In its still very recent decision, the CAS CAS 2024/A/11060 of 19 September 2025 once again showed how strictly the two-year limitation period of Art. 23 para. 3 FIFA RSTP must be interpreted. Specifically, the case concerned a player who went to the FIFA Football Tribunal after outstanding salary and bonus payments - albeit late. Too late, as it turned out. The FIFA Football Tribunal only deals with claims that are less than two years old.
The player argued that the club's behaviour - including an alleged acknowledgement of guilt - should interrupt this limitation period. In principle, this would be conceivable under the Swiss Code of Obligations. However, there is no corresponding provision in the FIFA RSTP, nor is there any unintended loophole.
The CAS consistently followed this line:
- The two-year period has been finalised.
- No interruption, no inhibition - not even when recognised by the club.
- Swiss law does not intervene here on a subsidiary basis.
Important: The provision of Art. 23 para. 3 FIFA RSTP concerns exclusively Proceedings before FIFA bodies. For civil court proceedings, the path remains open for the player even after the two years - especially in the case of employment contracts, where the FIFA RSTP deliberately do not provide for exclusivity. However, the national statute of limitations must still be observed here.
This decision means in particular for players, their agents and lawyers:
- Deadline management is crucial.
- Formal „acknowledgements“ by the club do not help in proceedings before the FIFA Football Tribunal.
- Parallel strategies - FIFA vs. ordinary courts - must be thought through at an early stage.
An exciting case that once again shows how tricky the interplay between international sports association law and national labour/civil law can be.
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