Labour Disputes
Texto da decisão
REF. FPSD-20207
Decision of the
Dispute Resolution Chamber
passed on 22 September 2025
regarding an employment-related dispute concerning the player Odise Roshi
BY:
Angela COLLINS (Australia)
CLAIMANT:
Odise Roshi, Albania
Represented by Arda Zengipeduk
RESPONDENT:
Erzurumspor FK, Türkiye
Represented by Enes Simsek
pg. 2
REF. FPSD-20207
I. Facts of the case
1.
On 13 August 2024, the Albanian player Odise Roshi (hereinafter: the Claimant or the Player)
and the Turkish club Erzurumspor (hereinafter: the Respondent or the Club) concluded an
employment contract (hereinafter: the Contract) valid as from its date of signature until 30
June 2025.
2.
In accordance with the Contract, the Respondent undertook to pay the Claimant a signing
bonus in the amount of EUR 64,000, as well as a monthly salary in the amount of EUR
20,000 from September 2024 to June 2025.
3.
In addition, the Contract read as follows:
“[…] Conditional Payments:
•
•
•
•
•
5.000,-EUR bonus if the Player plays in the first eleven squad in the 10 official league
matches of the first half of the league.
5.000,-EUR bonus if the Player plays in the first eleven squad in the 10 official league
matches of the second half of the league.
10.000,-EUR bonus if the Player scores in total 10 goals or assists in the official league
matches.
10.000,-EUR bonus if the Club qualify for play-off matches
50.000,-EUR bonus if the Club promotes to the Super League at the end of the season.
(If the Club promotes to the Super League via play-off matches the entitlement of the
Player will be 50.000,-EUR) […]
3.2. The aforementioned conditional payments shall be paid by the Club within 30 days after the
end of the relevant season, if the Player is entitled to them. Play-off and promotion to the higher
league bonuses shall be calculated and paid on a pro-rata basis according to the number of
official league games played by the Player in the relevant season. In addition, friendly matches,
cup matches and play-off matches will not be taken into account in the calculation of bonuses
fees.
3.3. If a due date for the above-mentioned amounts falls on a Saturday, Sunday or on a day
officially recognized as a public holiday in Republic of Turkey, then the due date shall be deemed
to be the next working day.
3.4. All payments to be made to the Player shall be NET and the Club shall be responsible for the
full payment of the withholding tax, income tax, stamp tax and any other tax arising from this
contract in accordance with the Turkish tax law legislation in the territory in Turkey. If the Player
is to be held liable and pays any amount to the taxation authorities, the Club will reimburse
such amounts, plus their interests and the damages suffered thereof, if any, within five days
following the receipt of a written request by the Player […]”
pg. 3
REF. FPSD-20207
II. Proceedings before FIFA
4.
On 4 August 2025, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Position of the Claimant
5.
In his claim, the Claimant argued that the Respondent failed to fulfil its financial obligations
under the Contract.
6.
In particular, the Claimant argued that he is entitled to the monthly salaries for May 2025
and June 2025 in the amount of EUR 40,000, as well as bonuses totalling EUR 30,000. In this
regard, the Claimant stated that he started in the first eleven squad in 10 official matches
in the first and second halves of the league, that he contributed to 12 goals in the official
league matches, and that the Respondent qualified for the play-off stage.
7.
The Claimant’s requests for relief were the following:
“1- To accept the claims of Player Odise Roshi,
2- To condemn Respondent to pay outstanding monthly salaries which are;
a. The monthly payment for the month of May EUR 20.000, plus %5 [sic] interest p.a. as from
01.06.2025,
b. The monthly payment for the month of June EUR 20.000, plus %5 [sic] interest p.a. as from
01.07.2025
3- To condemn Respondent to pay EUR 30.000 as outstanding performance related bonuses plus
%5 [sic] interest p.a. as from 31.07.2025,
4- To impose a ban against Respondent from registering any new players, either nationally or
internationally according to Article 24 of FIFA Regulations on the Status and Transfer of Players,
5- To establish that the costs of the present arbitration procedure shall be borne by the
Respondent.”
b. Position of the Respondent
8.
In its reply, the Respondent acknowledged that the Claimant was entitled to EUR 294,000
under the Contract and submitted various proofs of payment in his favour for a total
amount of EUR 234,000. In this regard, the Respondent argued that the Claimant had not
taken into account in his claim the payment of EUR 10,000 dated 25 July 2025.
pg. 4
REF. FPSD-20207
9.
Considering the foregoing, it is the position of the Respondent that the Claimant is in fact
entitled to EUR 60,000.
c. Reaction of the Claimant to the alleged payment
10. The Claimant acknowledged having received a payment of EUR 10,000 from the
Respondent on 25 July 2025.
11. Accordingly, the Claimant amended his requests for relief as follows:
“1- To accept the claims of Player Odise Roshi.
2- To condemn the Respondent to pay the outstanding monthly salaries which are: a. The
remaining monthly payment for the month of May, EUR 10,000, plus 5% interest p.a. as from
01.06.2025. b. The monthly payment for the month of June, EUR 20,000, plus 5% interest p.a. as
from 01.07.2025.
3- To condemn the Respondent to pay EUR 30,000 as outstanding performance-related bonuses,
plus 5% interest p.a. as from 31.07.2025.
4- To impose a ban against the Respondent from registering any new players, either nationally
or internationally, according to Article 24 of the FIFA Regulations on the Status and Transfer of
Players.
5- To establish that the costs of the present arbitration procedure shall be borne by the
Respondent.”
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
12. First of all, the Single Judge of the Dispute Resolution Chamber (hereinafter: the Single Judge)
analysed whether she was competent to deal with the case at hand. In this respect, she
took note that the present matter was presented to FIFA on 4 August 2025 and submitted
for decision on 26 September 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.
13. Furthermore, the Single Judge 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,
pg. 5
REF. FPSD-20207
which concerns an employment-related dispute with an international dimension between
an Albanian player and a Turkish club.
14. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, she 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
15. The Single Judge 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 Single Judge
stressed the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which she 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
16. Having established the competence and the applicable regulations, the Single Judge
entered into the merits of the dispute. In this respect, the Single Judge started by
acknowledging all the above-mentioned facts as well as the arguments and the
documentation on file. However, the Single Judge emphasised that in the following
considerations she will refer only to the facts, arguments and documentary evidence,
which she considered pertinent for assessing the matter at hand.
i. Main legal discussion and considerations
17. The Single Judge then moved to the substance of the matter, and took note of the fact that
it remained undisputed between the parties that the Claimant is entitled to outstanding
remuneration amounting to USD 60,000 under the Contract.
18. In particular, the Single Judge observed that the Claimant’s outstanding remuneration
consists of USD 10,000 as the balance of the monthly salary for May 2025, USD 20,000 as
the monthly salary for June 2025, and USD 30,000 as bonuses.
19. In view of the foregoing and bearing in mind the basic legal principle of pact sunt servanda,
which in essence means that agreements must be respected by the parties in good faith,
the Single Judge decided that the Respondent is held liable to pay the Claimant USD 60,000
deriving from the Contract concluded between the parties.
pg. 6
REF. FPSD-20207
20. In addition, taking into consideration the Claimant’s request as well as the constant practice
of the Football Tribunal in this regard, the Single Judge decided to award the Claimant
interest at the rate of 5% p.a. on the outstanding amounts as follows:
•
EUR 10,000, plus 5% interest p.a. as from 1 June 2025 until the date of effective
payment;
•
EUR 20,000, plus 5% interest p.a. as from 1 July 2025 until the date of effective
payment; and
•
EUR 30,000, plus 5% interest p.a. as from 31 July 2025 until the date of effective
payment.
ii. Compliance with monetary decisions
21. Finally, taking into account the applicable Regulations, the Single Judge 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.
22. In this regard, the Single Judge 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.
23. Therefore, bearing in mind the above, the Single Judge decided that the Respondent must
pay the full amount due (including all applicable interest) to the Claimant within 45 days of
notification of the decision, failing which, at the request of the Claimant, 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 Respondent in accordance with art. 24 par. 2, 4, and 7 of the Regulations.
24. The Respondent shall make full payment (including all applicable interest) to the bank
account provided by the Claimant in the Bank Account Registration Form, which is attached
to the present decision.
25. The Single Judge 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.
pg. 7
REF. FPSD-20207
d. Costs
26. The Single Judge 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 Single Judge decided that no procedural costs were to be
imposed on the parties.
27. Likewise, and for the sake of completeness, the Single Judge recalled the contents of art.
25 par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
28. Lastly, the Single Judge concluded her deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 8
REF. FPSD-20207
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Odise Roshi, is accepted.
2.
The Respondent, Erzurumspor FK, must pay to the Claimant the following amounts:
- EUR 10,000 as outstanding remuneration plus 5% interest p.a. as from 1 June 2025 until
the date of effective payment;
- EUR 20,000 as outstanding remuneration plus 5% interest p.a. as from 1 July 2025 until
the date of effective payment; and
- EUR 30,000 as outstanding remuneration plus 5% interest p.a. as from 31 July 2025 until
the date of effective payment.
3.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
4.
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.
5.
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.
6.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 9
REF. FPSD-20207
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. 10