Panathinaikos FC training compensation case against Como 1907 & FIFA in Lausanne, Switzerland; Zeeni transferred to Estrela

Panathinaikos FC training compensation case against Como 1907 & FIFA in Lausanne, Switzerland; Zeeni transferred to Estrela

Palais de Beaulieu Av. Bergières 10 CH-1004 Lausanne Tel: +41 21 613 50 00 www.tas-cas.org

CAS 2025/A/11368 Panathinaikos FC v. Como 1907 S.R.L. & FIFA ARBITRAL AWARD delivered by the COURT OF ARBITRATION FOR SPORT sitting in the following composition:

Sole Arbitrator: Mr Daan de Jong, Lawyer, Utrecht, the Netherlands in the arbitration between Panathinaikos FC, Greece Represented by Mr Anastasios-Panagiotis Kezas, Attorney-at-Law in Athens, Greece

• Appellant - and Como 1907 S.R.L., Italy Represented by Mr Paolo Lombardi and Mr Luca Pastore, Lombardi Associates Limited, Attorneys-at-Law in Edinburgh, United Kingdom
• First Respondent - Fédération Internationale de Football Association (FIFA), Switzerland Represented by Mr Miguel Liétard Fernández-Palacios, Director of Litigation
• Second Respondent -

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I. PARTIES 1. Panathinaikos FC (“Panathinaikos” or the “Appellant”) is a Greek professional football club affiliated to the Hellenic Football Federation (the “HFF”), which in turn is affiliated with the Fédération Internationale de Football Association (“FIFA”). 2. Como 1907 S.R.L. (“Como” or the “First Respondent”) is an Italian professional football club affiliated with the Italian Football Federation (“FIGC”), which in turn is affiliated with FIFA. 3. FIFA (“the Second Respondent”) is an association under Swiss law, with its registered office in Zurich, Switzerland. FIFA is the governing body of international football worldwide and exercises regulatory, supervisory and disciplinary authority over continental confederations, national associations, clubs, officials and players on a worldwide level. 4. Panathinaikos and Como shall hereinafter be jointly referred to as the “Clubs”, while Panathinaikos, Como and FIFA shall collectively be referred to as the “Parties”. II. FACTUAL BACKGROUND A. Introduction 5. The following section presents a summary of the principal facts as derived from the Parties’ written submissions and the evidence assessed during the proceedings. This overview is provided solely to outline the background of the dispute. Where appropriate, further factual elements will be addressed in the context of the legal analysis below. The Sole Arbitrator has thoroughly reviewed all arguments, evidence, and submissions on record; however, only those aspects deemed necessary to support the reasoning of this award are referred to in the ensuing paragraphs. B. Facts of the case 6. The present proceedings concern Panathinaikos’ alleged entitlement to training compensation payable by Como arising from the registration by Como of Mr Bilal Abdelrahman Zeeni, a football player of French nationality (the “Player”), born on 21 November 2003. 7. According to his player passport, the Player was registered with Panathinaikos from 23 January 2020 to 30 June 2024—first as an amateur (23 January 2020 to 19 December 2021) and thereafter as a professional (20 December 2021 to 30 June 2024). The Sole Arbitrator notes that the employment contract between Panathinaikos and the Player was concluded on 21 October 2021 for the period from 21 October 2021 to 30 June 2024 (the “Panathinaikos Contract”), which predates the official registration of the Player as a professional by approximately two months. Pursuant to the Panathinaikos Contract, the Player was, inter alia, entitled to a fixed monthly salary of EUR 726,

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together with an annual Christmas bonus equivalent to one month’s salary, and Easter and holiday allowances each equal to half a month’s salary. 8. Panathinaikos allegedly sent the Player a contract-renewal offer on 30 April 2024, both by email and through service by a bailiff, by means of which it allegedly offered the Player a contractual extension for the period from 1 July 2024 to 30 June 2027 providing, inter alia, for a monthly salary of EUR 926.75, together with an annual Christmas bonus equivalent to one month’s salary, and Easter and holiday allowances each equal to half a month’s salary (“Contract Offer”). 9. It is undisputed between the Clubs that no agreement was ultimately reached between the Player and Panathinaikos resulting in that the employment relationship between the Player and Panathinaikos ended on 30 June 2024, after which the Player became a free agent. 10. On 30 August 2024, the Player became registered with Como as a professional. On the same day, FIFA initiated the Player’s Electronic Player Passport (“EPP”) process and started the corresponding review procedure through the FIFA TMS system. 11. Shortly thereafter, the Player was transferred from Como to Club Football Estrela, a Portuguese club, where he was officially registered as a player on 5 September 2024, under a three-year professional employment contract commencing on 1 September 2024, pursuant to which he was, inter alia, entitled to receive a salary of EUR 130,000 for the 2024/25 season and EUR 156,000 for each of the 2025/26 and 2026/27 seasons. 12. On 16 September 2024, and again on 1 October 2024, the FIFA Clearing House Department sent automated e-mails to Panathinaikos, whereby it invited the club to review the Player’s EPP and to upload relevant documentation such as the contract- renewal offer for the purpose of training rewards in the FIFA TMS system. 13. On 21 March 2025, Panathinaikos received another message from the FIFA Clearing House Department by means of which Panathinaikos was reminded to upload any relevant documentation in FIFA TMS, such as a contract offer under Article 6(3) of Annexe 4 of the FIFA Regulations on the Status and Transfer of Players (June 2024 Edition) (“FIFA RSTP”), expressly noting that no further deadline would be granted and that, failing such submission, FIFA would proceed on the basis of the existing record: “Dear TMS user, Please note that your club is participating in this electronic player passport (EPP) and that its review phase is now closed. We noticed that new registration information regarding the player in question has been included in the EPP by the participating member association(s) during the review process, in line with article 9 of the FIFA Clearing House regulations.

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Based on the above, please be informed that the said new registration information is now available to you in the EPP. In accordance with art. 10 par. 1 and 10 par. 2 of the FIFA Clearing House regulations, we kindly ask you to provide any documentation relevant to the entitlement to training rewards of any relevant club in the EPP, including but not limited to waivers (to be uploaded by the new club) or contract offers (to be uploaded by the former club of the player under art. 6 par. 3 of Annexe 4 of the Regulations on the Status and Transfer of Players), by no later than the end date of the ongoing “completion” phase as currently displayed in TMS. In general, in case of an international transfer of a player between two clubs affiliated to different member associations (before and/or after the end of the calendar year of the 23rd birthday of the player) against compensation, we wish to draw your attention to the fact that should any training rewards due to the former club be included within the said compensation paid by the new club, the new club shall upload the transfer agreement of reference under in the applicable “waiver” section in relation to the registration of the player at the former club. Additionally, in cases of an international transfer of a player from a club based in the EU/EEA to a new club which located in another EU/EEA country, and according to art. 6 par. 3 of Annexe 4 of the Regulations on the Status and Transfer of Players, the former club of the player may submit in the EPP an exemption of contract offer as described in the TMS Help Centre article found under https ://support. fifatms. corn/en/support/sol utions/articles/7000070607- submitting-proof-of-a-professional- contract-offer-or-an-exemption-ofcontract- offer Please note that no further deadlines will be provided. Should you fail to reply within the set deadline, we may proceed on the basis of the file as it stands. Thank you for taking note of the above and for your collaboration. Yours sincerely, FIFA Player Registration & Transfer Data Department” 14. On 25 March 2025, Panathinaikos received a final automated reminder from the FIFA Clearing House Department informing the club that the phase for completing the Player’s EPP would close within 24 hours whilst for the last time inviting the club to provide the relevant documentation, in order to preserve its right to training compensation in connection with the Player. 15. It is undisputed that Panathinaikos failed to upload any contract offer into FIFA TMS during the EPP review process before the deadline set by the FIFA Clearing House Department expired.

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On 31 March 2025, following the completion of the EPP review process, the FIFA General Secretariat notified the Clubs of the Player’s EPP together with its so-called determination on the EPP of the Player (the “Appealed Decision”), the pertinent parts of which read as follows: “Considerations for entitlement to training rewards (cf. article 10 FCHR) 9.1 In case of an international transfer of a professional between clubs of two different associations (whether during or at the end of his contract) before the end of the calendar year of his 23rd birthday, training compensation is owed to his former club for the time he was effectively trained by that club (cf. article 2 paragraph 1 b) of Annexe 4 and article 3 paragraph 1 of Annexe 4 to the RSTP) from the calendar year of his 12th birthday up until the end of the calendar year of his 21st birthday (cf. article 1 paragraph 1 of Annexe 4 and article 5 paragraph 2 of Annexe 4 to the RSTP). 9.2 The player was registered with PANATHINAIKOS FC as a professional before the end of the calendar year of his 21st birthday before being registered as a professional with COMO 1907 S.R.L. before the end of the calendar year of his 23rd birthday. 9.3 In accordance with article 6 paragraph 3 of Annexe 4 to the RSTP, if the former club (in casu, PANATHINAIKOS FC) does not offer the player a contract, no training compensation is payable unless the former club can justify that it is entitled to such compensation. 9.4 The club PANATHINAIKOS FC did not provide any information regarding a possible offer of contract in relation to the registration of the player at PANATHINAIKOS FC and the subsequent transfer to COMO 1907 S.R.L. for the purpose of entitlement to training compensation, in accordance with article 6 of Annexe 4 to the RSTP. 9.5 It is therefore determined that PANATHINAIKOS FC does not fulfil the requirements of article 6 of Annexe 4 to the RSTP. 9.6 PANATHINAIKOS FC is therefore not entitled to training compensation for the registration of the player at the club during the aforementioned period(s). Conclusion 10. In consideration of the above and in accordance with the FCHR and annexes 4 and 5 to the RSTP, the FIFA general secretariat has determined the entitlement of clubs to training rewards for the above trigger as follows. 11. No club is entitled to training compensation. 12. All of the above determinations and decisions are reflected in the EPP in question and/or will be considered in the generation of any Allocation Statement from this EPP

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for the calculation and distribution of training rewards in accordance with article 13 of the FCHR. 13. Pursuant to article 57 paragraph 1 of the FIFA Statutes and in accordance with article 10 of the FCHR, this decision may be appealed before the Court of Arbitration for Sport within 21 days of notifica