Labour Disputes
Texto da decisão
REF. FPSD-20115
Decision of the
Dispute Resolution Chamber
passed on 30 October 2025
regarding an employment-related dispute concerning the player Szidonia
Papp
COMPOSITION:
Lívia SILVA KÄGI (Brazil & Switzerland), Deputy Chairwoman
Khadija TIMERA (Senegal), Member
Jorge GUTIÉRREZ (Costa Rica), Member
CLAIMANT:
Szidonia Papp, Hungary
Represented by Antonis Vogiatzakis
RESPONDENT:
NEES ATROMITOU 2018, Greece
Represented by Paraskevas Atlamazoglou
pg. 2
REF. FPSD-20115
I. Facts of the case
1.
On 20 June 2024, the Hungarian player, Szidonia Papp (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 Papp Szidonia 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
Bucharest - Athens - Bucharest.”
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 16 June 2025, the Player put the Club in default of payment of EUR 6,000, granting it 15
days in order to remedy the default.
6.
On 2 July 2025, the Player terminated the Contract invoking just cause due to outstanding
salaies.
7.
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.
8.
According to her new employment contract with BSC 1924 Futball FT, the Player is entitled
to a monthly remuneration of HUF 400,000.
pg. 3
REF. FPSD-20115
II. Proceedings before FIFA
9.
On 28 July 2025, the Player filed the claim at hand before FIFA. A summary of the parties’
respective positions is detailed below.
a. Position of the Player
10. 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).
11. The Player further argued that the Club failed to fulfil its financial obligations and that she
had just cause to terminate the Contract.
12. The Player submitted that, as of the date of the default notice, the Club failed to pay her
EUR 6,000 corresponding to the full salaries from January to May 2025.
13. The Player further claimed to be entitled to the amount corresponding to the value of the
ticket for the Athens to Bucharest flight, in accordance with the Handwritten Document.
14. 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 Szidonia Papp terminated the Employment Agreement with just
cause;
- Order the football club “Nees Atromitou 2018” to pay to the player Szidonia Papp the total
net amount of seven thousand two hundred euro (7,200€) 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 Szidonia Papp the value
of the outstanding air – ticket from Athens to Bucharest, 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 Szidonia Papp 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;
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REF. FPSD-20115
- 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. Position of the Club
15. Despite having been invited to do so, the Club failed to provide its position within the
deadline granted by the FIFA general secretariat, i.e., no later than 25 August 2025.
16. On 26 August 2025 at 1:54 hrs (local time in Greece), the Club filed a late response.
17. On 10 September 2025, the FIFA general secretariat acknowledged receipt of the above
correspondence and informed the Club that it will be up to the relevant Chamber of the
Football Tribunal to accept or not its response to the claim.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
18. 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 28 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.
19. 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 Hungarian player and a Greek club.
20. 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. 5
REF. FPSD-20115
b. Admissibility of the late reply
21. At this point, the Chamber recalled that the Club failed to timely submit its reply to the
claim of the Player. In this respect, the Chamber pointed to art. 11 par. 4 of the Procedural
Rules and concluded that said late reply cannot be considered in the matter at hand.
c. Burden of proof
22. 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
23. 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
24. 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.
25. In particular, the Chamber observed that the Player maintained to have terminated the
Contract with just cause due to outstanding salaries.
26. The Chamber also observed that the Club failed to provide its position within the deadline
granted by the FIFA general secretariat and, therefore, determined that the decision will be
made based on the arguments and evidence on file (cf. art. 21 par. 1 of the Procedural
Rules).
27. In this context, the Chamber acknowledged that its task was to analyse whether the Player
had a just cause to unilaterally terminate the Contract and, if so, to determine the legal
consequences thereof.
pg. 6
REF. FPSD-20115
28. Notwithstanding the above, the Chamber determined that, before entering into the
analysis of the termination of the Contract, it must be analysed ex officio the status of the
Player.
29. In this context, 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 well-established 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.
30. In this sense, and based on the documentation on file, the Chamber held that, in
accordance with its well-established jurisprudence, the monthly salary 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.
31. Consequently, the Chamber deemed that the Player held professional status.
32. 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.
33. 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,
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).
34. The Chamber noted that, according to the Player, the Club failed to pay her monthly
salaries from January to June 2025.
35. 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.
36. 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. Nonetheless, the Chamber observed that
no evidence was provided in this regard.
37. 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.
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REF. FPSD-20115
ii. Consequences
38. 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.
39. 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 six full monthly
salaries under the Contract, amounting to EUR 7,200.
40. In addition, the Chamber also took note that the Player requested the payment of the value
of the flight tickets from Athens to Bucharest under the Handwritten Document. In this
respect, the Chamber observed that it was provided that the Player travelled to Bucharest
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.
41. 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.
42. 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 7,200 (i.e., six
times EUR 1,200).
43. 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.
44. 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.
45. 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.
pg. 8
REF. FPSD-20115
46. 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).
47. 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.
48. 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.
49. 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.
50. 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.
51. 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.
52. 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.
53. 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
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REF. FPSD-20115
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.
54. However, the Chamber noted that the Player requested to be compensated in the amount
of EUR 5,800.
55. 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.
56. 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
57. 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.
58. 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.
59. 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.
60. 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.
61. 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.
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REF. FPSD-20115
e. Costs
62. 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.
63. 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.
64. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
pg. 11
REF. FPSD-20115
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Szidonia Papp, is partially accepted.
2.
The Respondent, NEES ATROMITOU 2018, must pay to the Claimant the following
amount(s):
- EUR 7,200 as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of EUR 1,200 as from 1 February 2025 until the date
of effective payment;
- 5% interest p.a. over the amount of EUR 1,200 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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REF. FPSD-20115
6.
The consequences shall only be enforced at the request of the Claimant in accordance
with art. 24 par. 7 and 8 and art. 25 of the Regulations on the Status and Transfer of Players.
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 13
REF. FPSD-20115
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. 14