Labour Disputes
Texto da decisão
REF. FPSD-19980
Decision of the
Dispute Resolution Chamber
passed on 22 January 2026
regarding an employment-related dispute concerning
the player Ioannis Kiakos
COMPOSITION:
Frans DE WEGER (The Netherlands), Chairperson
Johan VAN GAALEN (South Africa), Member
Calum BEATTIE (Scotland), Member
CLAIMANT / COUNTER-RESPONDENT:
Ioannis Kiakos, Greece
Represented by Alkis Papantoniou
RESPONDENT / COUNTERCLAIMANT:
Towarzystwo Sportowe Wisla Krakow SA, Poland
pg. 2
REF. FPSD-19980
I. Facts of the case
1.
On 30 June 2024, the Greek player Ioannis Kiakos (hereinafter: the Player or the Claimant /
Counter-Respondent) and the Polish club Towarzystwo Sportowe Wisla Krakow SA
(hereinafter: the Club or the Respondent / Counterclaimant) entered into an employment
contract (hereinafter: the Contract) valid as from 1 July 2024 until 30 June 2025.
2.
Clauses 3.2 and 3.5 of the Contract established:
“2. In case of doubt, it shall be deemed that the Parties intended to conclude the Contract
for the period of 1 seasons 2024/2025, subject to sec. 4-6 below, if due to a decision of
entities organizing football competitions in Poland, including PZPN, Exstraklasa S.A.,
Pierwsza Liga Pilkarska (hereinafter referred to as the ’PLP‘) or Malopolski Zwizek Pilki
Nonej (hereinafter referred to as the ’MZPN‘) and UEFA or FIFA or as a result of a decision
of state authorities, the date of the beginning and/or the end of the 2024/2025 season
change, the Parties undertake to enter into negotiations in order to appropriately adapt
the term of this Contract.”
[…]
“5. The Contract shall be extended for a fixed period of time covering 1 season, i.e. the
2025/2026 season, i.e. from the 1st of July 2025 to the 30th of June 2026, if the Players
plays at least 50% (say: fifty percent) of the minutes played by the First Team during the
term of Contract within league competitions of the 2024/2025 season, including any
possible play-off matches of the First Team, if applicable.”
3.
Clause 4.1 of the Contract provided as follows:
“For the proper performance of the Contract, the Player is entitled to a basic
remuneration in the amount:
a. in the 2024/2025 season: 7 500,00 EUR (say: seven thousand five hundred euro 00/100)
+ VAT, if due, per month, i.e. a total 90 000,00 EUR (say: ninety thousand euro 00/100) +
VAT, if due,
b. in the 2025/2026 season, in the event of an extension of the Contract in accordance
with § 3 sec. 5 above: i. either 9 000,00 EUR (say: nine thousand euro 00/100) + VAT, if
due, per month; a total of 108 000,00 EUR (say: one hundred and eight thousand euro
00/100) + VAT, if due - if the First Team plays in 1 liga, i.e. the second highest league in
Poland, ii. or 10 000,00 EUR (say: ten thousand euro 00/100) + VAT, if due, per month; a
total of 120 000,00 EUR (say: one hundred twenty thousand euro 00/100) + VAT, if due if the First Team plays in Ekstraklasa, i.e. the highest professional league in Poland.”
pg. 3
REF. FPSD-19980
4.
Clauses 4.3 to 4.5 of the Contract stipulated:
“3. The Player shall be obliged to calculate and remit taxes and contributions to social
and health Insurance himself, in accordance with the applicable law.
4. Payment of remuneration referred to in this paragraph shall be done in arrears by the
10th day of the next calendar month, on the basis of a VAT invoice correctly issued and
delivered to the Club by the Player, by a bank transfer to the bank account specified In
such invoice.
5. The Parties agree to issue VAT invoices without signature and in electronic form and to
send them to the e-mail address for delivery of invoices indicated by the Club: [email protected].”
5.
Clause 5 of the Contract included the following:
“5 ADDITIONAL REMUNERATION
1. If, during the term of the Contract, the First Team is promoted to the Ekstraklasa, the
Player shall receive a one-off additional remuneration in the amount of 6 000,00 EUR
(say: six thousand euro 00/100) + VAT, if the due.
2. The additional remuneration set out in the preceding section shall be payable provided
that the Player has participated in the league matches (including play-off) played by the
First Team during the Contract’s term and leading to the achievement in not less than
70% (say: seventy per- cent) of the time of those matches. In any other case, the amount
of the award will be calculated in proportion to the league matches played and the time
spent on the pitch by the Player in those matches.
3. During the term of this Contract, the Player shall be entitled to an individual match
bonus in the amount specified in the table below + VAT, if due, for each goal and/or assist
scored by the Player for the First Team in a league match (including play-off):
Ekstraklasa / 1 liga
360,00 EUR (say: three hundred sixty euro 00/100)
4. During the term of this Contract, the Player shall be entitled to an individual victory
bonus in the amount specified in the table below + VAT, if due, for each league match
won by the Team, provided that the Player has played at least 1 (say: one) minute of such
match:
Ekstraklasa / 1 liga
360,00 EUR (say: three hundred sixty euro 00/100)
5. Subject to sec. 6-7 below, if during the term of the Contract the First Team:
pg. 4
REF. FPSD-19980
a. is ranked in the professional league of Ekstraklasa at the end of the season at the place
giving the right to play in the UEFA European cups qualifiers, the Player shall be entitled
to the one-off additional remuneration In the amount of 6 000,00 EUR (say: six thousand
eight euro 00/100) + VAT, if the due,
b. wins the Polish Cup, the Player shall be entitled to the one-off additional remuneration
in the amount of 8 900,00 EUR (say: eight thousand nine hundred euro 00/100) + VAT, if
due,
c. becomes the Champion of Poland, the Player shall be entitled to the one-off additional
remuneration in the amount of 17 700,00 EUR (say: seventeen thousand seven hundred
euro 00/100) + VAT, if due.
6. The additional remuneration referred to in sec. 5 let. a., b. or c. above shall only be
due if the Player participates in at least 70% (say: seventy percent) of the match time of
the relevant matches played by the First Team and leading to given achievement. In any
other case, the amount of the award shall be calculated in proportion to the matches
played by the First Team in the relevant competitions leading to given achievement and
the time spent on the field by the Player in those matches.
7. If the Player receives the additional remuneration specified in sec. 5 let. c. above, the
additional remuneration specified in sec. 5 let. a. above shall not be payable to the Player.
8. The calculations specified in sec. 1-6 above and §3 sec. 5 above shall not take into
account the additional time of the match, i.e. the Parties assume that each match lasts
90 minutes and that extra or added time shall not be awarded in any way.
9. For the calculation of goals and assists indicated in sec. 3 above, if due, only goals and
assists confirmed by the match organizer in the official match protocol shall be taken
into account.
10. For the conclusion of the Conclusion of the Contract, the Player shall be entitled to a
one-time additional remuneration in the amount of 5 000,00 EUR (say: five thousand
euro 00/100) + VAT, if due, payable by 31st of July 2024.
11. The Player shall be entitled to a one-time additional remuneration in the amount of
5 000,00 EUR (say: five thousand Euros 00/100) + VAT, if due, in the event that the Player
plays at least 60% (say: sixty percent) of the minutes played by the First Team during the
term of the Contract during the league competitions (including play-off) of the 2024/2025
season.
12. The additional remuneration referred to in sec. 1-6 above and sec. 11 above, if due,
shall be paid provided that the Player remains a player of the Club on the 30th of June
of the relevant season on the basis of a valid and unsuspended Contract (with the
pg. 5
REF. FPSD-19980
condition for the 2023/2024 season that the Player remains a player of the Club under a
valid and unsuspended Contract on the 4th of June 2024) and shall be payable within
fifteen days from the day of the end of the season during which the Player obtained an
achievement to be rewarded, on the basis of the invoices correctly issued and delivered
to the Club.
13. The additional remuneration specified in sec. 1-6 above and sec. 11 above shall be
due provided that after the end of the season in which the achievement is earned the
First Team is not relegated from the league level at which it played in the season of the
achievement.
14. The Parties mutually agree, that for the payment of the remuneration specified in §45 of the Contract, the exchange rate to be applied is the average NBP (National Bank of
Poland) rate of EUR for the last day of the month for which the remuneration is due, i.e.
the remuneration shall be paid in PLN.”
6.
Clause 7.1 of the Contract set forth:
“7 OBLIGATIONS OF THE PLAYER
1. By virtue of the Contract, Player undertakes to:
a. perform all contractual obligations specified herein I throughout the term of the
Contract,
b. represent the Club during national and international football competitions at the
highest possible level and comply with the rules of playing football,
c. inform the Club with a minimum 7-day advance every time the Player intends to leave
the territory of Republic of Poland,
d. actively participate in the training process and in sports rivalry, in accordance with the
instructions of the Club's coaching staff, including timely attendance to all exercises and
activities of the training process and sports rivalry,
e. conduct a healthy lifestyle and maintain fitness at the highest possible level. The Player
is exclusively responsible for the result of his physical form fluctuations,
f. undergo medical and physical fitness tests pursuant to the Club’s indications and use
only medical drugs and supplements prescribed by or agreed with the Club’s doctor,
g. endeavour within the sports competition process to maximize his psychophysical
abilities and to achieve the best sporting results of the team with regard to his own
assessment and the Club’s coaching staff’s recommendations taken into account,
pg. 6
REF. FPSD-19980
h. immediately inform the Club about any accident or illness and deliver appropriate
medical certificate to the Club as well as comply with the Club’s medical staff’s
instructions related to the Player’s inability to perform his contractual obligations. In the
event of the Player’s injury during the term of the Contract, the Player is obliged to apply
treatment method chosen by the Club’s medical staff, whereas the Club shall be obliged
to allow the Player to obtain, at the Player’s expense, an independent medical opinion in
significant circumstances concerning the Player’s health and when the Player reasonably
disputes the medical opinion provided by the Club. The opinion referred to in the
preceding sentence should be provided by a medical specialist in the relevant field of
medicine. In the event of a discrepancy between the medical opinions provided by the
Club and the Player, the Player and the Club shall agree in good faith on the terms and
conditions for obtaining a third, binding medical opinion from a specialist who is a
recognised expert in the relevant field of medical science. In the event the Player applies
a treatment method different than indicated by the Club but accepted by the Club’s
medical staff, the Player shall bear the whole cost and risk of such treatment method.
Applying a treatment method different than indicated or accepted by the Club shall
constitute a breach of the Contract,
(…).”
7.
Clause 9 of the Contract provided as follows:
“9 PROPER PERFORMANCE OF THE CONTRACT
1. Provision of false data or statements by the Player, as well as the Player’s nonperformance or improper performance of duties stemming from the present Contract, in
particular duties specified in §1, §7 and §8 of the Contract, shall constitute a material
breach of the Contract and a basis to impose disciplinary sanctions on the Player by the
Club's bodies or other competent disciplinary authorities.
2. Irrespective of the disciplinary liability of the Player referred to in sec. 1 above, should
the provisions of the Contract be violated or should any false statements be provided by
the Player, the Club shall be entitled to claim from the Player a contractual penalty in to
the amount of the Player's current monthly basic remuneration for each act of breach,
whereby the Player unconditionally and irrevocably agrees that the Club may make
deductions from the remuneration referred to in §4 and §5 of the Contract for
contractual penalties received by the Player, disciplinary sanctions, differences resulting
from unreturned sports equipment or other reasonable deductions.
3. The penalty referred to in sec. 2 above does not exclude the Club's right to claim further
reimbursement of damages under generally applicable rules in the amount exceeding
the amount of the penalty.”
pg. 7
REF. FPSD-19980
8.
On 1 July 2024, the parties concluded a document titled “Annexe to the professional
football player contract dated 30th of June 2024” (hereinafter: the Annex) in order to
establish new financial terms of the Contract. The Annex established the following.
“As of the date of conclusion of the Annexe, the Parties:
1. amend §4 sec. 1 of the Contract to read as follows:
‘a. For the proper performance of the Contract, the Player is entitled to a basic
remuneration in the amount:
b. in the 2024/2025 season: 9 300,00 EUR (say: nine thousand thirty hundred euro
00/100) + VAT, if due, per month, i.e. a total 111 600,00 EUR (say: one hundred eleven
thousand six hundred euro 00/100) + VAT, if due,
c. in the 2025/2026 season, in the event of an extension of the Contract in accordance
with § 3 sec. 5 above:
i. either 11 160,00 EUR (say: eleven thousand one hundred sixty euro 00/100) +
VAT, if due, per month; a total of 133 920,00 EUR (say: one hundred thirty three
thousand nine hundred twenty euro 00/100) + VA T, if due - if the First Team
plays in 1 liga, i.e. the second highest league in Poland,
ii. or 12 400,00 EUR (say: twelve thousand four hundred euro 00/100) + VAT, if
due, per month; a total of 148 800,00 EUR (say: one hundred forty eight
thousand eight hundred euro 00/100) + VAT, if due - if the First Team plays in
Ekstraklasa, i.e. the highest professional league in Poland.’
2. amend §5 sec. 1 of the Contract to read as follows:
‘1. If, during the term of the Contract, the First Team is promoted to the Ekstraklasa,
the Player shall receive a one-off additional remuneration in the amount of 7 500,00
EUR (say: seven thousand five hundred euro 00/100) + VAT, if the due.’
3. amend §5 sec. 3-5 of the Contract to read as follows:
‘3. During the term of this Contract, the Player shall be entitled to an individual match
bonus in the amount specified in the table below + VAT, if due, for each goal and/or
assist scored by the Player for the First Team in a league match (including play-off):
Ekstraklasa 1 liga
450,00 EUR (say: four thousand hundred fifty euro 00/100)
pg. 8
REF. FPSD-19980
4. During the term of this Contract, the Player shall be entitled to an individual victory
bonus in the amount specified in the table below + VAT, if due, for each league match
won by the Team, provided that the Player has played at least 1 (say: one) minute of
such match:
Ekstraklasa 1 liga
450,00 EUR (say: four thousand hundred fifty euro 00/100)
5. Subject to sec. 6-7 below, if during the term of the Contract the First Team:
a. is ranked in the professional league of Ekstraklasa at the end of the season at the
place giving the right to play in the UEFA European cups qualifiers, the Player shall be
entitled to the one-off additional remuneration in the amount of 7 500,00 EUR (say:
seven thousand five hundred euro 00/100)+VAT, if the due,
b. wins the Polish Cup, the Player shall be entitled to the one-off additional
remuneration in the amount of 11 000,00 EUR (say: eleven thousand euro 00/100) +
VAT, if due,
c. becomes the Champion of Poland, the Player shall be entitled to the one-off
additional remuneration in the amount of 22 000,00 EUR (say: twenty two thousand
euro 00/100) + VAT, if due.’
4. amend §5 sec. 10-11 of the Contract to read as follows:
‘10. For the conclusion of the Conclusion of the Contract, the Player shall be entitled
to a one-time additional remuneration in the amount of 6 200,00 EUR (say: six
thousand two hundred euro 00/100) + VAT, if due, payable by 31st of July 2024.
11. The Player shall be entitled to a one-time additional remuneration in the amount
of 6 200,00 EUR (say: six thousand two hundred euro 00/100) + VAT, if due, in the
event that the Player plays at least 60% (say: sixty percent) of the minutes played by
the First Team during the term of the Contract during the league competitions
(including play-off) of the 2024/2025 season.’
(…)
5. The remaining provisions of the Contract shall remain in force. (…)”
9.
On 30 April 2025, the Player’s accountant sent invoice FS/1/04/2025 to the Club. This invoice
was issued by the Player to the Club for the amount of PLN 48,933.75, including 23% VAT.
The invoice description stated: “Basic salary according to the contract – April 2025”.
pg. 9
REF. FPSD-19980
10. On 22 May 2025, the Player and a contact saved by him as “Basha Vullnet” (hereinafter: Mr.
Vullnet), who, according to the Player is the Club’s sporting director, had the following
WhatsApp conversation (quoted verbatim):
Mr. Vullnet:
“Hi File how are you ?
You was to Dawid ?”
Player:
“(voice message)”
Mr. Vullnet:
“What he told you ? You need to go to the doctor or not ?”
Player:
“Hey say he will speak Tomorrow
With some Doctor
I have inflammation
He put me some tape
I will take some voltaren
Bro
10 days
And After I will test
Rest”
Mr. Vullnet:
“Ok go to Dawid again next week”
11. On 29 May 2025, the Club played its last match of the season against Miedz Legnica.
12. During the 2024/2025 season, the Player played 19 matches for the Club in the Betclic 1
Liga, five as part of the starting eleven and 14 as a substitute. The Player scored one goal,
made two assists, and participated in 11 wins of the Club in the Betclic 1 Liga.
13. On 2 June 2025, the Player’s accountant sent invoice FS/1/05/2025 to the Club. This invoice
was issued by the Player to the Club for the amount of PLN 48,623.76, including 23% VAT.
The invoice description stated: “Basic salary according to the contract – May 2025”.
14. On 4 June 2025, the Player and Mr. Vullnet had the following WhatsApp conversation
(quoted verbatim):
Player:
“Good Morning file!
Kazie just Text me the individual Plan... probably he doesnt know
yet....
And please give me Deadline for the Money”
Mr. Vullnet:
“You don't need to do the individual trainings
What do you mean deadline ?”
pg. 10
REF. FPSD-19980
Player:
“The Money untill when they send
This Week
Next Week?”
Mr. Vullnet:
“Ok”
15. On 9 June 2025, the Player and Mr. Vullnet had the following WhatsApp conversation
(quoted verbatim):
Mr. Vullnet:
“File how are you ?
You will be in Monday 16?”
Player:
“Ela file all good
You ?
What you mean?
Where I will be on 16 june ?
Mr. Vullnet:
“Good file
Working
File you have contract until 30.06
You must be here”
Player:
“What do you mean file, we say
That I will Not continue
I speak already with other CIub
I try To find Club”
Mr. Vullnet:
“File everyone must back on Monday here
Until 30.06”
(call)
Player:
“File Dont try to make me Problems.... All the year they fuck me and I
Never Complained I tryed to be always ready and help the Team when
they needed me. And when I had Problems I Stayed there and Never
Left to greece to make Therapie.”
Mr. Vullnet:
“Nobody is trying to make you problems
You just need to respect the contract like everyone”
Player:
“You Respect the contract ?
I Need To Fix my Body File
And doctor nows the Problems, its not something so he needs To Check
me
pg. 11
REF. FPSD-19980
He know already”
Mr. Vullnet:
“For me everything is clear”
Player:
“My Problem”
Mr. Vullnet:
“I have no problems with it
But until 30.06 our doctor decide
Our doctor and our physio”
Player:
“File about my Health no one decide, if he woudnt make so many
bullshits would be different But I will take care of my Body and no
doctor
And in this case I Expect more Support from you File.”
Mr. Vullnet:
“Tell me how can i support you and I will do it”
Player:
(voice message)
Mr. Vullnet:
“I will send it to the president
About payments., you cannot say nothing because I give you
information before signing that’s we have delays and you accept it”
Player:
“Yes send it
Are u serious Right now file ?
I think this is a joke”
Mr. Vullnet:
“So you are telling me that’s I didn’t tell you anything about salaries ?”
Player:
“You Said last year we had Problems But this year will be different,
because of Europe and this stuff”
Mr. Vullnet:
“Wouah i m chocked file”
Player:
“This is the thank you for all the year I sacrifice for you and this Club. I
got depressed because of the Coach and the Situation with almost 3,4
months not paid. I broke up with my Girl, I had car accident. But ok I
know for you you dont care about you Look to Save your Ass File But I
didnt excpet this from you”
Mr. Vullnet:
“Save my ass ? From what ? I m trying to avoid you problems and you
attack me“
pg. 12
REF. FPSD-19980
Player:
“Give me one serious reason to be there on June 16th File, since we’ve
already agreed that we won’t continue together next season. Why
shouldn’t I focus on my health and how I’ll move forward with my
career? Things didn’t work out the way either of us wanted, but
returning in the middle of my recovery and at the same time hearing
these kinds of things from you, is something I honestly can’t
understand. I’m truly sorry for this kind of mindset because I believed
that the team wouldn’t stand in the way, neither of my health nor of me
personally.”
Mr. Vullnet:
“I will speak with president tomorrow morning and i will let you know”
16. On 13 June 2025, the Player underwent an MRI. The findings of the MRI were as follows:
“FINDINGS
The articular surface of the left femoral head is normal. Normal imaging of the left
acetabulum. No hydrarthrosis.
Minimal fluid present in the lower part of the left hip joint.
Minimal edema at the level of the myotendinous junction and tendon of the left iliopsoas
muscle - possible minor muscle strain.
No other pathological signal intensity changes from the bone marrow and muscle group
examination.
Normal anatomy of the left sciatic nerve pathway.”
17. On 16 June 2025, the Club announced on its official website that the Player’s contract would
expire at the end of June 2025 and would not be extended. The Club wished the Player the
best in his future.
18. Also on 16 June 2025, a contact saved as “Kamil Manager” removed the Player from a
WhatsApp group named “Biala Gwiazda Myslenice”.
19. On an unspecified date, which according to the Player was 20 June 2025, the Player sent a
message to Mr. Vullnet requesting his outstanding remuneration.
20. On 23 June 2025, the Club sent a notice to the Player requesting him to provide
explanations for his absence from the Club’s first senior team training sessions and fitness
and endurance tests on 16 and 17 June 2025. The Club alleged that the Player was
breaching his contractual obligations, which could constitute grounds for disciplinary
sanctions. The Club granted the Player three days to provide explanations and informed
him that if he failed to respond, the Club would be entitled to impose contractual penalties.
Lastly, the Club informed the Player that he had the right to be assisted by legal counsel
and the right to be heard.
pg. 13
REF. FPSD-19980
21. On 26 June 2025, the Player replied to the Club’s letter, arguing that on 4 June 2025 Mr.
Vullnet had told him that he was not expected to follow the schedule of the team, since he
was not returning to the Club. In addition, the Player stated that on 9 June 2025 Mr. Vullnet
told him that he would speak with the Club’s president and therefore suggested that the
Club should stop pushing him. Furthermore, the Player argued that he underwent an MRI
on 13 June 2025, which showed that he should undergo treatment, and on 16 June 2025
the Club announced his departure, and he was removed from the first team’s WhatsApp
group chat. Moreover, the Player asserted that on 20 June 2025 he requested his
outstanding remuneration and that Mr. Vullnet failed to reply, all of which created a
legitimate expectation that it was reasonable not to attend the pre-season until 30 June
2025. However, the Player alleged that, after his complaint regarding overdue payables,
the Club took the opportunity to adopt abusive behaviour and put pressure on him, even
though he was not going to play for the Club again and was injured. Lastly, the Player
argued that the Club had no legal or rational grounds to impose any disciplinary sanctions.
22. On 27 June 2025, the Player put the Club in default and requested payment of PLN
97,557.51 as salaries and EUR 5,040 plus VAT as bonuses. In particular, the Player alleged
that despite the issuance of invoices, the Club had failed to pay him two salaries
(FS/1/04/2025 and FS/1/05/2025), as well as EUR 1,080 plus VAT as bonuses for
goals/assists and EUR 3,960 plus VAT as bonuses for victories. The Player also mentioned
that the salary for June 2025 would be due soon and granted the Club 10 days to comply
with the payments.
23. On 30 June 2025, the Player’s accountant sent invoice FS/1/06/2025 to the Club. This invoice
was issued by the Player to the Club for the amount of PLN 48,523.09, including 23% VAT.
The invoice description stated: “Basic salary according to the contract – June 2025”.
24. On 3 July 2025, the Player received PLN 16,311.25 from the Club as partial payment of
invoice FS/1/04/2025.
25. On 9 July 2025, the Player’s accountant sent invoice FS/2/06/2025 to the Club. This invoice
was issued by the Player to the Club for the amount of PLN 26,296.39, including 23% VAT.
The invoice description stated: “Basic salary according to the contract – regarding the
2024/2025 season”.
26. On 11 August 2025, after this claim was lodged, the Club responded to the Player’s letter
and imposed a contractual penalty of EUR 1,500 on him. In this regard, the Club alleged
that the fact that the Contract was not extended was irrelevant, as he was bound to the
Club until 30 June 2025 and was obligated to perform all duties until that date. However,
the Club remarked that he failed to attend the training sessions of 16 and 17 June 2025.
Additionally, the Club contended that the informal exchange of messages with Mr. Vullnet
did not constitute any form of waiver or modification of the Player’s contractual obligations.
Moreover, the Club affirmed that the Player violated the medical provisions stipulated in
the Contract by undergoing an MRI in Greece without the Club’s authorization. The Club
pg. 14
REF. FPSD-19980
further stated that neither the messages nor the announcement on the official website
indicated that he was allowed to be absent from training, as both were neutral and
informative. Based on this, the Club stated that the EUR 1,500 penalty would be deducted
from the Player’s remuneration.
27. On 5 September 2025, the Club paid PLN 9,159.82 to “NACZELNIK URZĘDU SKARBOWEGO
KRAKÓW-ŚRÓDMIEŚCIE”. According to the Club, it was obliged to make this payment on
behalf of the Player to the Internal Revenue Service of Poland and, therefore, this amount
should be considered as paid to the Player in accordance with the Contract.
28. On 30 September 2025, the Club paid PLN 3,459.86 to “NACZELNIK URZĘDU SKARBOWEGO
KRAKÓW-ŚRÓDMIEŚCIE”. According to the Club, it was obliged to make this payment on
behalf of the Player to the Internal Revenue Service of Poland and, therefore, this amount
should be considered as paid to the Player in accordance with the Contract.
29. On 20 November 2025, the Club paid PLN 137,086.58 to the Player.
II. Proceedings before FIFA
30. 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
31. The Player argued that the parties concluded the Contract, which was valid until 30 June
2025. The Player stated that during the 2024/2025 football season, he scored two goals and
made two assists in the league, while he participated for at least one minute in 10 wins of
the Club in the league. Notwithstanding, the Player argued that the Club failed to pay him
several amounts and, therefore, on 27 June 2025 he put the Club in default and requested
payment of PLN 48,933.75 for April 2025, PLN 48,623.76 for May 2025, and EUR 5,040 plus
VAT for the bonuses.
32. According to the Player, the Club only paid him PLN 16,311.25 corresponding to April 2025.
In addition, he alleged that on 11 July 2025 the salary for June 2025 became due and that
on 16 July 2025 the bonuses became due. In this regard, the Player asserted that there are
overdue payables towards him equal to PLN 156,065.74 (PLN 32,622.50 for April 2025, PLN
48,623.76 for May 2025, PLN 48,523.09 for June 2025, and PLN 26,296.39 for bonuses).
33. The Player’s requests for relief were the following:
“In view of the above, the Claimant request by your Respectable Chamber to:
pg. 15
REF. FPSD-19980
A. Determine that the Respondent has overdue payables towards the Claimant on the
total amount of PLN 156,065.74;
B. To order the Club to pay to the Player the said overdue amount plus default interest
of 5% calculated as follows:
i.
ii.
iii.
iv.
5% interest on the amount of PLN 32,622.50, calculated from 11.05.2025 and
until effective payment of the amount;
5% interest on the amount of PLN 48,623.76, calculated from 11.06.2025 and
until effective payment of the amount;
5% interest on the amount of PLN 48,523.09, calculated from 11.07.2025 and
until effective payment of the amount;
5%’ interest on the amount of PLN 26,296.39, calculated from 01.07.2025 and
until effective payment of the amount;
C. The imposition of the appropriate disciplinary sanctions against the Club, on the basis
of art. 12bis FIFA RSTP.”
b. Reply and counterclaim of the Club
34. In its reply, the Club remarked that the Contract and the Annex were valid until 30 June
2025 and that on 16 and 17 June 2025 the Player was absent from the training sessions
and the fitness and endurance tests of the Club’s first senior team. The Club also stated
that during the first half of June 2025 the Player had been seeking medical treatment in
Greece without the prior consultation or consent of the Club.
35. Based on the above, the Club affirmed that on 23 June 2025 it summoned the Player to
provide explanations for his absence and informed him of the possibility of the imposition
of a contractual penalty. In this regard, the Club acknowledged that the Player provided his
explanations and asserted that on 11 August 2025 it responded to the explanations and
notified him of the imposition of a penalty of EUR 1,500.
36. The Club argued that there was no mutual agreement to terminate the Contract and,
therefore, the parties remained fully bound to perform all obligations, including full
participation in the training process, until the final day of the contractual term. The Club
remarked that, for example, a teammate of the Player in the same situation continued to
attend every mandatory training session.
37. Furthermore, the Club affirmed that its delay in payments could not imply that the Player
was released from his duties, and that the Player failed to obtain authorization for his
absence, unlike other players.
38. The Club also insisted that the Player underwent a medical examination during the term of
the Contract without authorization.
pg. 16
REF. FPSD-19980
39. Based on all the above, the Club argued that it imposed a contractual penalty of EUR 1,500,
which represents 20% of the value of a salary under the Contract and is neither excessive
nor unreasonable. According to the Club, this fine was imposed in respect of the principles
of fairness and proportionality, while taking into account the established jurisprudence of
the Football Tribunal and the Court of Arbitration for Sport (CAS), and the Player was
already aware that he could be subjected to penalties when he signed the Contract.
40. The Club’s requests for relief were the following:
“I. Due to the reasons explained above I kindly request the FIFA Football Tribunal to fully
reject the Claim.
II. In the event that the request specified in point I above is not approved, the Respondent
hereby kindly requests that the Claimant’s claim is rejected in part, primarily with respect
to the deduction of the remuneration due to improper performance of the Contract. In
case the Chamber finds that such deduction of 1 500,00 EUR (say: one thousand five
hundred euro 00/100) is substantiated, the Respondent requests that the Chamber
awards at least the said amount or a higher figure, as the contractual breaches were of
a serious nature.”
41. After the FIFA general secretariat requested the Club to clarify its submission, the Club
modified its requests as follows:
“41. Pursuant to art. 22 sec. 1 let b) and art. 23 sec. 1 of the RSTP as well as art. 18 sec. 1
and art. 21 sec. 3 of the Procedural Rules the Counter-Claimant hereby requests the FIFA
Dispute Resolution Chamber of the FIFA Football Tribunal to:
a. fully reject the Claim;
b. in the event that the request specified in point I above is not approved, the CounterClaimant hereby kindly requests that the Counter-Respondent's claim is rejected in part,
primarily with respect to the deduction of the remuneration due to improper
performance of the Contract in the amount of 5 000,00 EUR (say: five thousand euro
00/100);
c. in case the Chamber finds that such deduction of 5 000,00 EUR (say: five thousand
euro 00/100) is not substantiated, the Counter-Claimant requests that the Chamber
awards at least the amount of 1 500,00 EUR (say: one thousand five hundred euro
00/100).”
pg. 17
REF. FPSD-19980
c. Player’s reply to the counterclaim
42. In his reply to the counterclaim, the Player argued that the team’s sporting obligations
ended on 29 May 2025 and that, after that date, no professional obligations existed for the
2024/2025 football season. The Player further contended that on 4 June 2025, Mr. Vullnet
informed him that he was not expected to follow the schedule of the team, since he was
not returning to the Club.
43. The Player argued that, however, after his complaints regarding the existence of overdue
payables, the Club changed its stance and put pressure on him to attend the pre-season,
even though he was not going to play for the Club again. Therefore, the Player alleged that
the Club informed him that he had to join the pre-season and that the medical staff and
coaches would decide on medical and health issues, although he was leaving the Club.
44. In this context, the Player affirmed that Mr. Vullnet suggested that the Club would stop
pushing and that the Player would receive a response from the president to clarify the
situation. In the meantime, he asserted that he underwent an MRI, the Club announced his
departure, and he was expelled from the WhatsApp group. Additionally, the Club stopped
replying to his messages.
45. The Player maintained that on 23 June 2025 he received a notice inviting him to provide
explanations for his absences on 16 and 17 June 2025, and not regarding the alleged
medical examinations and treatment from third parties. The Player stated that he replied
to these allegations and that on 11 August 2025, after the Contract had ended and while
the Club still owed salaries, the Club imposed a disciplinary decision.
46. Regarding the two-day absence, the Player alleged that after the end of the team’s
obligations, he left for Greece for his off-season vacation. According to the Player, he was
not expected to return to the Club’s activities until the expiry of the Contract, based on
standard practice in football employment relationships, clause 3.2 of the Contract and art.
18 par. 2 of the Regulations on the Status and Transfer of Players (hereinafter: the
Regulations). The Player further argued that the behaviour of the parties, i.e. the
aforementioned events as of 4 June 2025, aligned with this understanding - especially the
conversations with Mr. Vullnet, who is a high-ranking official, and his expulsion from the
WhatsApp group.
47. Additionally, the Player remarked that the teammate who participated in the pre-season
was specifically mentioned as doing so in the Club’s announcement, in contrast to the
Player’s own announcement, which did not include such information. The Player affirmed
that other players did not participate in the pre-season and remarked that, since the Club
granted leave to another player, there was discriminatory behaviour toward him.
48. Therefore, the Player affirmed that the disciplinary sanctions shall be deemed null and
void.
pg. 18
REF. FPSD-19980
49. Regarding the alleged treatment in Greece, the Player stated that the Club did not specify
the exact breach, he was not invited to provide explanations about this alleged breach, and
the Club never requested him to refrain from these actions beforehand, even though the
Club was aware of his injuries. He argued that he only underwent an MRI to protect his
physical integrity. Thus, the Player asserted that he did not commit any breach in this
regard and, in any event, the Club did not follow the correct process.
50. In general, the Player contended that the Club’s arguments regarding the validity of the
disciplinary sanctions rely solely on clause 9 of the Contract, which generally refers to the
Club’s right to impose disciplinary sanctions upon the Player. However, the Player argued
that this clause does not provide the necessary contractual basis for the Club to impose
disciplinary sanctions against him.
51. Moreover, the Player stated that there is no established disciplinary committee within the
Club to guarantee the Player’s right to be heard, and the decision appears to have been
taken solely by the president. Additionally, he was not informed of his right to appeal the
decision. In any event, the Player argued that the Club is not entitled to set off overdue
payables owed to employees against fines, which he also considered disproportionate
given his salary, the fact that the absence lasted only two days, and the timing of the
decision.
52. Lastly, the Player affirmed that the Club’s request to reduce the overdue payables lacks any
regulatory and contractual basis and made the following requests for relief:
“97. In view of the above, the Claimant request by your Respectable Chamber to:
A. Determine that the Respondent has overdue payables towards the Claimant on the
total amount of PLN 156,065.74;
B. To order the Club to pay to the Player the said overdue amount plus default interest
of 5% calculated as follows:
i.
ii.
iii.
iv.
5% interest on the amount of PLN 32,622.50, calculated from 11.05.2025 and
until effective payment of the amount;
5% interest on the amount of PLN 48,623.76, calculated from 11.06.2025 and
until effective payment of the amount;
5% interest on the amount of PLN 48,523.09, calculated from 11.07.2025 and
until effective payment of the amount;
5% interest on the amount of PLN 26,296.39, calculated from 01.07.2025 and
until effective payment of the amount;
C. The imposition of the appropriate disciplinary sanctions against the Club, on the basis
of art. 12bis FIFA RSTP.
pg. 19
REF. FPSD-19980
D. Reject the arguments and requests of the Respondent / Counter-Claimant in their
entirety, and in particular to reject:
I. The Respondent's request to fully reject the claim;
II. The Respondent's request to deduct an amount of EUR 5,000 from the overdue
payables due to alleged improper performance;
III. The Respondent's request to deduct an amount of EUR 1,500 from the overdue
payables based on the disciplinary decision of the Club.”
d. Additional documents and comments of the parties
53. On 16 October 2025, the FIFA general secretariat informed the parties that the submission
phase in the present case was closed (cf., art. 23, par. 1 of the Procedural Rules Governing
the Football Tribunal; hereinafter: the Procedural Rules).
54. On 20 November 2025, after the closure of the submission phase, the Club paid the Player
PLN 137,086.58 and argued that on 8 and 30 September 2025 it paid PLN 9,159.82 and PLN
3,427.73 respectively on behalf of the Player to the Internal Revenue Service of Poland.
Therefore, the Club stated that the entire outstanding remuneration had been paid,
excluding the amount of EUR 1,500, which is the subject of the counterclaim.
55. On 5 December 2025, the Player acknowledged receipt of PLN 137,086.58 but argued that
he did not receive the payments of PLN 9,159.82 and PLN 3,427.73, which were also
allegedly made before the closure of the submission phase, with the first one even made
before the Club’s submission dated 10 September 2025. In this regard, the Player stated
that the submissions regarding the alleged two payments should be considered
inadmissible. In any event, the Player argued that the documents submitted by the Club
have not been translated into an official FIFA language and should be disregarded.
56. Lastly, the Player amended his requests for relief as follows:
“78. In view of the above, the Claimant request by your Respectable Chamber to:
A. Determine that the Respondent had overdue payables towards the Claimant on the
total amount of PLN 156,065.74, of which PLN 137,086.58 PLN was paid to the Claimant
after the closure of the submissions, and therefore the amount of PLN 18,979.16 remains
overdue.
B. To order the Club to pay to the Player the default interest of 5% calculated as follows:
i.
ii.
5% interest on the amount of PLN 32,622.50, calculated from 11.05.2025 and
until effective payment of the amount, i.e. until 20.11.2025;
5% interest on the amount of PLN 48,623.76, calculated from 11.06.2025 and
until effective payment of the amount, i.e. until 20.11.2025.
pg. 20
REF. FPSD-19980
iii.
iv.
v.
5% interest on the amount of PLN 48,523.09, calculated from 11.07.2025 and
until effective payment of the amount, i.e. until 20.11.2025.
5% interest of the amount of PLN 7,317.23, calculated from 01.07.2025 and until
effective payment of the amount, i.e. until 20.11.2025
5% interest on the amount of PLN 26,296.39, calculated from 01.07.2025 and
until effective payment of the amount;
C. The imposition of the appropriate disciplinary sanctions against the Club, on the basis
of art. 12bis FIFA RSTP.
D. Reject the arguments and requests of the Respondent / Counter-Claimant in their
entirety, and in particular to reject:
I. The Respondent's request to fully reject the claim;
II. The Respondent's request to deduct an amount of EUR 5,000 from the overdue
payables due to alleged improper performance (which was actually withdrawn by the
Claimant with his late submission).
III. The Respondents request to deduct an amount of EUR 1,500 from the overdue
payables based on the disciplinary decision of the Club.”
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
57. 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
22 January 2026. Taking into account the wording of arts. 31 and 34 of the January 2026
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.
58. 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 Greek player and a Polish club.
59. 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.
pg. 21
REF. FPSD-19980
b. Admissibility of the Club’s submission dated 20 November 2025
60. The Chamber then recalled that the Club submitted an unsolicited correspondence on 20
November 2025, i.e., after the closure of the submission-phase, the admissibility of which
must be assessed.
61. In this respect, the Chamber first considered that according to the practice of the Football
Tribunal, simple proofs of payments are, in principle, not interpreted as a formal
amendment of submissions and generally admitted with the ultimate goal to prevent
unjust enrichment.
62. Nevertheless, the Chamber also noted that in the present case the Club submitted two
alleged proofs of payments made to the Internal Revenue Service of Poland on behalf of
the Player and intended to deduct these amounts from the Player’s claim. In this regard,
considering that these alleged payments were not directly made to the Player but to a
third-party agency, and that the Club was thereby submitting a full new argument, the
Chamber deemed this part of the submission (and related evidence) inadmissible and
decided to disregard them, based on art. 23 par. 1 of the Procedural Rules.
c. Burden of proof
63. 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).
d. Merits of the dispute
64. 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.
i. Main legal discussion and considerations
65. The Chamber then moved to the substance of the matter, noting that it concerned a claim
brought by a player against a club for outstanding remuneration and a counterclaim
brought by a club against the player for a salary deduction / penalty.
pg. 22
REF. FPSD-19980
66. The Chamber recalled that, according to the Player, the Club failed to pay him several
salaries and bonuses. Although the Player acknowledged a partial payment, he argued that
the alleged payments made to the Internal Revenue Service of Poland could not be taken
into account and that the Club was not entitled to any deduction, as the penalty should be
considered null and void.
67. Conversely, the Chamber noted that the Club argued that it paid all the amounts
corresponding to the Player and is entitled to deduct EUR 1,500 as a penalty. While the Club
submitted its request as a counterclaim and appeared to seek an “award”, the Chamber
interpreted that it actually sought the deduction of EUR 1,500 from the outstanding
remuneration – originally EUR 5,000 but considering the partial payment and the
allegations that it paid everything except EUR 1,500, the Chamber deemed that this request
was moot.
68. In this regard, the Chamber noted that it was undisputed that the Player was entitled to
the PLN 156,065.74 he requested, but the Club argued that PLN 9,159.82 and PLN 3,427.73
should be considered as already paid and that further EUR 1,500 (or PLN 6,384) should be
deducted.
69. In this context, the Chamber acknowledged that its task was to determine whether the
Player is entitled to the full amount claimed or whether any deductions shall apply.
70. Regarding the payments of PLN 9,159.82 and PLN 3,427.73 allegedly made on behalf of the
Player, the Chamber recalled that the evidence and arguments submitted by the Club were
deemed inadmissible and, therefore, the Club was not entitled to this deduction. The
Chamber stressed that even if the documents were to be considered admissible (quod non),
the Club’s argument could still not be accepted, as the documents were untranslated and
there was no agreement between the parties regarding any set-off of these obligations.
71. Regarding the EUR 1,500 penalty, the Chamber noted that it was undisputed that the Player
was absent on 16 and 17 June 2025. While the Club argued that the Contract was still valid
and binding and that he was therefore obliged to attend training sessions, the Player
affirmed that the Club’s behaviour and standard practice granted him the legitimate
expectation that he was not obliged to attend those sessions. It was also undisputed that
on 23 June 2025 the Club requested the Player to provide explanations regarding his
absences, which he did on 26 June 2025, and that on 11 August 2025, after the claim had
been lodged, the Club imposed on the Player a penalty of EUR 1,500.
72. At this point, the Chamber recalled that, in line with established Football Tribunal and CAS
jurisprudence, clubs may, as a general principle, impose on players and offset such
amounts against salary only where the parties have expressly agreed to the possibility of
set-off. That said, CAS has applied a restrictive approach to such mechanisms, emphasizing
that any set-off of fines must not deprive an employee of their basic salary nor be
pg. 23
REF. FPSD-19980
implemented in an abusive or disproportionate way (see, for example, CAS 2018/A/5807).
Moreover, according to the jurisprudence of the Football Tribunal, financial penalties –
including fines or any comparable monetary sanctions – cannot be used by clubs as a tool
to circumvent or reduce outstanding financial obligations owed to players.
73. Furthermore, the Chamber pointed out that in previous cases addressing this issue, the
Football Tribunal has analysed whether a proper disciplinary process was followed by the
club and whether the player’s right to be heard was respected. Additionally, it has assessed
whether the fine was excessive or proportionate.
74. With all the above in mind, the Chamber decided that it had to analyse whether (i) there
was an agreement expressly allowing set-off; (ii) a proper disciplinary process was followed
by the Club; and (iii) the penalty was proportionate.
75. Regarding the existence of an agreement between the parties, the Chamber observed that
clause 9 of the Contract provided as follows:
“2. Irrespective of the disciplinary liability of the Player referred to in sec. 1 above, should
the provisions of the Contract be violated or should any false statements be provided by
the Player, the Club shall be entitled to claim from the Player a contractual penalty in to
the amount of the Player's current monthly basic remuneration for each act of breach,
whereby the Player unconditionally and irrevocably agrees that the Club may make
deductions from the remuneration referred to in §4 and §5 of the Contract for
contractual penalties received by the Player, disciplinary sanctions, differences resulting
from unreturned sports equipment or other reasonable deductions.”
76. In this context, the Chamber noted that the parties agreed that the Club was entitled to
make deductions from the Player’s remuneration.
77. Based on this, the Chamber determined that it had to analyse whether a proper disciplinary
process was followed by the Club. In this sense, and before entering into any further
assessment, the first point the Chamber highlighted was that the penalty was imposed
more than one month after the Contract had ended, and after the Player had lodged a
claim for his outstanding remuneration – from which the Club intends to make a deduction.
78. Consequently, the Chamber considered that the Club appeared to have imposed a
retroactive penalty in order to reduce the amount payable to the Player, when, based on
its own behaviour, after the Player replied to the notice on 26 June 2025, it failed to react
accordingly and failed to impose any alleged disciplinary measure before the Contract
came to an end, i.e. when it would have been legitimately expected that a disciplinary
sanction be imposed.
79. Moreover, the Chamber emphasised that while in the notice the Club informed the Player
of his right to be heard, it referred to a meeting that apparently never took place.
pg. 24
REF. FPSD-19980
Additionally, while in the first notice the Club only requested explanations for the absences,
in the letter imposing the fine it justified the penalty also on the basis of the medical
examinations and alleged treatment the Player underwent in Greece without authorization
– an issue that had not been raised in the first notice. Furthermore, the Chamber found it
unclear who decided to impose the penalty, as the president merely stated that the “Club”
imposed it, and the Player was not informed of the possibility to appeal.
80. Thus, the Chamber considered that the Club failed to follow a proper disciplinary process
and, therefore, no lawful deduction could be applied.
81. In any event, the Chamber remarked that the penalty may also be considered
disproportionate, taking into account that the Player was entitled to a monthly salary of
EUR 9,300 – which results in a daily wage of EUR 310 – and especially considering that the
Contract was due to expire in less than 15 days and that it appeared the Player was not
expected to attend pre-season.
82. In fact, the Chamber wished to highlight that, although it was undisputed that the Player
did not return to the Club’s country on 16 June 2025 and the Contract was valid until 30
June 2025, the Club did not argue that the Player failed to attend training from 16 June 2025
to 30 June 2025. Rather, it affirmed that he was only absent for two days. Moreover, the
Club acknowledged that the Player was entitled to the full salary of June 2025 and did not
argue that he should not be entitled to the salary for the second half of June – which would
be the expected behaviour if the Club truly expected him to attend activities until the end
of the Contract. Thus, the Chamber found that the Club’s behaviour suggested that the
Player was only expected to attend the trainings on 16 and 17 June 2025 and, in the
Chamber’s view, this made the penalty disproportionate, especially considering that the
Player acceptably returned to his country with the Club’s authorization on 29 May 2025 and
would have needed to travel to a foreign country merely to attend two days of training.
83. Based on the elements established above, the Chamber decided to reject the Club’s
allegations and to award the Player full outstanding remuneration.
84. Having established this, the Chamber first decided to reject the Club’s counterclaim, as no
amount should be awarded to the Club or deducted from the outstanding remuneration.
85. Then, the Chamber moved on to determine the amounts that should be awarded to the
Player, considering that he received a payment on 20 November 2025. The Chamber noted
that both the Contract and the Annex stipulated that the Player was entitled to several
amounts in EUR and, in principle, the Chamber pointed out that it would award him any
amounts in EUR. However, the Chamber also remarked that in this case: (i) clause 6 par. 14
of the Contract established that the remuneration should be paid in PLN, (ii) the Player
requested the amounts in PLN, (iii) the Club did not dispute owing the amounts claimed in
PLN, (iv) the Player issued all his invoices to the Club in PLN, (v) the claim was based on
several invoices in PLN using a stipulated exchange rate, which was also undisputed by the
pg. 25
REF. FPSD-19980
Club, and (vi) the Club paid the Player in PLN throughout the entire employment
relationship. Based on this, the Chamber decided to award all the amounts in PLN.
86. Having stated the above, the Chamber recalled that it remained undisputed that the Player
was entitled to PLN 156,065.74 for the balance of the invoice for April 2025, and the full
invoices for May and June 2025, as well as the bonuses, all including VAT. Since the Club
paid PLN 137,086.58 on 20 November 2025 and no further deductions were confirmed, the
Chamber considered that the Player should therefore be awarded PLN 18,979.16.
87. Additionally, the Chamber noted that the Player requested interest over the amounts paid
on 20 November 2025, considering that with those payments the Club settled the oldest
outstanding debts – which the Chamber found to be consistent with the standard practice
of the Football Tribunal in the absence of any allocation made by the relevant debtor.
88. In this regard, the Chamber recalled that the Club had to pay the salaries for April, May,
and June 2025 no later than the 10th day of the following month. Concerning the bonuses,
the Chamber interpreted that, based on the Contract, they were to be paid no later than
15 July 2025, i.e., 15 days after the season ended.
89. Hence, the Chamber considered that with the payment made on 20 November 2025, the
Club settled the salaries for April, May, and June 2025 and part of the bonuses.
90. Based on the above, the Chamber decided to award the Player 5% interest p.a. over the
balance for April and the full salaries for May and June 2025 as from the 11th day of each
following month until 20 November 2025, and over the paid balance of the bonuses from
16 July 2025 until 20 November 2025. Regarding the PLN 18,979.16 awarded with this
decision, the Chamber decided to award 5% interest p.a. as from 16 July 2025 until the date
of effective payment.
ii. Art. 12bis of the Regulations
91. The Chamber 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.
92. To this end, the Chamber confirmed that the Player put the Club 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.
93. Accordingly, the Chamber also confirmed that the Club 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.
pg. 26
REF. FPSD-19980
94. The Chamber further established that, by virtue of art. 12bis par. 4 of the Regulations the
Chamber has competence to impose sanctions on the club. On account of the above, and
bearing in mind that this is the first offense by the Club within the last two years, the
Chamber decided to impose a warning on the Club in accordance with art. 12bis par. 4 lit.
a) of the Regulations.
95. The Chamber 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
96. 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.
97. 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.
98. 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.
99. 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.
100. 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.
e. Costs
101. 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,
pg. 27
REF. FPSD-19980
or match agent”. Accordingly, the Chamber decided that no procedural costs were to be
imposed on the parties.
102. 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.
103. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
pg. 28
REF. FPSD-19980
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant / Counter-Respondent, Ioannis Kiakos, is partially accepted.
2.
The counterclaim of the Respondent / Counterclaimant, Towarzystwo Sportowe Wisla
Krakow SA, is rejected.
3.
The Respondent / Counterclaimant must pay to the Claimant / Counter-Respondent the
following amounts:
- 5% interest p.a. over the amount of PLN 32,622.50 as from 11 May 2025 until 20
November 2025;
- 5% interest p.a. over the amount of PLN 48,623.76 as from 11 June 2025 until 20
November 2025;
- 5% interest p.a. over the amount of PLN 48,523.09 as from 11 July 2025 until 20
November 2025;
- 5% interest p.a. over the amount of PLN 7,317.23 as from 16 July 2025 until 20
November 2025;
- PLN 18,979.16 as outstanding remuneration plus 5% interest p.a. as from 16 July 2025
until the date of effective payment;
4.
Any further claims of the Claimant / Counter-Respondent are rejected.
5.
A warning is imposed on the Respondent / Counterclaimant.
6.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
7.
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 / Counterclaimant 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.
pg. 29
REF. FPSD-19980
8.
The consequences shall only be enforced at the request of the Claimant / CounterRespondent in accordance with art. 24 par. 7 and 8 and art. 25 of the Regulations on the
Status and Transfer of Players.
9.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 30
REF. FPSD-19980
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. 31