Labour Disputes
Texto da decisão
REF. FPSD-19977
Decision of the
Dispute Resolution Chamber
passed on 30 October 2025
regarding an employment-related dispute concerning the player Ivana
Trbojevic
COMPOSITION:
Lívia SILVA KÄGI (Brazil & Switzerland), Deputy Chairwoman
Khadija TIMERA (Senegal), Member
Jorge GUTIÉRREZ (Costa Rica), Member
CLAIMANT:
Ivana Trbojevic, Serbia
Represented by Antonis Vogiatzakis
RESPONDENT:
NEES ATROMITOU 2018, Greece
Represented by Paraskevas Atlamazoglou
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REF. FPSD-19977
I. Facts of the case
1.
On 20 June 2024, the Serbian player, Ivana Trbojevic (hereinafter: the Player or the Claimant),
and the Greek club, NEES ATROMITOU 2018 (hereinafter: the Club or the Respondent)
entered into an employment contract (hereinafter: the Contract) valid for “two years”.
2.
In accordance with the Contract, the Club undertook to pay to the Player a monthly
remuneration of EUR 1,200.
3.
On 21 June 2024, a handwritten document was signed by the Club’s President, Mr. Tragos
Anastasios (hereinafter: the Handwritten Document), which read as follows (cited verbatim):
“President Tragos Anastasios
I declare that Ivana Trbojevic will collect bonuses for:
3rd place: 1,500€
2nd place: 3,000€
1st place: 4,500€
The house is covered for the team Nees Atromitou 2018, furnished, and the plane tickets from
Beograd - Athens - Beograd.”
4.
On 1 October 2024, the Club issued a payment receipt confirming the payment of EUR
1,200 in cash to the Player.
5.
On 24 February 2025, the Player sent a message to the Club requesting clarification about
housing arrangements and urgently asked when she would receive her overdue payments
due to lack of money for basic living expenses.
6.
On 4 April 2025, the Club issued a payment receipt confirming the payment of EUR 3,000
in cash to the Player.
7.
On 14 May 2025, the Player requested the payment of her salaries from the Club.
8.
On the same day, the Club replied to the Player, expressing its disappointment regarding
an incident that occurred the previous Saturday night.
9.
On 25 May 2025, the Player sent the following email to the Club (quoted verbatim):
“Good evening Stella, According to the agreement we have, you have to pay us the return
tickets for home. We have found tickets for Monday quite affordable. I will send you the flight
details along with luggage.”
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REF. FPSD-19977
10. On 16 June 2025, the Player put the Club in default of payment of EUR 4,300, granting it 15
days in order to remedy the default.
11. On 2 July 2025, the Player terminated the Contract invoking just cause due to outstanding
salaries.
12. On the same date, i.e., 2 July 2025, the Player entered into an employment contract with
the Hungarian club BSC 1924 Futball FT, valid as from its date of signature until 30 June
2026.
13. According to her new employment contract with BSC 1924 Futball FT, the Player is entitled
to a monthly remuneration of HUF 400,000.
II. Proceedings before FIFA
14. On 17 July 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
15. In her claim, the Player argued that, although the Contract described her status as an
amateur, she qualified as a professional under the Regulations on the Status and Transfer
of Players (hereinafter: the Regulations).
16. The Player further argued that the Club failed to fulfil its financial obligations and that she
had just cause to terminate the Contract.
17. The Player submitted that, as of the date of the default notice, the Club failed to pay her
EUR 4,300 corresponding to the partial salary for February 2025 and the full monthly
salaries from March to May 2025.
18. The Player further claimed to be entitled to the amount corresponding to the value of the
ticket for the Athens-Belgrade flight, in accordance with the Handwritten Document.
19. The Player’s requests for relief were the following:
“In light of the abovementioned, the Player hereby requests the Dispute Resolution Chamber
of the FIFA Football Tribunal to:
- Uphold the present claim;
- Determine that the player Ivana Trbojevic terminated the Employment Agreement with just
cause;
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REF. FPSD-19977
- Order the football club “Nees Atromitou 2018” to pay to the player Ivana Trbojevic the total
net amount of five thousand five hundred euro (5,500€) against outstanding salaries under
the Employment Agreement, with the applicable interest, at the rate of 5% p.a., starting
accrued as of the next day since each respective sum fell due until the date of effective
payment;
- Order the football club “Nees Atromitou 2018” to pay to the player Ivana Trbojevic the value
of the outstanding air – ticket from Athens to Beograd, as per the terms of the Annex, at an
amount to be determined by the FIFA Travel;
- Order the football club “Nees Atromitou 2018” to pay to the player Ivana Trbojevic the total
net amount of five thousand eight hundred euro (5,800€) as compensation for the unilateral
termination of the Employment Agreement with just cause, with the applicable interest, at the
rate of 5% p.a., starting accrued as of 3 July 2025 until the date of effective payment;
- Impose the appropriate sporting sanctions on “Nees Atromitou 2018”, pursuant to the
applicable provisions of the FIFA RSTP;
- Order “Nees Atromitou 2018” to bear the entire procedural costs of the present proceedings,
if any;”
b. Reply of the Club
20. In its reply, the Club alleged that no professional relationship existed between the parties,
as both the Club and the Player are amateurs.
21. The Club further asserted that the amount indicated in the Contract was intended to cover
the Player’s accommodation, food, subsistence and care-related expenses in Greece.
22. The Club submitted that, on 23 May 2025, the Player announced in a message to the team
that she was leaving Greece permanently, which she subsequently did on 26 May 2025.
23. The Club asserted that it did not provide her with flight tickets because it was not
contractually agreed.
24. In addition, the Club claimed that, in early April 2025, it paid the Player a total of EUR 3,000,
covering her salaries for April and May 2025, along with an outstanding balance of EUR 600.
25. The Club asserted that, had there been any outstanding debts owed to the Player, she
would have claimed the full amount in her email dated 25 May 2025, rather than solely
requesting reimbursement for the flight tickets.
26. The Club’s requests for relief were the following:
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REF. FPSD-19977
“Therefore, as proven by the above, our club owes nothing to the footballer Mrs. Ivana
Trbojevic, and her complaint to your Committee is not sincere. For this reason, she did not
turn to HFF's financial dispute resolution bodies. For the same reason, in her complaint to
you, she subsequently does not specifically state what amounts she has received from our
club and the dates she has received them (either herself or others on her behalf) since the
start of our cooperation to date.
Finally, we consider that this action was motivated by another Greek teammate of hers, who
asked for a transfer to another football club, and our team did not consent.”
c. Replica of the Player
27. In her replica, the Player maintained her position and reiterated that she is a professional
within the meaning of the Regulations.
28. In addition, the Player rejected all allegations made by the Club regarding the financial
aspects of their employment relationship.
29. The Player asserted that she had never been absent without justification and that she never
declared that she had decided to leave Greece permanently. In this respect, she asserted
that, since the last game of the 2024/25 season on 18 May 2025, she had the right to leave
Greece during the off-season.
30. The Player alleged that, in accordance Handwritten Document, the Club was contractually
obliged to provide her with flight tickets.
31. As per the payment of EUR 3,000 made on 4 April 2025, the Player asserted that it
corresponded to the partial salary for November 2024 (EUR 100), the salaries for December
2024 (EUR 1,200) and January 2025 (EUR 1,200), and the partial salary for February 2025
(EUR 500).
32. In light of the above, the Player maintained her initial requests for relief.
d. Duplica of the Club
33. In its duplica, the Club rejected the Player’s allegations and challenged the admissibility of
her claim, arguing that the dispute involves and amateur player and an amateur club.
34. In light of the above, the Club maintained its initial position.
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REF. FPSD-19977
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
35. 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 17 July 2025 and submitted for decision on
30 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.
36. 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 (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 Serbian player and a Greek club.
37. For the sake of completeness, the Chamber found that the Club challenged the
admissibility of the claim on the grounds that both the Club and the Player are of amateur
status. In this regard, the Chamber emphasized that the status of the Player or the Club is
not determinative for establishing the Football Tribunal’s jurisdiction or the admissibility of
the claim. Rather, the Chamber found that the Player’s status will be assessed in the context
of the substantive examination of the case.
38. 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
39. 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
40. 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-19977
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
41. The Chamber then moved to the substance of the matter, and took note of the fact that it
is a claim of a player against a club for breach of contract.
42. In particular, the Chamber observed that the Player maintained to have terminated the
Contract with just cause due to outstanding salaries.
43. The Chamber also observed that the Club maintained that the claim should be rejected
since both the Player and the Club have amateur status and that it fulfilled all of its financial
obligations to the Player until May 2025, when she unilaterally decided to leave the Club.
44. In this context, the Chamber acknowledged that its task was to analyse the status of the
Player and whether she had a just cause to unilaterally terminate the Contract and, if so,
to determine the legal consequences thereof.
45. With respect to the status of the Player, the Chamber referred to art. 2 par. 2 of the
Regulations which stipulates that a professional is “a player who has a written contract with
a club and is paid more for his footballing activity than the expenses he effectively incurs. All
other players are considered to be amateurs”. The Chamber also referred to its wellestablished jurisprudence, according to which the financial threshold arising out of the art.
2 par. 2 criteria is relatively low, as it does not require a player to make a living from their
footballing activity in order to qualify as a professional.
46. In this sense, and based on the documentation on file, the Chamber held that, in
accordance with its well-established jurisprudence, a monthly amount of EUR 1,200
established in the Contract, does in fact constitute a higher amount than the expenses the
Player effectively incurred for playing football.
47. Consequently, the Chamber deemed that the Player held professional status.
48. Having established the above, the Chamber acknowledged that its task was to determine,
based on the evidence presented on file, 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.
49. 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,
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REF. FPSD-19977
provided that she 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).
50. The Chamber noted that the Player claims not having received her remuneration
corresponding to the partial salary for February 2025 and the full monthly salaries from
March to May 2025.
51. Furthermore, the Chamber noted that the Player has provided written evidence of having
put the Club in default on 16 June 2025, i.e., at least 15 days before unilaterally terminating
the Contract on 2 July 2025.
52. At this point, the Chamber recalled that the Club bore the burden of proving that it indeed
complied with the financial terms of the Contract.
53. In this respect, the Chamber found that the Club has only demonstrated having paid the
Player a total of EUR 4,200, i.e., EUR 1,200 on 1 October 2024 and EUR 3,000 on 4 April 2025.
54. In light of the above, the Chamber found that, while it is acknowledged that additional
payments may have been made but are not documented on file (as the Player claims that
only EUR 4,300 remains outstanding), the Club has nonetheless failed to provide any
evidence to prove full compliance with its contractual financial obligations.
55. In view of the above, the Chamber concluded that the Player had just cause to terminate
the Contract in accordance with art. 14bis of the Regulations.
56. For the sake of completeness, the Chamber rejected the Club’s allegation that the Player
decided to leave Greece in May 2025 with no intention of returning, due to lack of
substantiation. Specifically, the Chamber considered that the email sent in May 2025,
requesting flight tickets to the Club, was intended for the Player to return home for
vacation, and there is no evidence proving that she had no intention of returning.
ii. Consequences
57. 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.
58. The Chamber observed that the outstanding remuneration at the time of termination,
coupled with the specific requests for relief of the Player, is equivalent to one partial salary
and four full salaries under the Contract, amounting to EUR 5,500.
59. In addition, the Chamber also took note that the Player requested the payment of the value
of the flight tickets from Athens to Belgrade under the Handwritten Document. In this
respect, the Chamber observed that it is undisputed that the Player travelled to Belgrade
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REF. FPSD-19977
in May 2025 for vacation. However, the Chamber further noted that the Player failed to
provide any evidence regarding the cost incurred for the flight tickets.
60. Accordingly, taking into account that the expense was already incurred but no evidence of
such expenditure was provided for reimbursement, the Chamber decided to reject the
Player’s request in this regard.
61. 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 to the Player the amounts which were
outstanding under the Contract at the moment of its termination, i.e., EUR 5,500 (i.e., four
times EUR 1,200 and EUR 700).
62. 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 amounts as from the corresponding due dates
until the date of effective payment.
63. 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.
64. 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.
65. As a consequence, 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 a player by a club shall be equal to the residual value
of the contract that was prematurely terminated, unless this player signed a new contract
following the termination of his previous contract (cf., art. 17 par. 1 lit. i) of the Regulations).
66. 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 EUR 14,400 (i.e., 12 times EUR 1,200) serves as the basis for
the determination of the amount of compensation for breach of contract.
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67. In this respect, the Chamber wished to emphasise that, although the Contract signed on
20 June 2024 stipulated a “two years” term, the Player indicated that its end date was 30
June 2026, and this was not disputed by the Club. Consequently, the Chamber determined
that the Contract’s original end date was specifically 30 June 2026.
68. 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 she 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 general obligation to mitigate
his damages.
69. Indeed, the Player found employment with the Hungarian club BSC 1924 Futball FT. In
accordance with the pertinent employment contract, the Player was entitled to HUF
400,000 per month, which the Chamber found to be equivalent to EUR 1,001.17 per month.
Therefore, the Chamber concluded that the Player mitigated her damages in the total
amount of EUR 12,014.04, that is, 12 times EUR 1,001.17.
70. 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.
71. In this respect, the DRC decided to award the amount of additional compensation of EUR
3,600, i.e., three times the monthly remuneration of the Player.
72. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Chamber found that the Club should in principle pay the amount
of EUR 5,985.96 to the Player (i.e., EUR 14,400 minus EUR 12,014.04 plus EUR 3,600), which
was to be considered a reasonable and justified amount of compensation for breach of
contract in the present matter.
73. However, the Chamber noted that the Player requested to be compensated in the amount
of EUR 5,800.
74. Consequently, taking into consideration the Player’s request and the principle of ne ultra
petita, the Chamber decided to award the Player the amount of EUR 5,800 for
compensation for breach of contract in the present matter.
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75. Lastly, 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 3 July 2025 until the date of effective payment.
iii. Compliance with monetary decisions
76. 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.
77. 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.
78. 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.
79. 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.
80. 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
81. 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.
82. 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.
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83. 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, Ivana Trbojevic, is partially accepted.
2.
The Respondent, NEES ATROMITOU 2018, must pay to the Claimant the following
amount(s):
- EUR 5,500 as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of EUR 700 as from 1 March 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 1,200 as from 1 April 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 1,200 as from 1 May 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 1,200 as from 1 June 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 1,200 as from 1 July 2025 until the date of
effective payment.
- EUR 5,800 as compensation for breach of contract plus 5% interest p.a. as from 3 July
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.
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.
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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
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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:
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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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