Acceleration Clause: CAS 2025/A/11962 Zamalek SC v. AIK FF Sweden

CAS 2025/A/11962 Zamalek SC v. AIK FF Sweden

Date of the decision: 2026-07-01

Arbitrator(s): Francesco Macri

CAS confirmed that an acceleration clause in a transfer agreement is not a penalty clause where it does not impose any additional financial burden on the debtor, but merely brings forward the due date of a pre-existing obligation. Zamalek’s internal management transition, alleged good faith and financial hardship did not affect the enforceability of the clause.

Facts and Procedure

On 3 September 2024, AIK FF Sweden (Respondent or AIK) and Zamalek SC (Appellant or Zamalek) concluded an agreement for the permanent transfer of the professional football player Omar Faraj (the Player) from AIK to Zamalek.

According to Article 3 of the transfer agreement (Transfer Agreement), Zamalek agreed to pay AIK a fixed transfer fee of USD 1,100,000. The amount was payable in two equal instalments of USD 550,000 each, due by 30 June 2025 and 30 June 2026 respectively.

Clause 3.5 of the Transfer Agreement provided that, if any of the agreed compensation and bonuses had not been received by AIK within ten days from the due date, all future instalments would become immediately due.

The Transfer Agreement also provided for a one-time...

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