Labour Disputes
Texto da decisão
REF. FPSD-20148
Decision of the
Dispute Resolution Chamber
passed on 5 March 2026
regarding an employment-related dispute concerning the player Stipe Juric
COMPOSITION:
Frans DE WEGER (The Netherlands), Chairperson
Khadija TIMERA (Senegal), Member
Jorge GUTIÉRREZ (Costa Rica), Member
CLAIMANT / COUNTER-RESPONDENT:
Stipe Juric, Croatia
Represented by Mateusz Stankiewicz
RESPONDENT / COUNTERCLAIMANT:
CFR Cluj, Romania
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REF. FPSD-20148
I. Facts of the case
1.
On an unspecified date, the Croatian player Stipe Juric (hereinafter: the Claimant / CounterRespondent or the Player) and the Romanian club CFR Cluj (hereinafter: the Respondent /
Counterclaimant or the Club) concluded an employment contract (hereinafter: the Contract)
valid as from 5 January 2025 until 30 June 2027.
2.
According to the Contract, the Club undertook to pay the Player a monthly salary of EUR
10,000 net and a monthly accommodation allowance of EUR 500 net at the latest by the
25th day of the month following the relevant month.
3.
On 26 June 2025, the Player put the Club in default and requested payment within 15 days
of EUR 31,500, i.e., corresponding to three outstanding monthly salaries and
accommodation allowances.
4.
On 10 July 2025, the Club provided the Player with a proposed agreement to terminate the
Contract amicably.
5.
On 11 July 2025, the Player provided the Club with a counteroffer to its proposed
agreement to terminate the Contract amicably.
6.
On the same day, i.e., 11 July 2025, the Club presented the Player with a final offer to
terminate the Contract amicably.
7.
On the same day, i.e., 11 July 2025, the Player informed the Club that he is not satisfied with
the wording of its final offer to terminate the Contract amicably and that his lawyer will
prepare an amended version by 14 July 2025.
8.
On 14 July 2025, the Player unilaterally terminated the Contract.
9.
On 16 July 2025, the Club remitted the amount of RON 160,004 to the Player.
10. On 26 September 2025, the Player signed a new employment contract with the Greek club
P.A.E. Levadeiakos, valid as from its date of signature until 30 June 2026. Under this new
contract, the Player is entitled to a total amount of EUR 74,000 net, i.e., EUR 57,500 net as
salaries, EUR 9,000 net as accommodation allowances and EUR 7,500 as sign-on fee.
II. Proceedings before FIFA
11. On 30 July 2025, the Player filed the claim at hand before FIFA. A summary of the parties’
respective positions is detailed below.
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a. Claim of the Player
12. In his claim, the Player argued that he terminated the Contract with just cause due to
outstanding remuneration.
13. In addition, the Player argued that he is entitled to interest for the Club’s delayed payments
of the outstanding monthly salaries and accommodation allowances for the period from
March to May 2025, which were only paid on 16 July 2025.
14. Having stated the above, the Player’s requests for relief were the following, quoted
verbatim:
“The Player claims for payment of the sum of EUR 294.191,32 net along with the statutory
interest in the rate 5% p.a. calculated in the following way:
1) From the sum of EUR 191,32 from 17 July 2025 until the date of payment;
2) From the sum of EUR 10.500,00 from 26 July 2025 until the date of payment;
3) From the sum of EUR 4.741,94 from 26 August 2025 until the date of payment;
4) From the sum of EUR 247.258,06 from 25 July 2025 until the date of payment;
5) From the sum of EUR 31.500,00 from 25 July 2025 until the date of payment.”
b. Reply and counterclaim of the Club
15. In its reply to the Player’s claim, the Club argued that the Player terminated the Contract
without just cause on 14 July 2025, acting in bad-faith and against the principle of venire
contra factum proprium.
16. In particular, the Club stated that following the Player’s default notice dated 26 June 2025,
it entered into negotiations with the Player on 9 July 2025 to conclude an agreement to
terminate the Contract and a draft agreement was prepared accordingly. In this respect,
the Club noted that, by 11 July 2025, it reached an agreement with the Player on the
substance of the agreement to terminate the Contract amicably, with the Player merely
requesting minor wording adjustments to be finalized by 14 July 2025. In this context, it is
the position of the Club that the Player abruptly and without justification unilaterally
terminated the Contract without just cause on 14 July 2025.
17. In support of its position, the Club argued that, on the date on which the Player unilaterally
terminated the Contract, i.e., 14 July 2025, there was no outstanding remuneration under
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the Contract, given the wording of the agreement concluded on 11 July 2025 to terminate
the Contract, which provided for the payment of EUR 80,000 on 15 August 2025.
18. In this context, the Club lodged a counterclaim against the Player with the following
requests for relief, quoted verbatim:
“1. To rule that the Claimant terminated the Employment Contract on 14 July 2025 without just
cause.
2. Consequently, to fully reject the Claimant`s Claim.
3. To fully accept the Counter-Claimant`s counterclaim.
4. Therefore, to condemn the Player to pay to the Counter-Claimant the amount of EUR 247,597
(Two Hundred Forty-Seven Thousand Five Hundred and Ninety-Seven Euro) net plus interest at
a rate of 5% per annum on the aforesaid amount for the period between 30 August 2025 until
the date of effective payment.
5. To impose on the Player a six-month restriction on playing in official matches.
6. For the effect of the above, to state that the Player shall be condemned to pay any and all
costs of the present proceedings, if any.
IN THE ALTERNATIVE
1. To partially accept the Claimant`s Claim insofar as to award the Claimant with a
compensation of symbolic nature only.
2. To otherwise reject the Claimant`s Claim.
3. Therefore, to find that no sporting sanctions shall be imposed on the Respondent.
4. For the effect of the above, to state that the Claimant shall be condemned to pay any and all
costs of the present proceedings, if any.”
c. Player’s reply to the Club’s counterclaim
19. In his reply to the Club’s counterclaim, the Player reiterated his initial position, namely that
he terminated the Contract with just cause due to outstanding remuneration.
20. Moreover, the Player acknowledged that negotiations were ongoing with the Club in July
2025 regarding the conclusion of an agreement to terminate the Contract amicably, but
argued that they could fail at any time, as was ultimately the case given the unreasonable
proposals of the Club.
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REF. FPSD-20148
21. In any event, the Player stated that the Club could have at any time pay the outstanding
remuneration under the Contract, which would have prevented him from unilaterally
terminating their employment relationship with just cause.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
22. First of all, the Dispute Resolution Chamber (hereinafter: the Chamber or the 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 30 July 2025 and submitted for decision on
05 March 2026. Taking into account the wording of arts. 32 and 35 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.
23. Furthermore, the Chamber referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations on the Status and Transfer of Players (hereinafter: the Regulations) (July 2025
edition), the Dispute Resolution Chamber is competent to deal with the matter at stake,
which concerns an employment-related dispute with an international dimension between
a Croatian player and a Romanian club.
24. 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
25. 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
26. 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
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the facts, arguments and documentary evidence, which it considered pertinent for
assessing the matter at hand.
i. Main legal discussion and considerations
27. The Chamber then moved to the substance of the matter, and took note of the fact that
the Player and the Club strongly dispute the justice of the early termination of the Contract
by the Player, based on the alleged non-payment of certain financial obligations by the Club
as per the Contract, in accordance with art. 14bis of the Regulations.
28. On one hand, the Chamber acknowledged the position of the Player, according to which
he terminated the Contract with just cause due to outstanding remuneration.
29. On the other hand, the Chamber noted that, according to the Club, the Player terminated
the Contract without just cause, acting in bad-faith and against the principle of venire contra
factum proprium.
30. The Chamber further observed that the Player and the Club also strongly dispute the
conclusion of an agreement to terminate the Contract amicably.
31. In this context, the Chamber acknowledged that its task was to determine, based on the
evidence presented by the parties, (i) whether an agreement to amicably terminate the
Contract was concluded between the Player and the Club; (ii) whether the amounts claimed
by the Player had in fact remained unpaid by the Club; and, if so, (iii) whether the formal
pre-requisites of art. 14bis of the Regulations had been fulfilled.
32. Within this framework, the Chamber first assessed the evidence on file and concluded that
the Player and the Club indeed engaged in exchanges with the intention of exploring a
possible amicable termination of the Contract. However, the Chamber pointed out that
none of these communications resulted in a mutually agreed or duly executed agreement
to terminate the Contract.
33. In addition, the Chamber underlined that any exchanges between the Player and the Club,
specifically including attempts to reach an agreement to terminate the Contract, and any
other similar communications, do not interrupt the 15-day deadline set out in the Player’s
default notice of 26 June 2025. Accordingly, the Chamber concluded that these exchanges
have no bearing on the validity or effect of the default procedure.
34. In continuation, the Chamber 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 he has put the debtor club in default in writing and has granted a
deadline of at least 15 days for the debtor club to fully comply with its financial obligation(s).
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REF. FPSD-20148
35. In the present matter, the Chamber observed that, on 26 June 2025, the Player claimed not
to have received his remuneration under the Contract corresponding to salaries and
accommodation allowances for the period from March to May 2025. The Chamber also
noted that the Player provided written evidence of having put the Club in default
accordingly on 26 June 2025, i.e., at least 15 days before unilaterally terminating the
Contract on 14 July 2025.
36. With the above in mind, the Chamber held that, in the case at hand, the Club bore the
burden of proving that it indeed complied with the financial terms of the Contract
concluded with the Player. In this respect, the Chamber acknowledged the evidence on file
showing that the relevant amounts referred to in the Player’s default notice of 26 June 2025
were only paid by the Club on 16 July 2025, i.e., after the unilateral termination of the
Contract. Accordingly, the Chamber considered that at least two monthly salaries remained
unpaid throughout the default period, and that the Club’s payment after the termination
of the Contract does not alter the assessment of just cause under art. 14bis of the
Regulations.
37. Thus, the Chamber decided that the Player had a just cause to unilaterally terminate the
Contract, based on art. 14bis of the Regulations.
38. Notwithstanding the above, the Chamber acknowledged that the Player’s conduct during
the negotiations with the Club may have reasonably created the impression that an
amicable agreement to terminate the Contract was achievable. However, in the Chamber’s
view, (i) the Player’s behaviour does not negate or undermine the requirements of art. 14bis
of the Regulations; and (ii) the Club should have been diligent to prevent the severe
consequences of the termination of the Contract. In this respect, the Chamber emphasised
the absence of evidence on file indicating that the Player agreed to suspend, extend, or
withdraw the deadline stipulated in his default notice of 26 June 2025.
39. Lastly, the Chamber held that the foregoing finding, i.e., that the Player had just cause to
unilaterally terminate the Contract, necessarily leads to the conclusion that the
counterclaim of the Club is rejected.
ii. Consequences
40. 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.
41. The Chamber observed that the Player’s outstanding remuneration under the Contract at
the time of its termination, coupled with the specific requests for relief of the Player, is
equivalent to the monthly salary for June 2025, i.e., EUR 10,500 net.
42. Taking into consideration the Player’s request, the principle of ne ultra petita, as well as the
constant practice of the Football Tribunal in this regard, the Chamber decided to award the
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REF. FPSD-20148
Player interest at the rate of 5% p.a. on the monthly salary for June 2025 as from 26 July
2025 until the date of effective payment.
43. In addition, the Chamber referred to the principles of ne ultra petita and ne bis in idem, and
accordingly decided to award the Player the outstanding amount of EUR 191.32,
representing the balance of interest on the Club’s delayed payment of salaries and
accommodation allowances for the period from March to May 2025, which were only paid
on 16 July 2025.
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.
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 252,000 net (i.e., the Player’s salaries under the Contract
from July 2025 to June 2027) serves as the basis for the determination of the amount of
compensation for breach of contract.
48. In continuation, the Chamber verified as to whether the Player had signed an employment
contract with another club during the relevant period of time, by means of which he would
have been enabled to reduce his loss of income. According to the constant practice of the
DRC as well as art. 17 par. 1 lit. ii) of the Regulations, such remuneration under a new
employment contract shall be taken into account in the calculation of the amount of
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compensation for breach of contract in connection with the general obligation to mitigate
his damages.
49. Indeed, the Chamber noted that the Player found employment on 26 September 2025 with
the Greek club P.A.E. Levadeiakos until 30 June 2026, under which he is entitled to EUR
74,000 net, i.e., EUR 57,500 net as salaries, EUR 9,000 net as accommodation allowances
and EUR 7,500 as sign-on fee. Therefore, the Chamber concluded that the Player mitigated
his damages in the total amount of EUR 74,000 net.
50. 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.
51. In this respect, the DRC decided to award the amount of additional compensation of EUR
31,500 net, i.e., three times the monthly remuneration of the Player under the Contract.
52. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Chamber decided that the Club must pay the amount of EUR
209,500 net to the Player (i.e., EUR 252,000 net minus EUR 74,000 net plus EUR 31,500 net),
which was to be considered a reasonable and justified amount of compensation for breach
of contract in the present matter.
53. Lastly, taking into consideration the Player’s request, the principle of ne ultra petita, 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 from 25 July 2025
until the date of effective payment.
iii. Compliance with monetary decisions
54. 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.
55. 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.
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56. 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.
57. 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.
58. 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
59. 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.
60. 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.
61. 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 / Counter-Respondent, Stipe Juric, is partially accepted.
2.
The counterclaim of the Respondent / Counterclaimant, CFR Cluj, is rejected.
3.
The Respondent / Counterclaimant must pay to the Claimant / Counter-Respondent the
following amounts:
- EUR 191.32 as outstanding amount;
- EUR 10,500 net as outstanding remuneration plus 5% interest p.a. as from 26 July 2025
until the date of effective payment; and
- EUR 209,500 net as compensation for breach of contract plus 5% interest p.a. as from
25 July 2025 until the date of effective payment.
4.
Any further claims of the Claimant / Counter-Respondent are rejected.
5.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
6.
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.
7.
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.
8.
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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