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Not every Greek football dispute can go to the Court of Arbitration for Sport (CAS).<\/p>\n
Greek football disputes do not move within a single forum. They begin within a domestic federation structure, are heavily shaped by the FIFA mandatory framework on dispute resolution and contractual stability and may culminate in CAS appeal arbitration only where the relevant domestic statutes or regulations open that route.<\/p>\n
Indeed, under Article R47 of the CAS Code of Sports-related Arbitration (the CAS Code), which entered into force on 1 July 2025, an appeal may be filed with CAS only if the statutes or regulations of the relevant federation or sports body so provide, or if there is a specific arbitration agreement, and only after exhaustion of available internal remedies.<\/p>\n
In disputes involving Greek football bodies and the Hellenic Football Federation (HFF), the route to CAS begins inside the HFF system and depends upon which HFF body rendered the decision. CAS review is provided for against final decisions of the HFF Appeals Committee<\/u><\/em> (see Article 60(3) of the HFF Statutes and Article 5(5) of the HFF procedural rules; CAS award Olympiakos FC & PAOK FC v. HFF, PAOK FC & Xanthi FC, CAS 2020\/A\/7019 & 7035, 10 July 2020; CAS award \u00a0Aris Football Club & Theodoros Karypidis v. HFF, CAS 2021\/A\/8344, 3 March 2022) and against only an exhaustive list of first-and-final-instance decisions of the HFF Court of Arbitration<\/u><\/em> since the rule is that the latter decisions, generally, are irrevocable (see Articles 21 and 5 of the HFF Court of Arbitration Procedural Rules; CAS award OFI Crete FC v. HFF & Christos Bourbos, CAS 2025\/A\/11227, 26 March 2026).<\/p>\n CAS, therefore, does not sit as a general appellate body over any Greek football decision; it is reached only if there is a valid textual basis for CAS review and the appellant attacks the final decision after the available internal remedies have been exhausted. The Greek football case law, in practice, confirms this threshold: CAS has denied jurisdiction<\/u><\/em> where appellants relied only on general HFF recognition of CAS or on FIFA\/UEFA provisions without a specific HFF appeal clause, but has accepted jurisdiction<\/u><\/em> where the challenged act was a final HFF Appeals Committee decision that expressly provided for an appeal to CAS (see CAS award Iraklis Thessaloniki FC & FC OFI Crete v. HFF, CAS 2010\/A\/2170 & 2171, 23 February 2011; CAS award Olympiakos FC & PAOK FC v. HFF, PAOK FC & Xanthi FC, CAS 2020\/A\/7019 & 7035, 10 July 2020). Once the parties in dispute submit to CAS procedure, they also waive recourse to state authorities for provisional or conservatory measures under the CAS Code.<\/p>\n The latest Greece-related CAS award of 26 March 2026, OFI Crete FC v. Hellenic Football Federation & Christos Bourbos (CAS 2025\/A\/11227) illustrates that this architecture, in practice, matters significantly for claim strategy and that jurisdiction remains a live and unpredictable issue in Greek football appeals before CAS.<\/p>\n In that case, the CAS was asked to determine a jurisdictional issue arising from a dispute concerning sporting succession and unpaid player debts in Greek football. The appeal was brought by OFI Crete FC (OFI) against Hellenic Football Federation (HFF) and former player Christos Bourbos (the Player), challenging a decision of the HFF Court of Arbitration that had dismissed the OFI request for retrial of an earlier sporting succession ruling.<\/p>\n The appellant, OFI, is a Greek professional football club based in Heraklion, Greece and affiliated with the HFF. The first respondent, HFF, is the governing body of Greek football. The second respondent, the Player, is a former Greek professional football player.<\/p>\n Between 2010 and 2016, the Player was employed by OFI PAE, the predecessor club that later entered into liquidation (the Old Club). In 2014, the player filed a claim before the HFF National Dispute Resolution Chamber (NDRC) seeking outstanding remuneration. The HFF NDRC awarded him \u20ac309,596 (around CHF 291’989), plus interest, and the decision was upheld on appeal by the HFF Appeal Arbitration Court. The Old Club failed to satisfy the debt.<\/p>\n Following financial difficulties and withdrawal from professional competition, the Old Club ceased participation in professional football, was dissolved and placed in liquidation. In August 2016, after promotion of the Old Club\u2019s amateur team to the professional leagues, OFI Crete FC was established as a new professional entity. This gave rise to the central issue of whether the new club constituted the sporting successor of the old club and, therefore, inherited part of its football-related debts.<\/p>\n In December 2020, the Player sought sporting sanctions against the OFI, claiming that it was the sporting successor of the Old Club. The HFF Court of Arbitration rejected the request in Decision No. 44\/2021. In December 2023, the Player filed a new application seeking recognition of sporting succession and payment of at least 50% of his established debt. On 12 September 2024, the HFF Court of Arbitration issued Decision No. 46\/2024, recogni<\/u>s<\/u>ing sporting succession between the old and new OFI entities and holding that the Club assumed responsibility for 50% of the sporting debt owed to <\/u>the Player<\/u>.<\/u><\/p>\n Subsequently, OFI filed a retrial request before the same tribunal seeking annulment and reconsideration of Decision No. 46\/2024. The HFF Court of Arbitration dismissed the retrial application in Decision No. 3\/2025, which became the sole subject of the CAS appeal. <\/u><\/p>\n On 28 February 2025, OFI filed an appeal to CAS challenging Decision No. 3\/2025. The HFF immediately raised a jurisdictional objection and requested termination of the proceedings. CAS bifurcated the case and decided to address jurisdiction as a preliminary issue before examining the merits.<\/p>\n OFI argued that the underlying dispute concerned a football-related financial matter on violation of the HFF rules and thus fell within Article 5(I) and 21 of the HFF Court of Arbitration Procedural Rules permitting an appeal to CAS. According to OFI, the appeal remained sports-related despite formally challenging a retrial decision because the underlying dispute concerned sporting succession and player debt. Any different interpretation would be unreasonably narrow and against the doctrine in dubio pro arbitratu<\/em>.<\/p>\n HFF argued that Articles 5 and 21 of the HFF procedural rules contain an exhaustive list of appealable disputes and retrial applications are not amongst these categories of disputes deliberately. According to HFF, retrial decisions are a separate extraordinary procedural remedy and are not linked to the substantive underlying sporting disputes.<\/p>\n The Player supported the HFF position and emphasised that the HFF statutes expressly provide that decisions of the HFF Court of Arbitration are final and not appealable to CAS, except where specific regulations state otherwise. According to the Player, OFI had chosen not to challenge the substantive sporting succession decision before CAS but only the retrial decision attempting to transform CAS into a third or even fourth instance tribunal.<\/p>\n The Sole Arbitrator distinguished between the decision addressing the substantive issue of sporting succession and liability for player debts (sport-matter decision) and the decision dealing solely with the procedural question of whether the case should be reopened through a retrial (procedural decision). CAS emphasised that the appeal before it challenged only the latter procedural decision and not the underlying sporting succession ruling. Accordingly, CAS could only examine the retrial decision and could not revisit the merits of sporting succession since the CAS de novo<\/em> review powers under Article R57 are limited by the scope of the decision under appeal.<\/p>\n The Sole Arbitrator accepted that Article 21 creates a limited exception allowing appeals from certain HFF Court of Arbitration decisions. However, those appeals are permitted only for the categories of disputes exhaustively listed in Article 5(I).<\/u> CAS held that a retrial request under Article 22 falls outside the categories enumerated in Article 5(I)<\/u> and thus retrial proceedings fall outside the jurisdictional gateway established by Article 21. Based on this interpretation, the Sole Arbitrator rejected CAS jurisdiction since he concluded that the dispute before CAS concerned exclusively the rejection of a retrial application and not a substantive football dispute falling within Article 5(I) of the HFF rules.<\/p>\n This recent CAS award includes several important takeaways for sports stakeholders in Greece:<\/p>\n Most importantly, this CAS award highlights how crucial it is to be strategic in identifying the challenged decision for an appeal before CAS and that Greek football disputes require coordinated domestic and international strategy rather than one-forum thinking. The reasoning of the sole arbitrator hinted very clearly that his decision would have been materially different had OFI challenged the sport-matter substantive decision as well.<\/p>\n\n