Labour Disputes
Texto da decisão
REF. FPSD-18633
Decision of the
Dispute Resolution Chamber
passed on 4 September 2025
regarding an employment-related dispute concerning the player
Maati Tamayazou
COMPOSITION:
Lívia SILVA KÄGI (Brazil & Switzerland), Deputy Chairwoman
Dana MOHAMED AL-NOAIMI (Qatar), Member
Stijn BOEYKENS (Belgium), Member
CLAIMANT / COUNTER-RESPONDENT:
Maati Tamayazou, Morocco
Represented by Iliass Segame
RESPONDENT / COUNTERCLAIMANT:
Al Sadaqa Shahat SC, Libya
Represented by Chebbi Med Ikbel
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REF. FPSD-18633
I. Facts of the case
1.
On 8 August 2024, the Moroccan player Maati Tamayazou (hereinafter: the Claimant /
Counter-Respondent or the Player) and the Libyan club Al Sadaqa Shahat SC (hereinafter: the
Respondent / Counterclaimant or the Club) concluded an employment contract (hereinafter:
the Contract) valid as from its date of signature until 30 July 2026.
2.
In accordance with the Contract, the Club undertook to pay the Player as follows:
“First Season (2024/2025): The Player shall receive a contract value of $45,000, distributed as
follows:
• 50% upon passing the medical examination and receiving the International Transfer
Certificate (ITC).
• 25% midway through the Libyan Premier League 2024/2025 (between the first and
second rounds).
• 25% at the end of the 2024/2025 sporting season.
Second Season (2025/2026): The Player shall receive a contract value of $60,000, distributed as
follows:
• 50% upon joining the pre-season training for the 2025/2026 season.
• 25% midway through the Libyan Premier League 2024/2025 [sic] (between the first
and second rounds).
• 25% at the end of the 2024/2025 [sic] sporting season.“
3.
In addition, the Contract stipulated that the Club undertook to provide the Player with
transportation as per the agreed terms, accommodation throughout his tenure, as well as
three meals per day.
4.
Lastly, article 4 of the Contract read as follows:
“The Club (Al-Sadaqa) has the exclusive right to unilaterally terminate the contract during any
transfer window, provided that it pays the Player a compensation of $5,000 without any
additional entitlements. […]”
5.
On 1 March 2025, the Player put the Club in default and requested payment within 15 days
of outstanding remuneration in the amount of USD 11,250, i.e. the second instalment of
the Contract for the season 2024/2025.
6.
On 13 March 2025, the Club sent the following correspondence to the Player:
“Greetings,
Regarding your request regarding the settlement of the financial status of player MAATI
TAMYAZOU,
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We apologize for the involuntary delay and inform you that the reason for the delay is the end
of the Fiscal [sic] year in Libya and the bank holiday For [sic] the month of Ramada. We also
inform you that the player is absent from the team’s training today and has left the city of and
residence without permission, which constitutes a clear violation of the terms of the contract.
Therefore, we address this letter to you, requesting that you attend the financial departments to
receive the dues or provide us with a method for paying salaries. It is mandatory to attend
training and adhere to the laws and regulations. […]”
7.
On 14 March 2024, the Player provided the Club with his bank details and reiterated the
content of his default notice dated 1 March 2025.
8.
On 15 March 2025, the Club sent the following correspondence to the Player:
“After greeting you, with reference to your letter dated Friday, March 14, in which you provided
us with the bank details of athlete MAATI TAMAYAZOU, we would like to inform you that, based
on the decision of the Libyan government attached to this letter, Friday and Saturday are official
public holidays in the State of Libya No. 1019 of 1990, which will delay the bank transfer process
and conflict with the deadline you have granted.
After communicating with the player in question, the player has agreed to come to the State of
Libya and join the team's training on Monday, March 16, 2025, provided that he receives his
contribution in cash upon arrival.
We are therefore informing you of the circumstances we are facing, noting that the club is
prepared to pay in any manner and that the amount is ready, either in cash upon arrival or by
bank transfer, provided that the SWIFT transfer, due to the holidays, requires an extension of
the deadline until Monday, March 17, 2025, at the end of the day.
We hope you will understand and cooperate with us to reach a resolution. […]”
(Freely translated from French)
9.
On 16 March 2025, the Club sent the following correspondence to the Player, accompanied
by proof of payment dated 15 March 2025 in the amount of USD 11,250:
“Dear Sir,
We have previously sent you a letter regarding the payment mechanism for the player Maati
Tamayazou on March 15th, but without any response of approval or rejection. We hereby inform
you that the club, as a gesture of goodwill, has transferred the amount via an authorized
exchange office to the State of Morocco, the place of residence and presence of the player this
evening, as attached and proven to you with the financial receipt for the transfer process, due
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REF. FPSD-18633
to the difficulty of the Swift bank transfer in Libya we thank you for your kind cooperation with
us.”
10. On 18 March 2025, the Club sent the following correspondence to the Player:
“Sir, we would like to inform you that we have not yet received a response to our previous letter.
We would like to inform you that we have transferred $11,250 via a currency exchange office.
We have attached the approved receipt, but without a response. The amount has not yet been
received. We have therefore proceeded with the transfer via SWIFT. However, we are missing the
other information for the player's account. We hope you will provide us with the account
number. We would like to inform you that we are calling the player to join training sessions as
soon as possible and that we are ready to facilitate the return procedures, including ticket
delivery and security checks. We look forward to resolving these issues as quickly as possible.”
(Freely translated from French)
11. On 19 March 2025, the Club sent the following correspondence to the Player:
“This is the third time we have contacted you regarding the player's situation and his
motivations. To date, the transfer to Morocco in the player's name has not been received and
we have not received the player's bank account details to finalize the SWIFT transaction.
Furthermore, the club has asked the player to resume training, but to no avail and without
response. The club is therefore renewing its friendly letter to finalize the transaction and
demands that the player resume training while respecting his rights towards the club.”
(Freely translated from French)
II. Proceedings before FIFA
12. On 17 March 2025, the Player filed the claim at hand before FIFA. A summary of the parties’
respective positions is detailed below.
a. Claim of the Player
13. In his claim, the Player argued that the Club has continuously being in breach of its
contractual obligations as per the Contract.
14. In this context, the Player’s requests for relief were the following:
“32.1. Declare that the Claimant has terminated his employment contract with just cause, in
accordance with Article 14bis FIFA RSTP, due to the Respondent’s repeated breaches;
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32.2. Confirm that the Claimant is immediately released from all contractual obligations toward
the Respondent without any sporting or financial consequences on his part;
32.3. Order the Respondent to pay the Claimant full financial compensation for the Respondent’s
breach of contract, calculated as follows:
32.3.1. Payment of outstanding remuneration:
• Outstanding salary installment (25%) due at mid-season: USD 11.250 with interest at a rate of
5% per annum from March 17, 2025, until the date of effective payment;
32.3.2. Payment of compensation for breach of contract as follows:
• Payment of USD 82,500, representing the rest of the total value of the contract (which is worth
105,000 USD) with an interest at a rate of 5% per annum from the due date of termination until
full payment;
32.3.3. Payment of all outstanding bonuses, including:
• Unpaid match bonuses for five official matches as per the club’s internal policy 1000 Libyan
Dinars (LYD) and 500 Libyan Dinars (LYD) per draw which is a total of 4.500 Libyan Dinars which
equates to 934,09 USD. The amounts for the bonuses should accrue interest at a rate of 5% per
annum from their respective due dates until the date of effective payment;
32.3.4. Imposing sporting sanctions against the Respondent:
• Imposition of sporting sanctions on Al Sadaqa Shahat SC, in accordance with Article 24 of the
RSTP, for its persistent failure to fulfill contractual obligations. Sanctions may include a transfer
ban or any other appropriate disciplinary measures.”
b. Reply of the Club and counterclaim
15. In its reply, the Club argued that it had done everything it could to pay the Player and had
fulfilled its obligations towards him pursuant to the Contract.
16. In addition, the Club argued that the Player was absent from training sessions and left Libya
without authorisation.
17. Considering the foregoing, the Club lodged a counterclaim against the Player, requesting
the payment of the residual value of the Contract in the amount of USD 71,250.
c. Player’s reply to the counterclaim
18. In his reply to the counterclaim lodged by the Club, the Player reiterated his initial position
and requests for relief, noting that the Contract was terminated with just cause due to
outstanding remuneration. In this context, the Player argued that the Club’s counterclaim
is entirely without merit and that it failed to provide any evidence to support its position.
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d. Unsolicited correspondence from the parties
19. Based on art. 11 par. 4 of the Procedural Rules Governing the Football Tribunal (hereinafter:
the Procedural Rules), the Player’s correspondence dated 23 April 2025, and the Club’s
correspondence dated 3 May 2025 were disregarded as they were filed outside the relevant
time limit.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
20. First of all, the Dispute Resolution Chamber (hereinafter: the Chamber or the DRC) analysed
whether it was competent to deal with the case at hand. In this respect, it took note that
the present matter was presented to FIFA on 17 March 2025 and submitted for decision on
4 September 2025. Taking into account the wording of arts. 31 and 34 of the January 2025
edition of the Procedural Rules, the aforementioned edition of the Procedural Rules is
applicable to the matter at hand.
21. Furthermore, the Chamber referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations on the Status and Transfer of Players (hereinafter: the Regulations) (July 2025
edition), it is competent to deal with the matter at stake, which concerns an employmentrelated dispute with an international dimension between an Moroccan player and a Libyan
club.
22. Subsequently, the Chamber analysed which regulations should be applicable as to the
substance of the matter. In this respect, it confirmed that, in accordance with art. 29 of the
Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand as
to the substance.
b. Burden of proof
23. The Chamber recalled the basic principle of burden of proof, as stipulated in art. 13
par. 5 of the Procedural Rules, according to which a party claiming a right on the basis of
an alleged fact shall carry the respective burden of proof. Likewise, the Chamber stressed
the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which it may consider
evidence not filed by the parties, including without limitation the evidence generated by or
within the Transfer Matching System (TMS).
c. Merits of the dispute
24. Having established the competence and the applicable regulations, the Chamber entered
into the merits of the dispute. In this respect, the Chamber started by acknowledging all
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REF. FPSD-18633
the above-mentioned facts as well as the arguments and the documentation on file.
However, the Chamber emphasised that in the following considerations it will refer only to
the facts, arguments and documentary evidence, which it considered pertinent for
assessing the matter at hand.
i. Main legal discussion and considerations
25. The Chamber then moved to the substance of the matter, and took note of the fact that
the parties strongly dispute the justice of the early termination of the Contract by the
Player, based on the alleged non-payment of certain financial obligations by the Club as
per the Contract, in accordance with art. 14bis of the Regulations.
26. In this context, the Chamber acknowledged that its task was to determine, based on the
evidence presented by the parties, whether the claimed amounts had in fact remained
unpaid by the Club and, if so, whether the formal pre-requisites of art. 14bis of the
Regulations had in fact been fulfilled.
27. The Chamber then referred to the wording of art. 14bis par. 1 of the Regulations, in
accordance with which, if a club unlawfully fails to pay a player at least two monthly salaries
on their due dates, the player will be deemed to have a just cause to terminate his contract,
provided that he has put the debtor club in default in writing and has granted a deadline
of at least 15 days for the debtor club to fully comply with its financial obligation(s).
28. In the present matter, the Chamber noted that the Player claims not having received his
remuneration corresponding to USD 11,250, i.e. the second instalment for the season
2024/2025. Furthermore, the Chamber took note that the Player has provided written
evidence of having put the Club in default on 1 March 2025 for the outstanding amount of
USD 11,250 under the Contract.
29. In continuation, the Chamber recalled the wording of art. 14bis par. 2 of the Regulations,
according to which for any salaries of a player which are not due on a monthly basis, the
pro-rata value corresponding to two months shall be considered.
30. Considering the foregoing, the fact that the Player’s salary was not due on a monthly basis,
that no due dates were included in the Contract for the payment of its instalments and that
there is no evidence on file in this regard, the Chamber calculated the pro-rata value of the
Player’s remuneration and concluded that his monthly salary corresponded to USD 4,375,
i.e. USD 105,000 / 24 months.
31. Accordingly, the Chamber held that, on the date of his default notice to the Club dated 1
March 2025, the Player had outstanding remuneration of more than two monthly salaries.
32. The Chamber then recalled that, in the case at hand, the Club bore the burden of proving
that it indeed complied with the financial terms of the Contract concluded between the
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REF. FPSD-18633
parties. Nonetheless, the Chamber considered that the evidence provided by the Club does
not prove the payment of the amount claimed as outstanding by the Player. In particular,
the Chamber observed that the proof of payment dated 15 March 2025 provided by the
Club is merely a printed copy with handwritten additions and lacks essential elements such
as the names of the financial institutions and the relevant bank details involved in the
alleged transaction. In any event, the Chamber pointed out that, based on the evidence on
file, the Club informed the Player after 15 March 2025 that the payment of the outstanding
amount had not been completed. Therefore, the Chamber concluded that the Club had
failed to comply with the financial terms of the Contract.
33. Moreover, in the absence of a notice of termination of the Contract sent from the Player to
the Club, the Chamber concluded that the Player terminated the Contract by lodging his
claim before FIFA on 17 March 2025, i.e. at least 15 days after the default notice sent to the
Club.
34. For the sake of completeness, the Chamber referred to art. 13 par. 5 of the Procedural
Rules, according to which a party that asserts a fact has the burden of proving it, and went
on to analyse the documentation provided by the Club in support of its allegation that the
Player failed to fulfil his contractual obligations due to his prolonged absence without
proper authorisation. After a thorough analysis of the evidence on file, the Chamber
considered that the Club did not discharge its burden of proof as it failed to provide any
evidence in this regard.
35. Thus, the Chamber decided that the Player had a just cause to unilaterally terminate the
Contract, based on art. 14bis of the Regulations.
36. Lastly, the Chamber held that the foregoing finding, i.e. the Player had just cause to
unilaterally terminate the Contract, necessarily leads to the conclusion that the
counterclaim of the Club is rejected.
ii. Consequences
37. Having stated the above, the Chamber turned its attention to the question of the
consequences of such unjustified breach of contract committed by the Club.
38. The Chamber observed that the outstanding remuneration at the time of termination of
the Contract, coupled with the specific requests for relief of the Player, are equivalent to
USD 11,250, i.e. the second instalment of the Contract for the season 2024/2025.
39. As a consequence, and in accordance with the general legal principle of pacta sunt servanda,
the Chamber decided that the Club is liable to pay the Player USD 11,250 as the outstanding
amount under the Contract at the moment of its termination.
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40. In addition, taking into consideration the Player’s request as well as the constant practice
of the Football Tribunal in this regard, the Chamber decided to award the Player interest
at the rate of 5% p.a. on the outstanding amount as from 17 March 2025 until the date of
effective payment.
41. Having stated the above, the Chamber turned to the calculation of the amount of
compensation payable by the Club in the case at stake. In doing so, the Chamber firstly
recapitulated that, in accordance with art. 17 par. 1 of the Regulations, the amount of
compensation shall be calculated, in particular and unless otherwise provided for in the
contract at the basis of the dispute, taking into account the damage suffered, according to
the “positive interest” principle, having regard for the individual facts and circumstances of
each case, and with due consideration for the law of the country concerned.
42. In application of the relevant provision, the Chamber held that it first of all had to clarify as
to whether the pertinent employment contract contained a provision by means of which
the parties had beforehand agreed upon an amount of compensation payable by the
contractual parties in the event of breach of contract. In this regard, the Chamber
established that no compensation clause providing for an amount due in the event of
termination of the employment relationship by the Player was included in the Contract at
the basis of the matter at stake.
43. As a consequence, the members of the Chamber determined that the amount of
compensation payable by the Club to the Player had to be assessed in application of the
other parameters set out in art. 17, par. 1 of the Regulations. In this respect, the Chamber
recalled that, as a general rule, the compensation to be paid to the player by the club shall
be equal to the residual value of the contract that was prematurely terminated, unless the
player signed a new contract following the termination of his previous contract (cf. art. 17
par. 1 lit. i)).
44. Bearing in mind the foregoing, as well as the claim of the Player, the Chamber proceeded
with the calculation of the monies payable to the Player under the terms of the Contract
from the date of its unilateral termination until its end date. Consequently, the Chamber
concluded that the amount of USD 71,250 (i.e. USD 11,250 as the third instalment for the
season 2024/2025 and USD 60,000 for the season 2025/2026) serves as the basis for the
determination of the amount of compensation for breach of contract.
45. In continuation, the Chamber verified as to whether the Player had signed an employment
contract with another club during the relevant period of time, by means of which he would
have been enabled to reduce his loss of income. According to the constant practice of the
DRC as well as art. 17 par. 1 lit. ii) of the Regulations, such remuneration under a new
employment contract shall be taken into account in the calculation of the amount of
compensation for breach of contract in connection with the player’s general obligation to
mitigate his damages.
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46. In this respect, the Chamber noted that the Player remained unemployed since the
unilateral termination of the Contract.
47. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Chamber decided that the Club must pay the amount of USD 71,250
to the Player, which was to be considered a reasonable and justified amount of
compensation for breach of contract in the present matter.
48. Taking into consideration the Player’s request as well as the constant practice of the
Football Tribunal in this regard, the Chamber decided to award the Player interest on said
compensation at the rate of 5% p.a. as of 17 March 2025 until the date of effective payment.
49. Lastly, the Chamber rejected the Player’s request for match bonuses as it is not supported
with the necessary documentary evidence in accordance with art. 13 par. 5 of the
Procedural Rules.
iii. Compliance with monetary decisions
50. Finally, taking into account the applicable Regulations, the Chamber referred to art. 24 par.
1 and 2 of the Regulations, which stipulate that, with its decision, the pertinent FIFA
deciding body shall also rule on the consequences deriving from the failure of the
concerned party to pay the relevant amounts of outstanding remuneration and/or
compensation in due time.
51. In this regard, the DRC highlighted that, against clubs, the consequence of the failure to
pay the relevant amounts in due time shall consist of a ban from registering any new
players, either nationally or internationally, up until the due amounts are paid. The overall
maximum duration of the registration ban shall be of up to three entire and consecutive
registration periods.
52. Therefore, bearing in mind the above, the DRC decided that the Club must pay the full
amount due (including all applicable interest) to the Player within 45 days of notification of
the decision, failing which, at the request of the Player, a ban from registering any new
players, either nationally or internationally, for the maximum duration of three entire and
consecutive registration periods shall become immediately effective on the Club in
accordance with art. 24 par. 2, 4, and 7 of the Regulations.
53. The Club shall make full payment (including all applicable interest) to the bank account
provided by the Player in the Bank Account Registration Form, which is attached to the
present decision.
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54. The DRC recalled that the above-mentioned ban will be lifted immediately and prior to its
complete serving upon payment of the due amounts, in accordance with art. 24 par. 8 of
the Regulations.
d. Costs
55. The Chamber referred to art. 25 par. 1 of the Procedural Rules, according to which
“Procedures are free of charge where at least one of the parties is a player, coach, football agent,
or match agent”. Accordingly, the Chamber decided that no procedural costs were to be
imposed on the parties.
56. Likewise, and for the sake of completeness, the Chamber recalled the contents of art. 25
par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
57. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
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IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Maati Tamayazou, is partially accepted.
2.
The counterclaim of the Respondent, Al Sadaqa Shahat SC, is rejected.
3.
The Respondent must pay to the Claimant the following amounts:
- USD 11,250 as outstanding remuneration plus 5% interest p.a. as from 17 March 2025
until the date of effective payment; and
- USD 71,250 as compensation for breach of contract plus 5% interest p.a. as from 17
March 2025 until the date of effective payment.
4.
Any further claims of the Claimant are rejected.
5.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
6.
Pursuant to art. 24 of the Regulations on the Status and Transfer of Players, if full payment
(including all applicable interest) is not made within 45 days of notification of this decision,
the following consequences shall apply:
1. The Respondent shall be banned from registering any new players, either nationally or
internationally, up until the due amount is paid. The maximum duration of the ban shall
be of up to three entire and consecutive registration periods.
2. The present matter shall be submitted, upon request, to the FIFA Disciplinary Committee
in the event that full payment (including all applicable interest) is still not made by the
end of the three entire and consecutive registration periods.
7.
The consequences shall only be enforced at the request of the Claimant in accordance
with art. 24 par. 7 and 8 and art. 25 of the Regulations on the Status and Transfer of Players.
8.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
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NOTE RELATED TO THE APPEAL PROCEDURE:
According to art. 50 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf., art. 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION:
Fédération Internationale de Football Association – Legal & Compliance Division
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
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