid. The maximum
duration of the ban shall be of three entire and consecutive registration
periods.
2. The present matter shall be submitted, upon request, to the FIFA Disciplinary
Committee in the event that full payment (including all applicable interest) is
still not paid by the end of the of the three entire and consecutive
registration periods.
5. The consequences shall only be enforced at the request of the Claimant in
accordance with article 24 paragraphs 7 and 8 and article 25 of the Regulations on
the Status and Transfer of Players.
6. The final costs of the proceedings in the amount of USD 5,000.00 are to be paid by
the Respondent to FIFA reference to case no. TMS 15539 (cf. note relating to the
payment of the procedural costs below.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
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REF TMS 15539
NOTE RELATED TO THE APPEAL PROCEDURE:
Pursuant to article 58 paragraph 1 of the FIFA Statutes, this decision may be appealed before
the Court of Arbitration for Sport within 21 days of notification.
NOTE RELATED TO PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf. article 20 of the Procedural Rules).
CONTACT INFORMATION:
Fédération Internationale de Football Association
Fédération International de Football Association - Legal & Compliance Division
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
www.fifa.com | legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
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