Labour Disputes
Texto da decisão
REF. FPSD-19645
Decision of the
Dispute Resolution Chamber
passed on 15 August 2025
regarding an employment-related dispute concerning the player Christian Ilic
BY:
Calum BEATTIE (Scotland)
CLAIMANT:
Christian Ilic, Croatia
Represented by Pauline Mbanza
RESPONDENT:
FUTBOLEN KLUB SPARTAK 1918, Bulgaria
Represented by Iva Nikolova
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REF. FPSD-19645
I. Facts of the case
1.
On 3 July 2024, the Croatian player, Christian Ilic (hereinafter: the Player or the Claimant),
and the Bulgarian club, Spartak Varna (hereinafter: the Club or the Respondent) entered into
an employment contract (hereinafter: the Contract) valid as from 4 July 2024 until 15 June
2025.
2.
According to clause III. 2 of the Contract, the parties agreed that the Player would receive
a monthly salary of “BGN 13,555.62 […] 6,000.00 EUR NET on the date of conclusion of the
contract/ payable by the 30th of the next month”.
3.
In addition, the Player was entitled to the following bonuses:
“viii.1 the CLUB pays the FOOTBALLER a bonus of 150 euros for every goal and assist”
viii.11 the CLUB in its capacity as an employer provides an apartment or in the event of
another desire of the FOOTBALLER, will pay BGN 500/five hundred per month for housing
rent. THE SOCCER PLAYER will pay all additional costs for electricity, water and other
consumables for the apartment/apartment.”
4.
On 5 May 2025, the Player sent to the Club a default notice requesting the total amount of
EUR 16,650 as follows:
“€3,600 – 60% of my December salary
€12,000 – Full salary for February and March
€750 – Four months’ rent
€300 – One Goal + One Assist bonus”
5.
The Player gave a deadline of 15 days to the Club to comply with its default.
II. Proceedings before FIFA
6.
On 18 June 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
7.
The Player lodged the present claim with FIFA for overdue payables that arose from the
Contract.
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REF. FPSD-19645
8.
In particular, the Player requested the following relief:
“i. Determine that the Respondent failed to comply with its financial obligations established
under the Employment Agreement and, consequently, order the Respondent to the payment
of the monthly salaries match bonuses and house rent in the total amount of EUR 16,650
(Sixteen Thousand Six Hundred Fifty Euros) net;
ii. Order the Respondent to pay 5% interest p.a. calculated over the outstanding amount, as
of the day after such amount became due, i.e. 31 January 2025, 30 March 2025, and 30 June
2025, until the dates of effective payment;
iii. Impose a fine upon the Respondent as outlined under Article 12bis par. 4 FIFA RSTP”
9.
Regarding the requested amounts, the Player argued that the salaries of February, March
2025 as well as the balance of the salary of December 2024 remained outstanding.
However, the Player did not provide a breakdown of the housing allowance.
10. Finally, the Player alleged that the Club expressly acknowledged its debt towards the Player
by failing to contest the existence of its debt and by failing to reply to the Player’s default
notice.
b. Reply of the Respondent
11. Despite being invited to do so, the Respondent did not reply to the claim.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
12. First of all, the Single Judge of the Dispute Resolution Chamber (hereinafter: the Single Judge)
analysed whether he was competent to deal with the case at hand. In this respect, he took
note that the present matter was presented to FIFA on 18 June 2025 and submitted for
decision on 15 August 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.
13. Furthermore, the Single Judge 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 Single Judge is competent to deal with the matter at stake, which
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REF. FPSD-19645
concerns an employment-related dispute with an international dimension between a
Croatian player and a Bulgarian club.
14. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, he 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
15. The Single Judge 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 Single Judge
stressed the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which he 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
16. Having established the competence and the applicable regulations, the Single Judge
entered into the merits of the dispute. In this respect, the Single Judge started by
acknowledging all the above-mentioned facts as well as the arguments and the
documentation on file. However, the Single Judge emphasised that in the following
considerations he will refer only to the facts, arguments and documentary evidence, which
he considered pertinent for assessing the matter at hand.
i. Main legal discussion and considerations
17. The Single Judge then moved to the substance of the matter, and acknowledged that his
task was to determine the total amount that remained outstanding from the Contract.
18. The Single Judge pointed out that the Respondent did not reply to the claim, entailing that
his decision must be made on the basis of the documentation on file, that is, the
argumentation and evidence filed by the Claimant, in line with art. 21 par. 1 of the
Procedural Rules.
19. Having stated the above, the Single Judge turned his attention to the determination of the
outstanding amounts and noted that the Player requested outstanding salaries, bonuses
as well as the housing allowance.
20. In relation to the outstanding salaries, the Single Judge observed that the Player claimed
payment of the monthly salaries for February and March 2025, each amounting to EUR
6,000, as well as the remaining balance of EUR 3,600 from the December 2024 salary.
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REF. FPSD-19645
21. The Single Judge further noted that the Club failed to submit a response to the claim. As a
result, the Player’s allegations regarding the unpaid salaries remained uncontested.
22. Consequently, in view of the above and the principle of pacta sunt servanda, the Single Judge
decided to award the Player the amount of EUR 15,600 as outstanding salaries.
23. Furthermore, the Single Judge observed that the Player requested the bonuses of EUR 150
for one goal and EUR 150 for one assist.
24. Nevertheless, the Single Judge observed that the Player failed to submit any supporting
evidence and did not discharge his burden of proof to establish that the conditions for the
claimed bonuses had been met.
25. In light of the foregoing, the Single Judge rejected the Player’s request for payment of the
bonuses.
26. In addition, the Player requested payment of housing rent in the total amount of EUR 750,
but did not specify which months were allegedly outstanding.
27. The Single Judge recalled that, under the terms of the Contract, the Player was entitled to
a monthly rent allowance of BGN 500. Given the lack of a detailed breakdown from the
Player, and considering that BGN 500 is approximately equivalent to EUR 255, the Single
Judge inferred that the claim likely related to three months of unpaid rent (EUR 255 × 3).
28. In this context, and taking into account that the Contract stipulated payment in BGN, the
Single Judge awarded the Player the equivalent of EUR 750, corresponding to BGN 1,466.85.
29. Consequently, and in line with the principle of pacta sunt servanda, the Single Judge decided
to award the amount of BGN 1,466.85 to the Player as housing allowance.
30. In light of the foregoing, the Single Judge decided to award the Player the net amount of
EUR 15,600, corresponding to the salaries for February and March 2025 and the
outstanding balance of the December 2024 salary, as well as BGN 1,466.85 in respect of
the housing allowance.
31. In addition, taking into consideration the Claimant’s request as well as the constant practice
of the Football Tribunal in this regard, the Single Judge decided to award the Claimant
interest at the rate of 5% p.a. on the outstanding amounts as following:
-
5% interest over the amount of EUR 3,600 as from 1 January 2025 until the
date of effective payment;
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REF. FPSD-19645
-
5% interest over the amount of EUR 3,600 as from 1 March2025 until the date
of effective payment;
-
5% interest over the amount of EUR 6,000 as from 1 April 2025 until the date
of effective payment;
-
5% interest over the amount of BGN 1,466.85 as from 18 June 2025 until the
date of effective payment.
32. Finally, and for the sake of completeness, the Single Judge wished to clarify that due to the
generic request for relief regarding the housing allowance, the 5% interest over the amount
corresponding to the housing allowance shall accrue from the date on which the claim was
submitted.
ii. Art. 12bis of the Regulations
33. The Single Judge then referred to art.12bis par. 2 of the Regulations, which stipulates that
any club found to have delayed a due payment for more than 30 days without a prima facie
contractual basis may be sanctioned, in accordance with art. 12bis par. 4 of the Regulations.
34. To this end, the Single Judge confirmed that the Claimant put the Respondent in default of
payment of the amounts sought, which had fallen due for more than 30 days, and granted
the Respondent with at least 10 days to cure such breach of contract.
35. Accordingly, the Single Judge also confirmed that the Respondent had delayed a due
payment without a prima facie contractual basis. It followed that the criteria enshrined in
art. 12bis of the Regulations were met in the case at hand.
36. The Single Judge further established that, by virtue of art. 12bis par. 4 of the Regulations
the Single Judge has competence to impose sanctions on the club. On account of the above,
and bearing in mind that this is the second offense by the Respondent within the last two
years, the Single Judge decided to impose a reprimand on the Respondent in accordance
with art. 12bis par. 4 lit. a) of the Regulations.
37. The Single Judge also highlighted that a repeated offence will be considered as an
aggravating circumstance and lead to more severe penalty, in accordance with art. 12bis
par. 6 of the Regulations.
iii. Compliance with monetary decisions
38. Finally, taking into account the applicable Regulations, the Single Judge 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
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REF. FPSD-19645
concerned party to pay the relevant amounts of outstanding remuneration and/or
compensation in due time.
39. In this regard, the Single Judge 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.
40. Therefore, bearing in mind the above, the Single Judge 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.
41. 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.
42. The Single Judge 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
43. The Single Judge 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 Single Judge decided that no procedural costs were to be
imposed on the parties.
44. Likewise, and for the sake of completeness, the Single Judge recalled the contents of art.
25 par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
45. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
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REF. FPSD-19645
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Christian Ilic, is partially accepted.
2.
The Respondent, Futbolen Klub Spartak 1918, must pay the Claimant the following
amounts:
-EUR 15,600 net and BGN 1,466.85 as outstanding remuneration plus 5% interest p.a.
as follows:
-5% interest over the amount of EUR 3,600 as from 1 January 2025 until the date of
effective payment;
-5% interest over the amount of EUR 6,000 as from 1 March 2025 until the date of
effective payment;
-5% interest over the amount of EUR 6,000 as from 1 April 2025 until the date of effective
payment;
-5% interest over the amount of BGN 1,466.85 as from 18 June 2025 until the date of
effective payment.
3.
Any further claims of the Claimant are rejected.
4.
A reprimand is imposed on the Respondent.
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.
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REF. FPSD-19645
8.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
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REF. FPSD-19645
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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