Acórdão do FIFA, processo FPSD-20159 IBRAHIM_2026-02-19

Data

19/02/2026

Fonte

inside.fifa.com

Labour Disputes

Texto da decisão

REF. FPSD-20159

Decision of the
Dispute Resolution Chamber
passed on 19 February 2026
regarding an employment-related dispute concerning
the player Jibril Ibrahim

COMPOSITION:
Frans DE WEGER (The Netherlands), Chairperson
Khadija TIMERA (Senegal), Member
Dana MOHAMED AL-NOAIMI (Qatar), Member

CLAIMANT / COUNTER-RESPONDENT:
Jibril Ibrahim, Nigeria
Represented by PCN Sportiva

RESPONDENT / COUNTERCLAIMANT:
FCU 1948 Craiova, Romania

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REF. FPSD-20159

I. Facts of the case
1.

The parties to this dispute are:
•
•

the Nigerian player Jibril Ibrahim (hereinafter: the Player or the Claimant / CounterRespondent); and
the Romanian club FCU 1948 Craiova (hereinafter: the Club or the Respondent /
Counterclaimant), affiliated to the Romanian Football Federation (FRF).

On 3 September 2022, the Player, the Club and the Moldovan club Sfintul Gheorghe
concluded a document titled “Definitive transfer agreement” (hereinafter: the Transfer
Agreement), by means of which the Player was transferred to the Club on a definitive basis.
The Club paid EUR 200,000 net as transfer fee.

On 10 October 2022, the Player and the Club entered into an employment contract
(hereinafter: the Contract) valid – in principle - as from 3 October 2022 until 30 June 2024.

In accordance with clause V of the Contract, the Club undertook to pay to the Player inter
alia the following amounts (quoted verbatim):
“V. Consideration for the services performed by the player
1. For the services performed for the period 3rd of October 2022 - 30th of June 2024,
the professional player shall benefit from the following:
i. a signing-on fee of EUR 6,500 (sixthousandfivehundred) net, a one-off payment,
payable in lei, at the official exchange rate of the Romanian National Bank on the day
of the payment, until 3rd of October 2022, subject to the player obtaining the work
authorization and the valid registration of the player with the PFL/RFF, with the Player
having the right to play.
ii. for the period 3rd October 2022-30th June 2023, the professional football player shall
benefit from:
• a monthly net consideration of EUR 4,000 (fourthousand), payable in lei, at the official
exchange rate of the Romanian National Bank on the day of the payment. The date
from which the player is eligible for payment is the date from which the contract is
validly registered with the PFL/RFF and the player has the right to play;
• a match bonus, only for victory, of EUR 500 (fivehundred) net, if the player is in the
starting eleven;

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• the equivalent in lei of 300 EURO (threehundred), on a monthly basis, for
accommodation, the other maintenance expenses, as well as the real estate agency
fees, being exclusively the player’s responsibility. The damages and prejudices to the
accommodation shall be exclusively borne by the player. The accommodation fee shall
only be paid in exchange of a valid renting agreement and only for the duration of the
competition season;
• objective-related bonuses
i. if the team plays in the play-offs and if the player plays in at least 70% of the official
matches, the player shall benefit from a bous of EURO 10,000 (tenthousand);
ii. if the team wins Romania’s Cup and if the player plays in at least 70% of the official
matches, the player shall benefit from a bonus of EUR 10,000 (tenthousand).
Payment of bonuses (match and objective-related) shall be made in lei, at the official
exchange rate of the RNB, in accordance with the legal provisions in force, by bank
transfer or, on a case by case basis, in cash, within 15 (fifteen) working days from the
date the objective is reached.
- one round trip airplane ticket for each year, for the route Bucharest-Abuja (Nigeria)Bucharest, economy class, on condition that the player notifies the club, in writing, at
least 30 days before his intended departure date and provided that the club agrees to
the departure and return dates, the player complies with the return date to the training
sessions and with the health rules and requirements in place. The obligation to have all
the necessary documents for travel (tickets, reservations, visas for stop-overs, etc) falls
entirely on the Player.
(iii) for the period 1st of July 2023-30th June 2024, the professional football player shall
benefit from:
• a monthly net consideration of EUR 5,000 (fivethousand), payable in lei, at the official
exchange rate of the Romanian National Bank on the day of the payment. The date
from which the player is eligible for payment is the date from which the contract is
validly registered with the PFL/RFF and the player has the right to play;
• a match bonus, only for victory, of EUR 500 (fivehundred) net, if the player is in the
starting eleven;

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Clause IX of the Contract established:
“The company has the option to unilaterally extend the validity period of this contract
for 2 (two) years, from 01 July 2024 - 30 June 2026 by means of a written notification,
sent to the RFF/PFL, until 30 May 2024. In case the company takes up the right to extend
the validity period of this contract for 01 July 2024 - 30 June 2026, the parties negotiated
the following financial terms:
a. 30,000 (thirtythousand) EUR net, a bonus for taking up the extension option - payable
only once, within 30 (thirty) days from the date the option was exercised and the valid
registration thereof with the FRF/LPF, in RON, at the official exchange rate of the
Romanian National Bank on the day of the payment.

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b. for the period:
i. 01 July 2024-30 June 2025:
• a monthly net consideration of 6,500 EUR (sixthousandfivehundred) net, payable in
lei, at the official exchange rate of the BNR, on the day of the payment;
• a bonus of 500 EUR (fivehundred) net, only for a win, if the player is in the first eleven;
• if the team plays in the play-offs and if the player plays in at least 70% of the official
matches, the player shall benefit from a bous of EURO 10,000 (tenthousand);
• if the team wins Romania’s Cup and if the player plays in at least 70% of the official
matches, the player shall benefit from a bonus of EUR 10,000 (tenthousand);
• the equivalent in lei of 300 EURO (threehundred), on a monthly basis, for
accommodation.
• one round trip airplane ticket for each year, for the route Bucharest-Abuja (Nigeria)Bucharest, economy class, on condition that the player notifies the club, in writing, at
least 30 days before his intended departure date and provided that the club agrees to
the departure and return dates, the player complies with the return date to the training
sessions and with the health rules and requirements in place. The obligation to have all
the necessary documents for travel (tickets, reservations, visas for stop-overs, etc) falls
entirely on the Player.
i. 01.07.2025-30.06.2026:
• a monthly net consideration of 7,500 EUR (seventhousandfivehundred) net, payable in
lei, at the official exchange rate of the BNR, on the day of the payment;
• a bonus of 500 EUR (fivehundred) net, only for a win, if the player is in the first eleven;
• if the team plays in the play-offs and if the player plays in at least 70% of the official
matches, the player shall benefit from a bous of EURO 10,000 (tenthousand);
• if the team wins Romania’s Cup and if the player plays in at least 70% of the official
matches, the player shall benefit from a bonus of EUR 10,000 (tenthousand);
• the equivalent in lei of 300 EURO (threehundred), on a monthly basis, for
accommodation.

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REF. FPSD-20159

• one round trip airplane ticket for each year, for the route Bucharest-Abuja (Nigeria)Bucharest, economy class, on condition that the player notifies the club, in writing, at
least 30 days before his intended departure date and provided that the club agrees to
the departure and return dates, the player complies with the return date to the training
sessions and with the health rules and requirements in place. The obligation to have all
the necessary documents for travel (tickets, reservations, visas for stop-overs, etc) falls
entirely on the Player.”
6.

Clause X of the Contract stipulated:
“In case, during the performance of this sports-activity contract, the Player wishes to
unilaterally withdraw from this contract, prior to the term for which the contract was
concluded, under art. 1538, the New Civil Code, the parties evaluate in advance the
damages due to the club at the 10.000.000 EURO (tenmillion). This amount is certain,
fixed and due within 30 days from the date on which the Player notifies his intention for
unilateral termination.
When the value for the penal clause was assessed, upon entering into the contract, the
following were taken into account: the individual value of the Professional Player, the
increase of the team’s value, due to the contribution of the Professional Player, as well
as the increase of the player’s individual value by means of the national and
international competitions he took part in.”

On 1 February 2024, the Club notified the Player of the extension of the Contract, effective
from 1 July 2024 until 30 June 2026.

On 26 June 2025, the Club sent the Player a report prepared by its accounting department,
informing him that several amounts had been overpaid and would be compensated with
the amounts due to him. According to this report, issued on 2 June 2025, it was stated that
an error had resulted in an overpayment of EUR 26,242, as the Player should have received
EUR 215,928 for the period from 3 October 2022 to 31 May 2025, but instead received EUR
242,170.

On an unspecified date and on 11 July 2025, the Player and a person named Dragos Enache
exchanged WhatsApp messages regarding a rent payment. The contact informed the
Player that he had until 14 July 2025 to pay the rent for June 2025, failing which he would
have to hand in the key. The Player forwarded these messages to an unidentified person.

10. On 12 July 2025, according to the Club, the Player displayed unsportsmanlike behaviour,
disregarding the instructions of the staff.
11. On 14 July 2025, the Player put the Club in default and requested the payment of EUR
32,500 for the salaries for January, February, March, April, and May 2025. The Player

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granted the Club 15 days to comply with the payment, i.e. until 29 July 2025. In addition,
the Player requested EUR 300 as accommodation allowance for June 2025 within 15 days.
12. Also on 14 July 2025, the Player forwarded a message from an unidentified person to
another unidentified person, in which it was stated that if the first individual did not receive
the money that day, the Player would have to leave the apartment and hand over the keys
the following day.
13. Between 15 and 18 July 2025, the Player was absent from training sessions.
14. On 18 July 2025, the Club replied to the letter, stating that the Player had already been
informed that he had received payments in excess of the amounts due to him under the
Contract. In this respect, the Club alleged that the amounts claimed as outstanding were
not accurate and urged the Player to comply with his obligations under the Contract.
15. Also on 18 July 2025, the Player replied to the Club’s correspondence, rejecting the
assertion that he had been overpaid by EUR 26,242 and the attempt to unilaterally set off
the alleged overpayment against the contractual entitlements owed to him. The Player
noted that the alleged accounting errors made over two years were neither communicated
nor contested during the relevant period, and that the payments had been made
consistently as part of his agreed remuneration package. The Player asserted that the Club
could not withhold his entitlements by citing alleged historic overpayments, particularly
when they resulted from the Club’s own accounting failures and without any proof of bad
faith on his part. The Player also recalled that the Club had failed to pay the accommodation
allowance for June 2025, which had resulted in his eviction, and reiterated the deadline for
payment, under threat of application of art. 14bis of the Regulations on the Status and
Transfer of Players (hereinafter: the Regulations).
16. On 22 July 2025, the Club replied to the Player, stating that it had paid his rent directly and
that his allegation of eviction was a complete misrepresentation demonstrating his bad
faith. In addition, the Club remarked that the Player had been absent from regular training
sessions without providing any justification and requested that he immediately report to
training, warning that failure to do so would lead to disciplinary procedures.
17. On 23 July 2025, the Player replied to the Club, insisting that he had been evicted from his
accommodation due to the Club’s non-payment. In this sense, the Player asserted that the
landlord’s written communications threatening eviction had been forwarded to the Club by
him at the time he received them, but the Club failed to respond. Moreover, the Player
referred to his previous letter and insisted that the Club was in default. In particular, he
argued that his absence from training was directly attributable to the instability caused by
his eviction, which demonstrated the Club’s abusive conduct. In this letter, the Player
requested the amount of EUR 39,000, including the salary for June 2025, the
accommodation allowance for July 2025, and a bonus for winning a match. Lastly, the

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Player reiterated that the deadline was 29 July 2025 and attached several WhatsApp
conversations.
18. On 28 July 2025, the Club sent a letter to the Player summoning him on 29 April (sic) 2025
at 13:00 at the Club’s head office for a hearing concerning his absences.
19. On 30 July 2025, the Player terminated the Contract, citing just cause based on art. 14bis
of the Regulations. The Player alleged that the Club had failed to pay him the salaries from
January to May 2025, a match bonus, and the rent for June and July 2025, and referred to
his previous correspondence.
20. The Player has remained unemployed since the termination of the Contract.

II. Proceedings before FIFA
21. On 31 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
22. In his claim, the Player argued that the parties concluded an employment contract valid
from 3 October 2022 until 30 June 2024, with the Club holding a unilateral option to extend
the contract for two further seasons, i.e. until 30 June 2026, which the Club exercised.
According to the Player, under the extended Contract he was entitled to a monthly salary
of EUR 6,500 for the 2024/25 season and EUR 7,500 for the 2025/26 season, as well as EUR
300 per month for accommodation and a EUR 500 victory bonus if he started in a match
won by the team.
23. The Player alleged that the Club failed to pay his monthly salaries for January to June 2025,
the victory bonus for one match in which he started and the team won, and the rent for
June and July 2025. According to the Player, when he requested payment of the outstanding
amounts, the Club sent a letter dated 26 June 2025 alleging that he had been overpaid by
EUR 26,242 due to accounting mistakes, and that such amount offset the claimed arrears.
24. The Player asserted that these allegations were completely false and, therefore, on 14 July
2025, he placed the Club in default to the email indicated in the FIFA Transfer Matching
System (TMS), granting a 15-day deadline to settle the outstanding salaries and rent.
Nevertheless, he stated that the Club reiterated the alleged overpayment and denied the
existence of overdue amounts.
25. Moreover, the Player maintained that he rejected the Club’s allegations – both the
purported claim of overpayment totalling EUR 26,242 and the attempt to unilaterally setoff said alleged overpayment against the current contractual entitlements owed to him -

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pointing out that the payments had been consistent in amount and timing for over almost
two years and were neither communicated nor challenged during the relevant payment
period. According to the Player, such systematic payments cannot be classified as an
accounting error, and the letter dated 26 June 2025 and the set-offs were invalid.
26. The Player further argued that the Club failed to pay his rent, which led to his eviction,
despite the landlord’s notifications forwarded by him to the Club. The Player submitted
that the Club subsequently accused him of unauthorised absence from training, which he
considered unfounded and aimed at diverting attention from the alleged contractual
breaches.
27. In light of the above, the Player stated that he terminated the Contract with just cause on
30 July 2025, invoking art. 14 and 14bis of the Regulations, based on his eviction – which,
according to the Player, caused him aggravated damages - and the Club’s non-payment.
28. The Player made the following requests for relief:
“44. The Claimant respectfully urges the DRC to award the Claimant the underlisted
reliefs in the present dispute: The breakdown of the Claimant’s relief is as follows:
• Outstanding salary for the month of January 2025 (€6,500) plus 5% interest Per Annum
as from the due date of payment.
• Outstanding salary for the month of February 2025 (€6,500) plus 5% interest Per
Annum as from the due date of payment.
• Outstanding salary for the month of March 2025 (€6,500) plus 5% interest Per Annum
as from the due date of payment.
• Outstanding salary for the month of April 2025 (€6,500) plus 5% interest Per Annum
as from the due date of payment.
• Outstanding salary for the month of May 2025 (€6,500) plus 5% interest Per Annum
as from the due date of payment
• Outstanding salary for the month of June 2025 (€6,500) plus 5% interest Per Annum
as from the due date of payment
• Rent for the month of June 2025 (€300) plus 5% interest Per Annum as from the due
date of payment
• Rent for the month of July 2025 (€300) plus 5% interest Per Annum as from the due
date of payment
• Victory bonus for match which the Claimant started and the team won (€500) plus 5%
interest Per Annum as from the due date of payment
• The sum of €90,000 (Ninety Thousand Euros) being the residual value of the contract
that commenced on the 3rd of October 2022.
• The sum of €45,000 (Forty Five Thousand Euros) as additional compensation for the
eviction of the Claimant caused by the abusive conduct of the Respondent.”

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b. Reply and counterclaim of the Club
29. In its reply, the Club acknowledged that the parties concluded the Contract, which was
extended until 30 June 2026. In this regard, the Club contended that it had paid the EUR
30,000 extension sign-on fee within 30 days of the extension and that, in addition, monthly
amounts had been advanced to the Player by accounting error. Specifically, the Club
mentioned that following an internal audit, undue payments had been identified and
provided evidence in this regard. Accordingly, on 26 June 2025, it had notified the Player
that, pursuant to art. 1617 Romanian Civil Code, it would set off amounts due to the Player
against excess amounts already paid.
30. On this basis, the Club argued that the Player’s claim to financial entitlements for January June 2025 was baseless, as he had already been paid in advance for that period; therefore,
claims for residual value or compensation also lacked foundation.
31. The Club maintained that it had duly fulfilled its payment obligations and that the Player
failed to evidence any abusive conduct by the Club within the meaning of art. 14 of the
Regulations. The Club also submitted that the Player did not follow the procedure of art.
14bis of the Regulations, as he did not have two outstanding salaries at the time of
termination and did not notify the Club granting a 15-day deadline prior to unilaterally
terminating the Contract. The Club argued that the Player directly notified the termination.
32. The Club argued that the Player’s termination constituted a pretext to avoid returning or
compensating advance payments, and that the Player had absented himself without leave
from training sessions and matches. The Club indicated that it had initiated disciplinary
proceedings from 15 July 2025 for absence without leave, supported by internal reports
(including reports dated 14 and 18 July 2025) and the Club’s Internal Regulations. The Club
further alleged that the Player had been absent without leave from 15 July 2025, exceeding
15 consecutive days and showed unsportsmanlike conduct to the technical staff, which, in
the Club’s view, amounted to just cause in favour of the Club to terminate under art. 14 of
the Regulations; additionally, due to uncertainty regarding his return, the Club stated that
it had incurred additional costs to replace the Player.
33. The Club requested that the Player’s claim be dismissed in its entirety, with costs and legal
fees awarded against the Player, and lodged a counterclaim against the Player.
34. In this respect, the Club requested a finding that the Player terminated the Contract
without just cause and sought payment of EUR 10,000,000 as a termination clause agreed
under clause X of the Contract. Alternatively, the Club sought compensation of EUR 581,523
based on (i) the transfer fee it paid for the Player, (ii) the agent’s fee it paid for signing the
Player, (iii) signing-on fees, (iv) match bonuses, (v) rent, (vi) salaries, (vii) taxes on salaries
paid to the state budget and (viii) an amount paid in cash to the Player.

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35. The Club finally requested the sporting sanction of a 4-month suspension on the Player for
termination without just cause under art. 17 of the Regulations.
c. Reply to the counterclaim by the Player
36. In his reply to the counterclaim, the Player maintained his position and rejected the Club’s
arguments.
37. The Player argued that the Club’s assertion - namely, that the Player’s financial entitlements
from January to June 2025 are baseless because those salaries were allegedly already paid
due to an accounting error - is unfounded. The Player submitted that the Club’s attempt to
rely on this alleged error to unilaterally set-off amounts against current entitlements is
improper and reiterated that the alleged accounting errors - spanning nearly two years were never communicated nor challenged by the Club at any time during the payment
period. Furthermore, the Player affirmed that payments were consistent in both amount
and timing, making it impossible to credibly classify them as accounting errors.
38. The Player alleged that the Club failed to pay the rent for June 2025, despite receiving
multiple notifications from both the landlord and the Player. As a result, the Player was
issued a quit notice and subsequently evicted. In this context, the Player submitted that
this behaviour constituted abusive conduct by the Club, thereby establishing just cause
pursuant to art. 14 par. 2 of the Regulations.
39. Moreover, the Player argued that the Club failed to pay more than two monthly salaries
and was properly placed in default through written notice sent on 14 July 2025, granting 15
days to comply, in accordance with art. 14bis of the Regulations. The Club failed to comply,
giving the Player just cause to terminate the Contract.
40. The Player asserted that the alleged absence from training between 15 and 18 July 2025
was directly caused by the Club’s failure to pay rent, which resulted in eviction and made it
impossible for the Player to perform his contractual duties. The Player maintained that the
combination of non-payment of salaries, failure to pay rent, abusive conduct, and the
resulting impossibility to perform duties under the Contract amounts to just cause for
termination under art. 14bis and 14 par. 2 of the Regulations and art. 337(2) of the Swiss
Code of Obligations (SCO).
41. Lastly, the Player requested that the Club’s counterclaim be dismissed entirely, asserting
that the Club engineered the circumstances leading to termination by depriving the Player
of essential elements of the Contract, including six months of unpaid salary and unpaid
rent. The Player further maintain that the Club never denied owing the Player from January
to June 2025 and instead relied on an unsubstantiated allegation of accounting errors.

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III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
42. 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 31 July 2025 and submitted for decision on
19 February 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.
43. 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 Nigerian player and a Romanian club.
44. 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
45. 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 TMS.
c. Merits of the dispute
46. 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.

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i. Main legal discussion and considerations
47. 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 outstanding remuneration and compensation for
breach of contract, and a counterclaim filed by the club against the player for
compensation.
48. In particular, the Chamber observed that, according to the Player, he terminated the
Contract with just cause based on both art. 14 and art. 14bis of the Regulations, as the Club
failed to pay him the salaries from January to June 2025 and failed to pay the rent for June
2025, which led to his eviction.
49. Conversely, the Chamber noted that the Club argued that the Player had been overpaid
and was therefore entitled, under Romanian law, to set off the alleged overpayments
against his salaries. Moreover, the Club claimed that the Player had been absent from
training and had terminated the Contract without just cause.
50. In this context, the Chamber acknowledged that its task was to determine whether the
Player terminated the Contract with just cause and the ensuing consequences. The
Chamber then proceeded to analyse each of these issues in turn.
A. Did the Player have just cause to terminate the Contract?
51. First, the Chamber noted that it remained undisputed that the Club did not pay the Player
several salaries. However, the Chamber observed that the Club provided a justification for
the non-payment, arguing that the Player had been overpaid due to an accounting error
and that it had therefore set off the overpaid amounts against his salaries. The Player
denied the Club’s allegations and argued that he had not been overpaid and that such
alleged overpayments had never been communicated to him nor raised by the Club, which
consistently paid the relevant amounts. In any event, the Player essentially argued that the
Club was not entitled to unilaterally withhold his salaries and perform a set-off with the
alleged overpayments.
52. In this context, the Chamber observed that the Club provided several proofs of payment
demonstrating all the amounts paid to the Player during the entire employment
relationship.
53. Additionally, the Chamber pointed out that, apart from denying the overpayment, the
Player did not raise any objection to any of the proofs provided by the Club, which is why
the Chamber considered them to remain undisputed.
54. After examining all the proofs of payment provided as evidence, the Chamber
acknowledged that the Club paid the Player approximately RON 1,175,500 before he put

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REF. FPSD-20159

the Club in default. Notwithstanding, the Chamber noted that the Club failed to provide the
specific exchange rate applicable to each payment.
55. In this sense, the Chamber observed that, in its counterclaim, the Club referred to the
official exchange rate of the Romanian National Bank of 8 September 2025 but, except for
a link to the bank’s webpage, it failed to provide evidence of the alleged rate. Hence, the
Chamber considered an exchange rate published on the platform customarily employed
by the FIFA general secretariat considering the date of the last payment, i.e. 2 July 2025,
and concluded that this amount was equivalent to EUR 231,382.
56. In addition, considering that (i) during October 2022–June 2023 the Player was entitled to a
monthly salary of EUR 4,000, totalling EUR 36,000, (ii) during July 2023–June 2024 the Player
was entitled to a monthly salary of EUR 5,000, totalling EUR 60,000, (iii) during July 2024–
June 2025 the Player was entitled to a monthly salary of EUR 6,500, totalling EUR 78,000,
(iv) for the entire period (33 months) he was entitled to EUR 300 as accommodation
allowance, totalling EUR 9,900, and (v) he was entitled to EUR 36,500 as signing fee and EUR
2,900 as bonuses, as acknowledged by the Club in its calculations, the Chamber
understood that, by 30 June 2025, the Player should have received a total of EUR 223,300.
Therefore, the Chamber concluded that the Player appears to have indeed been overpaid.
57. In fact, taking into account that the Club itself acknowledged in its calculations that it had
not paid the Player’s salary from December 2024 to May 2025, the Chamber noted that, up
to November 2024, the Club had paid the Player RON 1,153,357 (excluding subsequent
payments for rent), equivalent to EUR 227,023 on 3 March 2025 - the date on which the
Club paid the salary for November 2024. By that point, the Player should have received
approximately EUR 182,200 (also excluding rent). In the eyes of the Chamber, this
demonstrates that the overpayment was even greater than the amount calculated up to
the date of default, as by that moment the Club had already begun withholding several of
the Player’s salaries.
58. Based on the above, and despite acknowledging that there may be nuances in the
calculations due to differing exchange rates and the undetailed and unsorted payments
made by the Club, the Chamber concluded that the Club’s allegations referring to the
overpayment to the Player were supported by documentary evidence, which was not
disputed by the Player.
59. While the Chamber found difficult to believe that an overpayment – based on the Club’s
own calculations – occurred since the first month of the employment relationship and
remained consistent in time and amount (EUR 2,500), even as the Player’s salary increased
each year, the Chamber also noted that the Player did not argue that his actual salary was
higher as part of a verbal – or other – agreement. In addition, the Player did not even claim
that this overpayment created a legitimate expectation that his salary was higher than
contractually stipulated. This is consistent with the fact that, in his notices of default and in
his claim, he only requested salaries and compensation based on the contractually agreed

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REF. FPSD-20159

amounts. In this sense, the Chamber observed that the Player merely denied the
overpayment – and rejected that it was caused by an accounting error – without providing
any further argument, whereas the Club’s position was supported by documentation to
which he raised no challenge.
60. Therefore, despite the Chamber’s doubts regarding the cause of the overpayment, the
Chamber could only conclude that the Player was overpaid.
61. Notwithstanding the above, the Chamber considered that the Club’s position to withhold
the Player’s salary due to this overpayment could not succeed.
62. First, the Chamber noted that the Club only communicated the alleged accounting mistakes
to the Player on 26 June 2025. In the table provided to the Player, the Club calculated the
entire employment relationship and concluded that he had been overpaid by EUR 26,242
for the period 3 October 2022–31 May 2025. Notwithstanding, it was observed that in this
table the Club was already considering its non-payment of the salaries for December 2024
to May 2025 and, only through the non-payment of these months, the alleged overpayment
reached EUR 26,242 – whereas, as established, the overpayment was actually higher.
Moreover, the Chamber noted that, in this communication, the Club further informed the
Player that the total amount allegedly paid in excess would be compensated with the
“amounts due to him”.
63. In this regard, the Chamber acknowledged that the Club retroactively informed the Player
that it would not pay him six salaries that were already due (December 2024–May 2025),
without having previously informed him of any such intention and without evidence that
any issue related to overpayments had been raised with him over the previous two years.
In the Chamber’s opinion, if the overpayments were due to the Club’s own error, this could
not operate to the Player’s detriment, and the Club could not unilaterally decide to withhold
the Player’s entire monthly salary – much less retroactively.
64. It was the opinion of the Chamber that, if the Club truly identified an overpayment, it should
have attempted to reach an agreement with the Player to progressively deduct part of his
salary each month or should have sought other means to obtain reimbursement. It was
not entitled to unilaterally determine that the Player was not entitled to any salary at all,
particularly when the overpayment resulted from its own mistake. Moreover, the Chamber
found that the Club could not argue that these amounts were paid “in advance” while
simultaneously claiming that they were accounting errors and allocating them to specific
months rather than to legitimate advances.
65. In this sense, the Chamber considered that the Club could not withhold several months of
salary to compensate amounts it had incorrectly paid.
66. In fact, following the Club’s logic of withholding salaries for set-off, the Chamber noted that
the overpayment until 31 May 2025, without paying six salaries, was still EUR 26,242.

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REF. FPSD-20159

Considering the Player’s salary of EUR 6,500, it remained unclear to the Chamber whether
the Club intended to withhold his salaries for at least four additional months until the
complete set-off, although it appeared that on 2 July 2025 it paid part of the salary for June.
67. The Chamber stressed that this was not a situation in which the Player received a higher
amount in a specific month and the overpayment was immediately evident; rather, for two
years he consistently received an additional amount from the Club, without any objection
ever being raised.
68. While, based on the jurisprudence of the Football Tribunal, set-off may be accepted in very
specific circumstances, the Chamber considered that it must be mutually agreed by the
parties. While the Club relied on Romanian law and provided an extract from the Romanian
Civil Code, the Chamber noted that national law was not relevant in this context, while also
observing that it remained unclear whether this was the only relevant provision under
Romanian legislation.
69. Based on the above, and even accepting that the Player was overpaid, the Chamber
concluded that the Club was not entitled to unilaterally decide not to pay the Player’s
salaries to effect a set-off and was therefore obliged to comply with the payments as
stipulated in the Contract.
70. Having established the above, the Chamber noted that the Player, on 14 July 2025, put the
Club in default and requested payment of the salaries for January to May 2025, which were
already due, and granted the Club 15 days to remedy the default. As stated above, these
salaries were acknowledged by the Club as unpaid, and the Chamber found that the Club’s
justification could not succeed. While the Club alleged in its counterclaim that the Player
did not send a notice of default and directly terminated the Contract, the Chamber
observed that not only did the Player provide proof of having sent the notices, but the Club
also replied to them, rendering its argument baseless.
71. Moreover, the Chamber highlighted that the Player terminated the Contract on 30 July
2025, i.e. 16 days after having sent the notice of default.
72. In light of the above, and considering that (i) the Club failed to pay the Player at least two
monthly salaries, (ii) the Player put the Club in default and granted it 15 days, and (iii) the
Club did not remedy the default, the Chamber concluded that the Player had just cause to
terminate the Contract based on art. 14bis of the Regulations.
73. Having already established the just cause based on overdue payables, the Chamber
considered it unnecessary to further analyse whether the Club’s conduct was abusive or
whether the Player was evicted from his accommodation to determine whether he had just
cause to terminate the Contract. In addition, and for the sake of completeness, the
Chamber considered that the Player’s absences were not relevant to the analysis, as the
Club did not terminate the Contract on this basis and no disciplinary sanction was imposed.

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REF. FPSD-20159

B. Consequences
74. Having stated that the Player had just cause to terminate the Contract, the Chamber
decided that the Club’s counterclaim against the Player must be rejected in its entirety, as
the Club was not entitled to compensation for breach of contract.
75. Then, the Chamber proceeded to analyse the Player’s requests and noted that he
requested outstanding remuneration and compensation for breach of contract.
1) Outstanding remuneration
76. The Chamber observed that the Player requested the salaries for January until June 2025
as outstanding remuneration.
77. Concerning the salaries for January to May 2025, the Chamber noted that it was undisputed
that they were not paid and, therefore, it decided to award them, plus 5% interest p.a. as
from the day following each due date. Although the Chamber observed that it appeared
that the salaries were paid on the 15th day of the following month, the Chamber also
emphasised that the Contract was silent regarding the due dates for the salaries between
July 2024 and June 2025. Therefore, the Chamber decided to award interest as from the
first day of each following month.
78. Regarding the salary for June 2025, the Chamber observed that the Club provided a bank
statement allocating a payment of RON 10,058 as “June”, which was equivalent to EUR
1,979.79. Since the payment was allocated to June, which, based on the nature and details
of all payments, the Chamber considered to be the salary for June, and the Player did not
raise any objection to it, the Chamber deducted this amount and awarded the Player EUR
4,520.21 for June 2025, with 5% interest p.a. as from 1 July 2025.
79. Since the termination was made on 30 July 2025 and based on the standard practice of the
Football Tribunal, the Chamber considered the salary for July as outstanding remuneration
and decided to award it to the Player with 5% interest p.a. as from the date of termination.
The Chamber remarked that as of 1 July 2025, the Player’s monthly salary was EUR 7,500
instead of EUR 6,500.
80. Concerning the rent for June and July 2025, the Chamber noted that the Club provided
evidence of having paid an amount in June as the Player’s rent to an unidentified person
who, according to the Club, was the landlord. The name of this person matched the name
of the individual with whom the Player exchanged messages, according to the evidence he
provided. However, the Chamber stressed that the Club failed to provide evidence
demonstrating that the payment made in June actually corresponded to the rent for June,
especially considering that, based on the proofs of payment, it made five rent payments

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REF. FPSD-20159

over six months, which was consistent with the Player’s allegations that both the rent for
June and the rent for July remained unpaid.
81. Hence, the Chamber decided to award both rents for June and July 2025 (EUR 300 each),
with 5% interest p.a. as from the day following the first day of each respective month, based
on standard practice of the Football Tribunal.
82. Lastly, the Chamber decided to reject the Player’s claim for the entitlement of the payment
of the alleged bonus, due to the lack of sufficient documentary evidence.
2) Compensation for breach of contract
83. Having stated the above, the Chamber turned to the calculation of the amount of
compensation payable by the Respondent 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.
84. 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 that the Player terminated the Contract with just cause. 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.
85. 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).
86. 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 (i.e., 30 July 2025) until its end date (i.e., 30 June
2026). Consequently, the Chamber concluded that the amount of EUR 82,500 (i.e., eleven
times EUR 7,500) serves as the basis for the determination of the amount of compensation
for breach of contract.
87. 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

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REF. FPSD-20159

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.
88. The Chamber further observed that the Player did not secure new employment following
the termination of the relevant contract. Consequently, no mitigation or additional
compensation applied (cf., art. 17 par. 1 lit. ii) of the Regulations).
89. 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
on said compensation at the rate of 5% p.a. as of 30 July 2025 until the date of effective
payment.
90. Lastly, the Chamber rejected the request of EUR 45,000 as additional compensation for the
eviction of the Player, as, despite several alleged messages via WhatsApp with the landlord,
there was no evidence that this situation effectively occurred.
ii. Compliance with monetary decisions
91. 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.
92. 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.
93. 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.
94. 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.

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REF. FPSD-20159

95. 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
96. 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.
97. 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.
98. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.

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REF. FPSD-20159

IV. Decision of the Dispute Resolution Chamber
1.

The claim of the Claimant / Counter-Respondent, Jibril Ibrahim, is partially accepted.

The counterclaim of the Respondent / Counterclaimant, FCU 1948 Craiova, is rejected

The Respondent / Counterclaimant must pay to the Claimant / Counter-Respondent the
following amounts:
- EUR 45,120.21 as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of EUR 6,500 as from 1 February 2025 until the date
of effective payment;
- 5% interest p.a. over the amount of EUR 6,500 as from 1 March 2025 until the date
of effective payment;
- 5% interest p.a. over the amount of EUR 6,500 as from 1 April 2025 until the date of
effective payment; 5% interest p.a. over the amount of EUR 6,500 as from 1 May 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 6,500 as from 1 June 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 300 as from 2 June 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 4,520.21 as from 1 July 2025 until the date
of effective payment;
- 5% interest p.a. over the amount of EUR 300 as from 2 July 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 7,500 as from 30 July 2025 until the date of
effective payment.
- EUR 82,500 as compensation for breach of contract plus 5% interest p.a. as from 30
July 2025 until the date of effective payment.

Any further claims of the Claimant / Counter-Respondent are rejected.

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REF. FPSD-20159

Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.

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.

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.

This decision is rendered without costs.

For the Football Tribunal:

Emilio García Silvero
Chief Legal & Compliance Officer

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REF. FPSD-20159

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. 24