Labour Disputes
Texto da decisão
REF. FPSD-19218
Decision of the
Dispute Resolution Chamber
passed on 24 July 2025
regarding an employment-related dispute concerning the Player
Sokol Cikalleshi
BY:
Clifford J. HENDEL (USA), Deputy Chairperson
Dana MOHAMED AL-NOAIMI (Qatar), Member
Khadija TIMERA (Senegal), Member
CLAIMANT:
Sokol Cikalleshi, Albania
Represented by Mr Anıl Dinçer
RESPONDENT:
Adanaspor AS, Türkiye
pg. 2
REF. FPSD-19218
I. Facts of the case
1.
On 13 January 2025, the Albanian player Sokol Cikalleshi (hereinafter: Claimant or player)
and the Turkish club Adanaspor AS (hereinafter: club or Respondent) concluded an
employment contract (hereinafter: contract) valid as from the date of signature until
31 May 2025.
2.
According to the contract, the Respondent undertook to pay the Claimant a monthly salary
of EUR 48,000 net, payable in equal instalments at the end of each month between January
2025 and 30 May 2025, to result in a total remuneration package of EUR 240,000 net.
3.
Furthermore, pursuant to the Contract, the Respondent undertook to pay the Claimant a
goal contribution (goal or assist) bonus of EUR 2,000 each.
4.
No default notices or correspondence exchanged between the parties has been submitted
to the file.
II. Proceedings before FIFA
5.
On 13 May 2025, the Claimant filed the claim at hand before FIFA. A summary of the parties’
respective positions is detailed below.
a. Claim of the Claimant
6.
In his claim, the player argued that the Respondent failed to pay the first four instalments
under the Contract of EUR 48,000 net each.
7.
Furthermore, according to the Claimant, the Respondent failed to pay EUR 6,000 as goal
contribution bonuses, since the former has scored three goals during the term of the
Contract.
8.
As such, the Claimant argued that the total debt of the Respondent constituted EUR 48,000
x 4 plus EUR 2,000 x 3 = EUR 198,000 net.
9.
The Claimant requested this amount with interest as follows:
-
On the amount of EUR 48,000, as from 1 February 2025 until the date of
effective payment;
On the amount of EUR 48,000, as from 1 March 2025 until the date of effective
payment;
On the amount of EUR 48,000, as from 1 April 2025 until the date of effective
payment;
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REF. FPSD-19218
-
On the amount of EUR 48,000, as from 1 May 2025 until the date of effective
payment;
On the amount of EUR 6,000, as from 13 May 2025 (date of claim) until the date
of effective payment.
b. Reply of the Respondent
10. On 22 May 2025, the Respondent was invited to provide a position to the claim and to state
whether it agreed or disagreed with a proposal issued by the FIFA General Secretariat.
11. On 30 May 2025, the Respondent requested an extension of the deadline to reply to the
claim.
12. On 24 June 2025, the FIFA General Secretariat issued a correspondence, wherein it granted
the Respondent an extension to provide its final submission by no later than 30 June 2025.
13. No further submission followed from the Respondent within the stipulated timeframe.
pg. 4
REF. FPSD-19218
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
14. First of all, the Dispute Resolution Chamber (hereinafter: the Chamber or 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 13 May 2025 and submitted for decision on
24 July 2025. Taking into account the wording of art. 31 and 34 of the January 2025 edition
of the Procedural Rules Governing the Football Tribunal (hereinafter: the Procedural Rules),
the aforementioned edition of the Procedural Rules is applicable to the matter at hand.
15. 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) (January
2025 edition), the Dispute Resolution Chamber is competent to deal with the matter at
stake, which concerns an employment-related dispute with an international dimension
between an Albanian player and a Turkish club.
16. 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 January 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Burden of proof
17. 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
18. 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
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.
pg. 5
REF. FPSD-19218
i. Main legal discussion and considerations
19. The Chamber then moved to the substance of the matter, and took note of the fact that
the basis of the present dispute is the payment of allegedly outstanding salaries, as well as
a conditional bonus for goals scored, pursuant to the Contract.
20. In this context, the Chamber acknowledged that its task was to determine whether the
amounts indeed remained unpaid, and based thereupon, what the consequences of such
supposedly unlawful non-payment may be.
21. It has to be noted that in the case at hand the Respondent bore the burden of proving that
it indeed complied with the financial terms of the contract concluded between the parties.
By failing to substantively reply to the claim, the Respondent left the amount in dispute
uncontested.
22. Therefore, in any event, the Chamber was comfortable to conclude that the contractually
guaranteed amounts – i.e., the four requested salaries between January and April 2025 –
shall be awarded to the Claimant, in the amount of EUR 192,000.
23. Having set this out, the Chamber moved on to consider the entitlement of the Claimant to
the goalscoring bonus in the amount of EUR 6,000 in total.
24. In this sense, the Chamber noted that the Claimant provided evidence of having scored
three goals during the 2024/2025 season.
25. The Chamber particularly noted that these goals occurred during the term of the Contract
at stake with the Respondent (in matches played on 8 February, 22 February, and
5 April 2025 respectively. As such, the Claimant met the burden of proving his entitlement
to the bonuses, in the Chamber’s estimation.
26. In view of the aforementioned, the Chamber decided that the Claimant shall be entitled to
receive overdue payables in the amount of EUR 198,000 net in total, in accordance with the
general legal principle of pacta sunt servanda.
27. Furthermore, the Chamber awarded interest on the above amount as follows:
-
On the amount of EUR 48,000 net, as from 1 February 2025 until the date of
effective payment;
On the amount of EUR 48,000 net, as from 1 March 2025 until the date of
effective payment;
On the amount of EUR 48,000 net, as from 1 April 2025 until the date of
effective payment;
On the amount of EUR 48,000 net, as from 1 May 2025 until the date of
effective payment;
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REF. FPSD-19218
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On the amount of EUR 6,000 net, as from 13 May 2025 (date of claim) until the
date of effective payment.
ii. Compliance with monetary decisions
28. 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.
29. 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.
30. Therefore, bearing in mind the above, the DRC decided that the Respondent must pay the
full amount due (including all applicable interest) to the Claimant within 45 days of
notification of the decision, failing which, at the request of the Claimant, 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 Respondent in accordance with art. 24 par. 2, 4, and 7 of the Regulations.
31. The Respondent shall make full payment (including all applicable interest) to the bank
account provided by the Claimant in the Bank Account Registration Form, which is attached
to the present decision.
32. 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
33. 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.
34. 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.
pg. 7
REF. FPSD-19218
35. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
pg. 8
REF. FPSD-19218
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Sokol Cikalleshi, is accepted.
2.
The Respondent, Adanaspor AS, must pay to the Claimant EUR 198,000 net as outstanding
remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of EUR 48,000 net as from 1 February 2025 until the
date of effective payment;
- 5% interest p.a. over the amount of EUR 48,000 net as from 1 March 2025 until the date
of effective payment;
- 5% interest p.a. over the amount of EUR 48,000 net as from 1 April 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 48,000 net as from 1 May 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 6,000 net as from 13 May 2025 until the date of
effective payment.
3.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
4.
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.
5.
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.
pg. 9
REF. FPSD-19218
6.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 10
REF. FPSD-19218
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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