Tanzania Football Federation v. Adel Amrouche & FIFA

This case is distinct from the well-known disciplinary ban Amrouche successfully challenged elsewhere in our library (see the related case note). Here, the underlying dispute concerned a separate, narrower engagement: a freelance agreement for Amrouche to work as a technical expert for FIFA's own training and development programmes, running from 1 July 2024 to 30 June 2025, under which his actual work amounted to roughly 30 days. Amrouche alleged the Tanzania Football Federation had breached that agreement and sought relief before FIFA's Players' Status Chamber (PSC); the TFF's own counterclaim in that proceeding was deemed withdrawn for a separate procedural failure of its own. The PSC ruled on the substance, and the TFF wanted to appeal to CAS. Before an appeal can even be filed, a party generally has to formally request the PSC's written grounds for its decision — and that request itself carries a strict 10-day deadline. The TFF submitted its request one day late.

There was no dispute about the underlying facts of the one-day delay — the only question was its legal consequence. The Sole Arbitrator distinguished between two categories of procedural deadline: "regulatory" deadlines, which are mandatory and whose breach automatically forfeits the procedural right in question, and "non-regulatory" deadlines, which may allow more flexibility depending on the circumstances. The 10-day grounds-request window fell squarely into the first category. CAS held that missing this deadline is not a minor, forgivable technicality: it operates as a waiver of the right to appeal at all. The panel did not go on to consider whether the TFF might otherwise have had a good case on the merits, because the procedural failure meant the merits were never reached.

Decided 7 October 2025. The underlying PSC decision became final and binding, and the TFF bore the costs of the failed appeal attempt — a stark illustration of how unforgiving CAS's procedural deadlines are, even by a single day.