Labour Disputes
Texto da decisão
REF. FPSD-19843
Decision of the
Dispute Resolution Chamber
passed on 15 October 2025
regarding an employment-related dispute concerning the Player Luciano
Gaston Squadrone
BY:
Michele COLUCCI (Italy)
CLAIMANT:
Luciano Gaston Squadrone, Italy
Represented by Jesus Garcia Arco
RESPONDENT:
Beroe, Bulgaria
Represented by Danilo Monti
pg. 2
REF. FPSD-19843
I. Facts of the case
1.
On 1 July 2023, the Italian player, Luciano Gaston Squadrone (hereinafter: the Player or the
Claimant) and the Bulgarian club Beroe (hereinafter: the Club or the Respondent) entered
into an employment contract (hereinafter: the Contract) valid until 10 June 2025.
2.
Clause 4.1.1 of the Contract read as follows:
“I. From July 2023 to June 2024: The Club shall pay the Player a monthly salary equal to 5,000.00
BGN (Five Thousand Bulgarian Leva) net, payable by the 25° of each subsequent month for
previous one.
II. From July 2024 to June 2025: The Club shall pay the Player a monthly salary equal to 6,000.00
BGN (Six Thousand Bulgarian Leva) net, payable by the 25° of each subsequent month for
previous one.”
3.
Clause 4.1.3 of the Contract read as follows:
“4.1.3 The Player will be entitled to an additional bonus for success, which is as follows:
I. If the Player effectively plays at least 75% (Seventy Five Percent) of the minutes disputed by the
first team of the Club in official matches of the football season, he will be entitled to 10,000.00
BGN (Ten Thousand Bulgarian Leva). The minutes that the Player spends on the bench will not
be taken into account. This bonus will be paid, if due, within 90 days after the termination of the
football season.”
4.
Clause 4.1.11 of the Contract indicated that the Player would be entitled to BGN 500 per
month as housing allowance.
5.
On 30 September 2024, the Club informed the Player that it had imposed a fine of BGN
1,384.62 due to aggressive behavior towards the Club’s coach. The Club further referred to
art. 7.3 of the Contract and stressed that the Player had 5 days to appeal the decision.
6.
On 25 May 2025, the Player put the Club in default and requested within 15 days the
payment of BGN 42,500 corresponding to the salaries between December 2024 and April
2025.
7.
On 30 May 2025, the Club responded to the Player, disputing the assertions made in the
Player’s letter and stating that “according [the Club]’s accounting records (which include the
fine imposed to you as per your disciplinary violation sanctioned on 30 September 2024
amounting to BGN 1,384.62) the Club has already paid the salary of December 2024, with the
amount of BGN 24,365.38 remaining unpaid, pertaining to the salaries of January (partially),
February, March and April 2025.”.
8.
On 9 June 2025, the Player sent a termination to the Club, mentioning that the salaries
remained unpaid.
pg. 3
REF. FPSD-19843
II. Proceedings before FIFA
9.
On 9 July 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
10. The Player lodged a claim for outstanding remuneration. The Player mentioned that the
Club failed to pay the following amounts:
-
BGN 42,000 as salaries between December 2024 and June 2025;
BNG 10,000 as bonus in accordance with clause 4.1.3 of the Contract; and
BGN 3,000 as housing allowance between January 2025 and June 2025.
11. The Player requested the following relief:
“SOLICITO A LA CÁMARA DE RESOLUCIÓN DE DISPUTAS DE LA FIFA que teniendo por presentado
este escrito con su copia y los documentos adjuntos con las suyas se sirva admitirlos y
teniendome por parte en la representación indicada, mandando que se entiendan conmigo
ulteriores diligencias, tenga por deducida DEMANDA EN RECLAMACIÓN DE CANTIDAD, por el
impago de salarios, y bonus, contra el BEROE PROFESSIONAL FOOTBALL CLUB-STARA ZAGORA,
dándole traslado de la demanda para que conteste y, en caso de no alcanzar acuerdo, se reciba
el pleito a prueba y tras los trámites legales se dicte Resolución por la que estimando la
demanda, se declare el incumplimiento del demandado y el derecho de mi mandante a exigir
EL ABONO DE LOS SALARIOS ADEUDADOS Y CONDENANDO A LA DEMANDADA A LA ENTREGA DE
DICHA CANTIDAD QUE HACE UN MONTO TOTAL DE CINCUENTA Y CINCO MIL BGN (55.000 BGN)
y ello con la imposición de las sanciones que le fueran de aplicación en caso de no acatar dicha
resolución.”
Freely translated to English:
“I REQUEST THE FIFA DISPUTE RESOLUTION CHAMBER to consider this submission, along with its
copy and the attached documents, to admit them, and to recognize me as a party in the
indicated representation. I request that all further proceedings be conducted with me, and that
a CLAIM FOR PAYMENT be considered as filed, due to the non-payment of salaries and bonuses,
against BEROE PROFESSIONAL FOOTBALL CLUB – STARA ZAGORA. I request that the claim be
forwarded to the respondent for a response and, if no agreement is reached, that the case
proceed to the evidentiary stage and, following the legal procedures, a decision be issued in
which the claim is upheld, the breach by the respondent is declared, and the right of my client
to demand THE PAYMENT OF THE OUTSTANDING SALARIES is recognized, ordering the
respondent to pay said amount, which totals FIFTY-FIVE THOUSAND BGN (BGN 55,000), along
with the imposition of any applicable sanctions in the event of non-compliance with said
pg. 4
REF. FPSD-19843
decision.”
b. Reply of the Respondent
12. On 22 August 2025, the Club rejected the Player’s claim.
13. The Club mentioned that for financial reasons it was not able to timely pay the Player’s
salary. However, the amount requested by the Player is not accurate. The Club stressed
that a fine was imposed on the Player of BGN 1,384.62 on 30 September 2024 due to the
Player misconduct; and that no bonuses were achieved nor proved to have been achieved
by the Player.
14. The Club further mentioned that according to its financial records, “the payments made by
the Club to the Player along the employment relationship (a total of BGN 105,250.00 […]), the
Club owes the Player an amount of BGN 33,031.38 (hereinafter the “Debt”).”
15. Finally, the Club stressed that it “is experiencing financials and economic problems which
impede the Club to comply in a timely manner with its obligations. However, as a demonstration
of good faith, PFC Beroe offers the Player to pay the Debt in Three (3) instalments“.
c. Replica of the Claimant
16. On 31 August 2024, the Player stated that the Club had acknowledged its outstanding debt
to the Player in the amount of BGN 33,031.38. Furthermore, the Player confirmed
acceptance of the fine deduction; however, he asserted his entitlement to the participation
bonus for each season (BGN 10,000 per season), as the contractual condition had been
met (i.e., participation in at least 75% of the matches).
17. The Player amended his request for relief as follows:
“SOLICITO A LA CÁMARA DE RESOLUCIÓN DE DISPUTAS DE LA FIFA que teniendo por presentado
este escrito con sus copias y los documentos adjuntos se sirva admitirlos y acuerde el abono de
los salarios adeudados al jugador por importe admitido por el Club de 33.031,28 BGN, así como
la cantidad de VEINTE MIL BGN (20.000 BGN) por haber disputado más del 75% de los partidos
correspondientes a las temporadas 23/24 y 24/25 (10.000 BGN temporada 23/24 y 10.000 BGN
temporada 24/25), y en consecuencia, se dicte Resolución por la que estimando la demanda, se
declare el incumplimiento del demandado y el derecho de mi mandante a exigir EL ABONO DE
LOS SALARIOS Y PRIMAS ADEUDADOS Y CONDENANDO A LA DEMANDADA A LA ENTREGA DE
DICHA CANTIDAD QUE HACE UN MONTO TOTAL DE CINCUENTA Y TRES MIL TREINTA Y UN CON
TREINTA Y OCHO BGN (53.031,38 BGN) y ello con la imposición de las sanciones que le fueran
de aplicación en caso de no acatar dicha resolución.”
Freely translated to English
pg. 5
REF. FPSD-19843
“I REQUEST THE FIFA DISPUTE RESOLUTION CHAMBER to consider this submission, along with its
copies and attached documents, as duly presented, and to admit them. I further request that it
orders the payment of the outstanding salaries owed to the player in the amount acknowledged
by the Club of BGN 33,031.28, as well as the amount of TWENTY THOUSAND BGN (BGN 20,000)
for having participated in more than 75% of the matches corresponding to the 2023/24 and
2024/25 seasons (BGN 10,000 for the 2023/24 season and BGN 10,000 for the 2024/25 season).
Consequently, I request that a decision be issued upholding the claim, declaring the
respondent's breach of contract and recognizing my client’s right to demand THE PAYMENT OF
THE OUTSTANDING SALARIES AND BONUSES, and condemning the respondent to pay said
amount, which totals FIFTY-THREE THOUSAND THIRTY-ONE AND THIRTY-EIGHT BGN (BGN
53,031.38), along with the imposition of applicable sanctions should the respondent fail to
comply with said decision.”
d. Duplica of the Respondent
18. On 24 September 2024, the Club contended that the Player’s reply exceeded the scope of
FIFA’s request by introducing new claims that should be dismissed. Specifically, the Club
argued that the Player improperly added new demands and evidence -particularly
concerning bonuses- that were not included in the original claim. The Club maintained that
FIFA had only authorized the Player to comment on the payment records and the proposed
payment plan, not to amend or expand the initial claim.
19. The Club contested the Player’s entitlement to bonuses linked to participation in more than
75% of matches during the 2023/24 and 2024/25 seasons. It argued that the bonus for the
2023/24 season was not included in the original claim and is therefore time-barred, while
the evidence submitted for the 2024/25 season, based on Transfermarkt data, is unreliable
and lacks official status. The Club further emphasized that, pursuant to FIFA’s procedural
rules, the burden of proof rests with the Claimant, and such evidence should have been
provided with the initial claim rather than introduced in a subsequent reply.
20. In conclusion, the Club requested that this attempt to remedy omissions in the original
claim, presented by the Claimant under a replica, be entirely rejected, as it contains
untimely and irrelevant statements and requests, and includes evidence submitted late
and lacking credibility.
21. Notwithstanding its objections, the Club acknowledged certain undisputed facts. The
Player confirmed having received BGN 105,250 during the term of employment, accepted
that a fine of BGN 1,384.62 was duly imposed, and agreed that the outstanding salary,
inclusive of the housing allowance, amounts to BGN 33,031.38.
pg. 6
REF. FPSD-19843
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
23. 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 9 July 2025 and submitted for
decision on 25 September 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.
24. 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) (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
an Italian player and a Bulgarian club.
25. 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 July 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Admissibility
26. The Single Judge observed that the Club contested the admissibility of the Player’s new
requests and additional evidence submitted in the replica, arguing that such requests were
precluded or time barred.
27. In this respect, the Single Judge recalled the following provisions of the Procedural Rules:
“Article 11: Time limits
4. A time limit was deemed to have been complied with if the action required or requested had
been completed by the latest on the last day of the time limit at the location of the party’s
domicile or, if the party was represented, at the domicile of its main legal representative.
Submissions and evidence filed outside the relevant time limit were to be disregarded.
[…]
Article 22: Second round of submissions
The FIFA general secretariat decided, where necessary, whether there would be a second round
of submissions.
Article 23: Closure of submission phase
pg. 7
REF. FPSD-19843
The FIFA general secretariat notified the parties of the closure of the submission phase of the
procedure. After such notification, the parties could no longer supplement or amend their
submissions or requests for relief or produce new evidence.”
28. Moreover, the Single Judge recalled art. 23 par. 3 of the Regulations, according to which,
the Football Tribunal shall not hear any case subject to these regulations if more than two
years have elapsed since the event giving rise to the dispute.
29. In view of the foregoing, the Single Judge concluded that:
(i) pursuant to clause 4.1.3 of the Contract, and subject to the relevant conditions being
fulfilled, the bonus for the 2023/2024 season is in principle due as of 1 August 2024, while
the bonus for the 2024/2025 season is in principle due as of 31 July 2025. Accordingly, both
claims were lodged within the two-year limitation period following the events giving rise to
the disputes;
(ii) the Claimant’s amendments were submitted during the second round of submissions,
i.e., within the time limit granted by the FIFA General Secretariat; and
(iii) the Club was afforded the opportunity to comment on the Claimant’s replica in its
duplica.
30. Accordingly, the Single Judge determined that the Claimant’s additional requests and
evidence submitted in the replica are admissible.
c. Burden of proof
31. 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).
d. Merits of the dispute
32. 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.
pg. 8
REF. FPSD-19843
i. Main legal discussion and considerations
33. The Single Judge then moved to the substance of the matter, and noted that the dispute
concerned a claim lodged by the Claimant against the Respondent regarding overdue
payables allegedly arising from the Contract.
34. In this regard, the Single Judge noted that, according to the Claimant, the Respondent had
failed to pay the amount of BGN 33,031.28 as salaries and BGN 20,000 as bonuses.
Conversely, the Respondent acknowledged that only BGN 33,031.38 remained
outstanding.
35. The Single Judge further observed that, although the Contract was terminated one day
prior to its scheduled expiry date, neither party raised any dispute regarding the Player’s
entitlement to salary payments up to 10 June 2025.
36. In light of the above, the Single Judge emphasized that, given the undisputed fact that the
Club failed to pay the Player’s remuneration in the amount of BGN 33,031.38, the Player
was entitled to such amount in accordance with the general legal principle of pacta sunt
servanda.
37. The Single Judge also acknowledged that the only point disputed between the parties
concerns the Player’s entitlement to participation bonuses for each season.
38. In this respect, the Single Judge recalled the wording of clause 4.1.3 of the Contract, which
provides as follows:
“If the Player effectively plays at least 75% (Seventy Five Percent) of the minutes disputed by
the first team of the Club in official matches of the football season, he will be entitled to
10,000.00 BGN (Ten Thousand Bulgarian Leva). The minutes that the Player spends on the
bench will not be taken into account. This bonus will be paid, if due, within 90 days after
the termination of the football season.” (emphasis added)
39. The Single Judge observed that the Club contested the evidence submitted by the Player,
alleging that the documentation originated from unreliable and unofficial sources.
However, the Club failed to provide any counter-evidence, such as the official data it
referred to, that would contradict the Player’s submissions. In this regard, given that the
Club challenged the validity of the Player’s documentation, the burden of proof rested with
the Club to demonstrate that the results reflected therein were inaccurate. In the absence
of such proof, the Single Judge decided to take into consideration the evidence provided
by the Player.
40. In view of the above considerations, the Single Judge analyzed the evidence provided and
concluded that the Player met the 75% match participation criterion for both seasons.
Based on the evidence submitted, the Player participated in 75.95% of the matches during
pg. 9
REF. FPSD-19843
the 2023/2024 season and 80% during the 2024/2025 season. Therefore, the Single Judge
held that the Player is entitled to BGN 20,000 as participation bonuses.
41. Having stated all the above, and in accordance with the general legal principle of pacta sunt
servanda, the Single Judge decided to award the Claimant BGN 53,031.38.
42. Moreover, the Single Judge observed that the Claimant did not request interests of 5% p.a.
on the requested amounts, therefore, he did not grant it in accordance with the principle
ne ultra petita.
43. Finally, and for the sake of completeness, the Single Judge noted that a termination notice
referring to art.14bis of the Regulations was filed in the case file. However, neither party
submitted any claims or analysis regarding the alleged breach. Therefore, the Single Judge
stressed that the present case concerned solely the issue of outstanding remuneration,
with no compensation being requested. Accordingly, no assessment of just cause was
conducted.
ii. Compliance with monetary decisions
44. 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
concerned party to pay the relevant amounts of outstanding remuneration and/or
compensation in due time.
45. 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.
46. 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.
47. 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.
pg. 10
REF. FPSD-19843
48. 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.
e. Costs
49. 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.
50. 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.
51. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 11
REF. FPSD-19843
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Luciano Gaston Squadrone, is partially accepted.
2.
The Respondent, Beroe , must pay to the Claimant the following amount(s):
- BGN 53,031.38 as outstanding remuneration.
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.
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.
6.
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.
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 12
REF. FPSD-19843
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
pg. 13