Labour Disputes
Texto da decisão
REF. FPSD-19726
Decision of the
Dispute Resolution Chamber
passed on 29 October 2025
regarding an employment-related dispute concerning the player Gaetan
Laura
COMPOSITION:
Frans DE WEGER (The Netherlands), Chairperson
Calum BEATTIE (Scotland), Member
Johan VAN GAALEN (South Africa), Member
CLAIMANT:
Gaetan Laura, France
Represented by Nazım Burçin Çelen
RESPONDENT:
MKE Ankaragucu SK, Türkiye
pg. 2
REF. FPSD-19726
I. Facts of the case
1.
On 6 February 2025, the French player Gaetan Laura (hereinafter: the Player or the Claimant)
and the Turkish club MKE Ankaragucu SK (hereinafter: the Club or the Respondent) entered
into an employment agreement valid as from the aforementioned date until 30 June 2026.
2.
Pursuant to the Contract, the Player was entitled to inter alia the following payments:
−
2024/2025 season
o Sign-on fee – EUR 75,000 due on 10 February 2025
o Salaries of EUR 200,000 net payable as follows:
▪ EUR 40,000 net on 28 February 2025
▪ EUR 40,000 net on 31 March 2025
▪ EUR 40,000 net on 30 April 2025
▪ EUR 40,000 net on 31 May 2025
▪ EUR 40,000 net on 30 June 2025
o Annual contribution of EUR 7,500 net for accommodation, flights, and car
expenses, due on 30 June 2025.
−
2025/2026 season
o Salaries of EUR 475,000 net payable as follows:
▪ EUR 47,500 net on 30 September 2025
▪ EUR 47,500 net on 31 October 2025
▪ EUR 47,500 net on 30 November 2025
▪ EUR 47,500 net on 31 December 2025
▪ EUR 47,500 net on 31 January 2026
▪ EUR 47,500 net on 28 February 2026
▪ EUR 47,500 net on 31 March 2026
▪ EUR 47,500 net on 30 April 2026
▪ EUR 47,500 net on 31 May 2026
▪ EUR 47,500 net on 30 June 2026
o Annual contribution of EUR 15,000 net for accommodation, flights, and car
expenses, due on 30 June 2026.
3.
The Contract further stated in point 2 of Clause 3 that “All the payments stipulated in this
Contract are net and the Club shall pay any tax obligations on behalf of the Player, including
but not limited to VAT, withholding and income tax.”
4.
On 2 June 2025, the Player put the Club in default and granted the Club 15 days to remit
payment on the total amount of EUR 120,000, relating to the salaries for March, April, and
May, due on 31 March 2025, 30 April 2025, and 31 May 2025, respectively.
pg. 3
REF. FPSD-19726
5.
On 19 June 2025, the Player sent a termination notice whereby he terminated the Contract.
6.
On 1 September 2025, the Player signed a new contract with the Iraqi club, Newroz Sports
Club. Such contract is valid as from 20 August 2025 until 20 June 2026 and the Player is
entitled to receive USD 330,000 in 10 equal monthly instalments of USD 33,000, payable at
the end of each Gregorian month. In addition, the new contract stipulated that the
amounts stated therein were net amounts in the state of Iraq.
II. Proceedings before FIFA
7.
On 27 June 2025, the Claimant filed the claim at hand before FIFA. A summary of the parties’
respective positions is detailed below.
a. Position of the Claimant
8.
The Player’s claim consisted of a claim for outstanding remuneration and compensation
for breach of contract, whereby he alleged that he had terminated the Contract with just
cause on the basis of art. 14bis of the Regulations on the Status and Transfer of Players.
9.
The Player’s requests for relief were the following (quoted verbatim):
“The Claimant firstly request your Chamber to make a decision that the Respondent has to pay
the overdue net amount of €120.000,00.- with its interest at the rate of 5% per annum as from
the dates stipulated herein below respectively until the date of effective payment.
Amount
➢ €40.000,00.➢ €40.000,00.➢ €40.000,00.-
Commencement of the Interest
31.03.2025
30.04.2025
31.05.2025
8.2 The Claimant secondly request your Chamber to make a decision that the unilateral
termination made by the Claimant is with just cause and in line with the jurisprudence of FIFA
and CAS.
8.3 The Claimant thirdly request your Chamber to make a decision that the Respondent has to
pay a compensation of €522,500,00.- corresponding to the remaining part of the contractual
relation with its interest rate of 5% per annum as from the termination date of 19.06.2025 until
the date effective payment.
8.4 The Claimant fourthly request your Chamber to condemn the Respondent pay indemnity of
€240,000,00 in accordance with article 337c/3 of Swiss Code of Obligations with its interest
starting from 19.06.2025
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REF. FPSD-19726
8.5 In consideration of the fact that the Respondent caused the Claimant to file the case herein,
we would like to request your Chamber to make a decision that the judicial costs and the legal
fees that the Claimant is faced with shall be fully paid by the Respondent.”
b. Position of the Respondent
10. Despite being invited to do so, the Club failed to submit a reply to the claim.
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REF. FPSD-19726
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
11. 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 27 June 2025 and submitted for decision on
29 October 2025. Taking into account the wording of arts. 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.
12. 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), the Dispute Resolution Chamber is competent to deal with the matter at stake,
which concerns an employment-related dispute with an international dimension between
a French player and a Turkish club.
13. 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
14. 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
15. 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. 6
REF. FPSD-19726
i. Main legal discussion and considerations
16. The Chamber then moved to the substance of the matter, and took note of the fact that
the Player alleged having unilaterally terminated the Contract with just cause due to the
alleged non-payment of certain financial obligations by the Club as per the Contract and in
accordance with art. 14bis of the Regulations.
17. The Chamber also noted that the Club failed to reply to the claim despite being invited to
do so and, therefore, determined that the decision will be made based on the arguments
and evidence on file (cf. art. 21 par. 1 of the Procedural Rules).
18. In this context, the Chamber acknowledged that its task was to determine, based on the
evidence presented, whether the claimed amounts had in fact remained unpaid by the
Respondent and, if so, whether the formal pre-requisites of art. 14bis of the Regulations
had been fulfilled in order to determine whether the termination at issue was justified as
well as the consequences deriving therefrom.
19. Regarding the termination of the Contract, the Chamber recalled that according to art.
14bis of the Regulations, 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 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 obligations.
20. The Chamber noted that in the case at hand, the Player alleged not having received the
salaries corresponding to the months of March, April and May 2025 (i.e., 3 monthly salaries)
and provided written evidence of having put the Club in default on 2 June 2025, i.e., at least
15 days before the unilateral termination of the Contract, on 19 June 2025.
21. In view of the above, the Chamber concluded that the Player had just cause to terminate
the Contract due to having at least 2 outstanding salaries and having provided the
Respondent with at least 15 days’ notice to comply with their default.
22. Regarding the outstanding salaries, the Chamber observed that the Player alleged that EUR
120,000 net arising from the Contract remained outstanding. The Chamber observed
further that the Club did not dispute that the above amounts remained outstanding, as it
failed to reply to the claim.
23. Consequently, and in line with the principle of pacta sunt servanda, the Chamber decided
that that the foregoing amounts were indeed outstanding at the time of termination for
just cause and the Club shall be held liable for the consequences deriving from such
termination.
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REF. FPSD-19726
ii. Consequences
24. Having stated the above, the Chamber turned its attention to the question of the
consequences of such unjustified breach of contract committed by the Respondent.
25. The Chamber observed that the outstanding remuneration at the time of termination,
coupled with the specific requests for relief of the Player, are equivalent to 4 salaries under
the Contract, amounting to EUR 160,000 net. In this respect, the Chamber considered, in
line with its usual practice, that the salary for the month of June 2025 shall be considered
as outstanding remuneration.
26. Therefore, and in accordance once more with the general legal principle of pacta sunt
servanda, the Chamber decided that the Club is liable to pay to the Player the amounts
which were outstanding under the Contract at the moment of the termination, i.e., EUR
160,000 net (i.e., EUR 40,000 times 4).
27. In addition, taking into consideration the Claimant’s request as well as the constant practice
of the Football Tribunal in this regard, the Chamber decided to award the Claimant interest
at the rate of 5% p.a. on the outstanding amounts as follows:
•
•
•
•
5% interest p.a. over the amount of EUR 40,000 net as from 1 April 2025 until
the date of effective payment;
5% interest p.a. over the amount of EUR 40,000 net as from 1 May 2025 until
the date of effective payment;
5% interest p.a. over the amount of EUR 40,000 net as from 1 June 2025 until
the date of effective payment.
5% interest p.a. over the amount of EUR 40,000 net as from 19 June 2025 until
the date of effective payment.
28. Having stated the above, the Chamber turned to the calculation of the amount of
compensation payable by the Respondent 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.
29. 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 such compensation clause was included in the employment contract at
the basis of the matter at stake.
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REF. FPSD-19726
30. 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)).
31. Bearing in mind the foregoing as well as the Player’s claim, 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 EUR 497,500 net (i.e., the residual value of the Contract,
consisting of EUR 7,500 net for the remainder of the 2024/2025 season and EUR 490,000
net for the entirety of the 2025/2026 season) serves as the basis for the determination of
the amount of compensation for breach of contract.
32. 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.
33. Indeed, the Player found employment with the Iraqi club, Newroz Sports Club. In
accordance with the pertinent employment contract, which had a duration from 20 August
2025 until 20 June 2026, the Player was entitled to a total remuneration of USD 330,000
net, or approximately EUR 287,557 net, during the term of the agreement. Therefore, the
Chamber concluded that the Claimant mitigated his damages in the total amount of EUR
287,557 net.
34. Subsequently, the Chamber referred to art. 17 par. 1 lit. ii) of the Regulations, according to
which a player is entitled to an amount corresponding to three monthly salaries as
additional compensation should the termination of the employment contract at stake be
due to overdue payables. In the case at hand, the Chamber confirmed that the contract
termination took place due to said reason i.e., overdue payables by the Club, and therefore
decided that the Player shall receive additional compensation.
35. In this respect, the DRC decided to award the amount of additional compensation of EUR
120,000 net, i.e., three times the monthly remuneration of the Player under the Contract.
36. 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 EUR
329,943 net to the Claimant (i.e., EUR 497,500 net as residual value minus EUR 287,557 net
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REF. FPSD-19726
in mitigation from the new contract plus EUR 120,000 net as additional compensation),
which was to be considered a reasonable and justified amount of compensation for breach
of contract in the present matter.
37. Lastly, taking into consideration the Claimant’s request as well as the constant practice of
the Football Tribunal in this regard, the Chamber decided to award the Claimant interest
on said compensation at the rate of 5% p.a. as of 19 June 2025 until the date of effective
payment.
iii. Consequences of art. 17 par. 4 of the Regulations
38. In continuation, the Chamber focused on the additional consequences of the breach of
contract in question and, in this respect, addressed the question of sporting sanctions
applicable to the Club in accordance with art. 17 par. 4 of the Regulations. The cited
provision stipulates that, in addition to the obligation to pay compensation, sporting
sanctions shall be imposed on any club found to be in breach of contract during the
protected period.
39. In this respect, the Chamber referred to item 7 of the “Definitions” section of the
Regulations, which establishes, inter alia, that the protected period shall last “for three entire
seasons or three years, whichever comes first, following the entry into force of a contract, where
such contract is concluded prior to the 28th birthday of the professional, or two entire seasons
or two years, whichever comes first, following the entry into force of a contract, where such
contract is concluded after the 28th birthday of the professional”.
40. In this respect, the Chamber took note that the Player was born on 6 August 1995 and the
relevant contract with the Club entered into force on 6 February 2025. Furthermore, the
Chamber noted that the Player terminated the Contract with just cause on 19 June 2025.
The breach of contract by the Club had therefore occurred within the protected period.
41. Furthermore, the Chamber noted that the Club had already been held liable for breaching
other players’ contracts in several recent occasions; in particular, in cases FPSD-15193,
FPSD-18380, and FPSD-18753.
42. Consequently, the Chamber decided that, by virtue of art. 17 par. 4 of the Regulations, the
Club shall be sanctioned with a ban from registering any new players, either nationally or
internationally, for two entire and consecutive registration periods.
iv. Compliance with monetary decisions
43. 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
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REF. FPSD-19726
concerned party to pay the relevant amounts of outstanding remuneration and/or
compensation in due time.
44. 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.
45. Notwithstanding the above the DRC wished to remark that, in accordance with art. 24 par.
3 of the Regulations, the aforementioned consequences may be excluded where the
pertinent FIFA deciding body has already imposed a sporting sanction on the same party
on the basis of article 12bis, 17 or 18quater of the Regulations.
46. In this respect, considering that art. 17 par. 4 of the Regulations applies in the matter, the
Chamber established that art. 24 par. 2 of the Regulations shall not apply, insofar as in case
the Club fails to comply with the decision at hand, the application of a further ban from
registering any new players on top of the one already being served by the Club would be
moot and against the spirit of the Regulations, particularly in the enforcement mechanism
established under art. 24 of the Regulations.
47. In view of the above, the DRC decide that, if the aforementioned sum plus interest is not
paid within 30 days of notification of this decision, the present matter shall be submitted,
upon the Player’s request, to the FIFA Disciplinary Committee for its consideration and
formal decision.
48. The Respondent 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.
d. Costs
49. 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.
50. 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.
51. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
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REF. FPSD-19726
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Gaetan Laura, is partially accepted.
2.
The Respondent, MKE Ankaragucu SK, must pay to the Claimant the following amount(s):
- EUR 160,000 net as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount EUR 40,000 net of as from 1 April 2025 until the date
of effective payment;
- 5% interest p.a. over the amount EUR 40,000 net of as from 1 May 2025 until the date of
effective payment;
- 5% interest p.a. over the amount EUR 40,000 net of as from 1 June 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 40,000 net as from 19 June 2025 until the date
of effective payment.
- EUR 329,943 net as compensation for breach of contract plus 5% interest p.a. as from
19 June 2025 until the date of effective payment.
3.
Any further claims of the Claimant are rejected.
4.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
5.
The Respondent shall be banned from registering any new players, either nationally
or internationally, for the two next entire and consecutive registration periods
following the notification of the present decision.
6.
If full payment is not made within 30 days of notification of this decision, the present
matter shall be submitted, upon request of the Claimant, to the FIFA Disciplinary
Committee.
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
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REF. FPSD-19726
pg. 13
REF. FPSD-19726
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
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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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