Labour Disputes
Texto da decisão
REF. FPSD-20363
Decision of the
Dispute Resolution Chamber
passed on 9 December 2025
regarding an employment-related dispute concerning the player Ivan Doric
BY:
Michele COLUCCI, Italy
CLAIMANT:
Ivan Doric, Serbia
Represented by Spf Nezavisnot
RESPONDENT:
FK Igman, Bosnia and Herzegovina
pg. 2
REF. FPSD-20363
I. Facts of the case
1.
On 5 September 2024, the Serbian player Ivan Doric (hereinafter: the Player or the Claimant)
and the Bosnian club FK Igman (hereinafter: the Club or the Respondent) concluded an
employment contract (hereinafter: the Contract) valid as from the date of its signature until
30 June 2025.
2.
Art. 4 of the Contract provided inter alia:
Article 4
(1) For the performance of duties as prescribed by this Contract, the Club commits to paying
the Player a salary in accordance with the provisions of this Contract, the Labor Law, and
the Club's Work Regulations, in the net amount of KM 800 and may increase or decrease
depending on the Club's performance and in accordance with the Club’s regulations but
cannot be changed without a written amendment to this Contract. During salary payment,
the club's finance department is obliged to provide the player with a written statement of
income (payroll). The payment of a player's salary is not public. The club is obliged to pay
the player's salary once a month, no later than the 30th of the month for the previous month
of work.
(…)
(4) The Contracting Parties also determine special allowances as follows: Allowance for the
meal in the amount of KM 200 monthly, and in the event that the club secures participation
in European competitions after the current season, the club undertakes to pay a fee in the
amount of one monthly salary from this article.
3.
Art 2. of the Annex to the Contract provided inter alia:
Article 2
The Basic Contract is supplemented by the following financial conditions: The Club and the
Player have agreed that on behalf of the Basic Contract No. 328-09/24 dated 5 September 2024,
FC Igman Konjic pays the amount of KM 1,000 to the account.
FC Igman Konjic undertakes to pay additional monthly amounts of KM 4,500 so that the player's
total net monthly income will be KM 5,500.
The club undertakes to pay one month's salary in advance to the player Ivan Đoric within 10
days from the moment of signing the contract.
All tax costs will be paid by FC Igman Konjic.”
pg. 3
REF. FPSD-20363
4.
On 3 August 2025, the Claimant put the Respondent in default requesting the following
amounts:
• KM 4,500 net as part of remuneration for April 2025, in accordance with art. 2 of Annex to the
Contract, which was supposed to be paid until 30 May 2025;
• KM 5,500 net as remuneration for May 2025, in accordance with art. 2 of Annex to the Contract,
which was supposed to be paid until 30 June 2025;
• KM 5,500 net as remuneration for June 2025, in accordance with art. 2 of Annex to the Contract,
which was supposed to be paid until 30 July 2025.
5.
Additionally, the Claimant granted a 10-day deadline to the Respondent to remedy the said
default.
II. Proceedings before FIFA
6.
On 15 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
7.
The Claimant lodged a claim for outstanding remuneration.
8.
In his claim, the Claimant argued that despite having put the Respondent in default, it failed
to comply with its financial obligations according to the Contract and the Annex to the
Contract.
9.
Consequently, the Claimant requested (quoted verbatim):
“We kindly request and claim in the following:
To order FC Igman Konjic to pay the football player, Mr. Ivan oric, the amount as follows:
a.KM 4,500 net as part of remuneration for April 2025, in accordance with art. 2, para. 3 of the
Annex to the Basic Contract, which was supposed to be paid on 30 May 2025 with 5% interest
p.a. from 31 May 2025 until the date of effective payment;
b.KM 5,500 net as remuneration for May 2025, in accordance with art. 2, para. 3 of the Annex
to the Basic Contract, which was supposed to be paid on 30 June 2025, with 5% interest p.a.
from 1 July 2025 until the date of effective payment;
c.KM 5,500 net as remuneration for June 2025, in accordance with art. 2 of the Annex to the
Basic Contract which was supposed to be paid until 30 July 2025, with 5% interest p.a. from 31
June 2025 until the date of effective payment”
pg. 4
REF. FPSD-20363
b. Reply of the Respondent
10. In its reply, the Respondent raised a formal objection to the jurisdiction of the FIFA Football
Tribunal. The Respondent maintained that the claim should be dismissed entirely due to
the absence of an international dimension and FIFA’s lack of jurisdiction.
11. The Respondent sustained that the employment relationship was essentially domestic. The
Claimant’s address and bank account are located in Bosnia and Herzegovina, and no
passport was provided to prove foreign citizenship. Therefore, the Player was registered
and treated as a domestic player, which facilitated his engagement with the Club.
12. The Respondent further argued, citing Article 26 of the WWIN League regulations, that even
if the Claimant were Serbian, he would not be considered a foreign player under the
applicable rules, which reads as follows:
“Foreign citizens in terms of the right to play are not considered players who have the
citizenship of any of the countries that were part of the former SFRY (North Macedonia, Serbia,
Montenegro, Croatia and Slovenia), as well as players who have the citizenship of any of the
member states of the European Union, but they remain subject to obligations in accordance
with the provisions of Article 18 of the Regulations on the Registration of Clubs and Players and
the Status and Transfer of Players of the NS/FS BiH.”
13. The Respondent asserted that that the Claimant is attempting to rely on foreign nationality
without presenting any evidence, such as a passport or official registration extract, which
undermines the claim of an international dispute.
14. The Respondent pointed out a contradiction in the claim regarding the Claimant’s
nationality. While the Claimant alleges Serbian citizenship, the claim lists a residential
address in Bosnia and Herzegovina (Bijeljina).
15. The Respondent emphasized that the Claimant’s FIFA Bank Account Registration Form
confirms a bank account in Bosnia and Herzegovina, as shown by the IBAN provided.
16. The Respondent argued that no passport was submitted among the exhibits, which is the
primary document to establish citizenship. Therefore, the alleged international dimension
of the dispute cannot be proven.
17. The Respondent sustained that the Claimant exploited and circumvented applicable
regulations by registering as a domestic player, which facilitated his employment and
contract with the club.
18. The Respondent asserted that that the Claimant now attempts to invoke foreign nationality
without providing any proof, such as a passport or an extract from the COMET system of
the Football Association of Bosnia and Herzegovina.
pg. 5
REF. FPSD-20363
19. The Respondent concluded that the Claimant is domiciled in Bosnia and Herzegovina, with
a registered address in Bijeljina, which further supports the domestic nature of the
employment relationship.
20. Lastly, the Respondent maintained that the alleged international dimension is
questionable and irrelevant, as the employment relationship is predominantly domestic.
c. Rejoinder of the Claimant
21. In his rejoinder, the Claimant argued that the Respondent did not contest the financial
claim, thereby tacitly acknowledging the debt. Any subsequent objections regarding the
financial claim should be considered groundless.
22. The Claimant contended that the only issue in dispute is whether FIFA DRC has jurisdiction
to decide the case.
23. The Claimant sustained that the Contract clearly states he is a Serbian citizen, making him
a foreign player in Bosnia and Herzegovina.
24. The Claimant emphasized that this fact alone proves the international dimension of the
dispute, as a foreign citizen signed an employment contract with a Bosnian club.
25. The Claimant underscored that his profile available in a well-known website specialized in
football statistics confirms his Serbian citizenship, reinforcing his status as a foreign player.
26. The Claimant submitted a copy of his Serbian passport and clarified that he holds no other
citizenship. He argued that the passport number matches the one in the employment
contract, proving the Club knew his nationality when signing him.
27. The Claimant argued that the Club had access to all relevant data on his citizenship and
registration but failed to provide any documents, acting in bad faith.
28. The Claimant added that the competent authorities of Bosnia and Herzegovina issued him
residence permits for the duration of his career there, including the 2024/25 season with
the Club, further proving his foreign status.
29. The Claimant rejected the Respondent’s reliance on Article 26 of the WWIN League
Regulations, stating these rules apply only to the 2025/26 season, while he played for the
Club in 2024/25. Moreover, he argued that these regulations govern competition
conditions, not citizenship.
30. The Claimant contended that the Club’s arguments about his address and bank account do
not prove citizenship, as freedom of movement does not determine nationality.
pg. 6
REF. FPSD-20363
31. The Claimant asserted that the Respondent failed to provide any evidence supporting its
claim that he was not a foreign citizen.
32. The Claimant argued that in employment-related disputes with an international dimension,
FIFA has jurisdiction unless a national independent arbitration tribunal exists that meets
FIFA’s standards. The Respondent failed to prove such a tribunal exists in Bosnia and
Herzegovina.
33. The Claimant concluded that that under Article 2 par. 1 of the Procedural Rules Governing
the Football Tribunal and Article 23 par. 1 in combination with Article 22(b) of FIFA
Regulations on the Status and Transfer of Players, the FIFA DRC is competent to decide this
case.
34. Lastly, the Claimant requested (quoted verbatim):
“We kindly request the FIFA DRC to decide as follows::
a. FIFA Tribunal (FIFA DRC) has jurisdiction to decide in this case;
b. The claim of the Claimant, Mr. Ivan Đoric, dated 15 August 2025, is accepted in its entirety;”
d. Final comments of the Respondent
35. Despite being invited to submit its final comments, the Respondent did not provide them
within the time limit given by the FIFA general secretariat.
pg. 7
REF. FPSD-20363
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
36. First of all, the Single Judge of the Dispute Resolution Chamber (hereinafter: the Single Judge)
analysed whether he was competent to deal with the case at hand. In this respect, he took
note that the present matter was presented to FIFA on 15 August 2025 and submitted for
decision on 9 December 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.
37. 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,
which concerns an employment-related dispute with an international dimension between
an nationality player and a nationality club.
38. Nonetheless, the Single Judge recalled that the Respondent challenged the jurisdiction of
FIFA to deal with the present matter, arguing that the dispute lacks an international
dimension.
39. The Single Judge noted that, conversely, the Claimant asserted that the claim has an
international dimension, as he is a citizen of Serbia and the Club is from Bosnia and
Herzegovina.
40. Therefore, the Single Judge determined that his task was to analyse whether the dispute
has international dimension.
41. In this regard, the Single Judge referred to the Commentary on the Regulations on the
Status and Transfer of Players (hereinafter: the Commentary) (2023 edition, p. 444), which
defines the notion of international disputes between clubs and players as follows:
“(…) An employment-related dispute between a club and a player is generally deemed to have
an international dimension whenever the player is of a nationality other than that of the country
in which their club is domiciled. This means that, for example, an employment-related dispute
between a Brazilian player and a Brazilian club will not normally fall within
FIFA’s jurisdiction, whereas an employment-related dispute between a Brazilian player and a
Malaysian club will normally fall within FIFA’s jurisdiction. In other words, contrary to standards
that may apply under international private laws, it is not the domicile of the player that is
decisive, but only their nationality.
(…)
pg. 8
REF. FPSD-20363
In summary, a dispute between a player and a club is deemed to be international
whenever the player and the club are of different nationalities. If the player holds dual
nationality, the dispute will be deemed to have an international dimension if the player is
registered by their club under their “foreign” nationality (e.g. a Brazilian/Italian player playing
for a Brazilian club is registered to play as an Italian). This is because players registered as
locals as a result of their “shared” nationality with the club cannot be deemed to be
international players. By the same token, the DRC has established that, for independent
countries which have more than one member association of FIFA incorporated within their
territory, there was no international element for players who were nationals of those
countries.”
(emphasis added by the Single Judge)
42. The Single Judge noted that the Respondent based its challenged mainly on the Claimant’s
residential address.
43. The Single Judge also observed that the Respondent provided evidence and relied on article
26 of the WWIN League regulations, that even if the Claimant were Serbian, he would not
be considered a foreign player under the applicable rules. This article read as follows:
“Foreign citizens in terms of the right to play are not considered players who have the
citizenship of any of the countries that were part of the former SFRY (North Macedonia, Serbia,
Montenegro, Croatia and Slovenia), as well as players who have the citizenship of any of the
member states of the European Union, but they remain subject to obligations in accordance
with the provisions of Article 18 of the Regulations on the Registration of Clubs and Players
and the Status and Transfer of Players of the NS/FS BiH.”
44. In this context, the Single Judge noted that the league’s regulations provided by the
Respondent referred to the “right to play” only and not citizenship. Moreover, based on the
Contract, the Single Judge observed that it was clear that the parties are from different
nationalities: while the Player is from Serbia, the Club is from Bosnia and Herzegovina.
45. Notwithstanding the above, the Single Judge referred again to the Commentary and to the
jurisprudence of the Football Tribunal and pointed out that regardless of the rules
established by the WWIN League regarding the registration of players from Serbia, the key
element to establish whether this dispute has an international dimension is to determine
if the parties share nationality.
46. The Single Judge further noted that the mens legis of the relevant provision is to safeguard
the parties’ access to justice and ensure fair proceedings, particularly where the relevant
events – and the employment relationship as a whole – took place in a
foreign jurisdiction. The Chamber also recalled that this protective purpose is distinct from
pg. 9
REF. FPSD-20363
considerations related to eligibility for participation in a specific competition, as invoked by
the Respondent in the present matter.
47. The Single Judge stressed that based on the Contract it is clear that the parties do not share
the same nationality, regardless of any benefit he may have received in relation to foreign
player quotas.
48. In view of the above, and based on the evidence on file, the Single Judge concluded that
this is a matter of international dimension and that, therefore, he had jurisdiction to decide
on the matter.
49. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, he 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
50. 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 he 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
51. 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 he will refer only to the facts, arguments and documentary evidence, which
he considered pertinent for assessing the matter at hand.
i. Main legal discussion and considerations
52. The Single Judge then moved to the substance of the matter and took note of the fact that
the Claimant argued that despite having put the Respondent in default it failed to comply
with the payment of KM 15,500 net arising from both the Contract and the Annex to the
Contract.
53. The Single Judge observed that, based on the evidence on file, the Respondent only
challenged FIFA’s jurisdiction and did not address the Claimant’s claim for the outstanding
pg. 10
REF. FPSD-20363
remuneration. In this regard, the Single Judge considered that, by not addressing the
claimed amounts requested by the Claimant, the Respondent did not discharge its burden
of proving that it paid the claimed amount.
54. Therefore, the Single Judge determined that that the Respondent shall be liable to pay the
Claimant his outstanding remuneration.
55. Having stated the above, the Single Judge turned his attention to the question of the
consequences of such unjustified breach of contract committed by the Respondent.
56. The Single Judge observed that the outstanding remuneration at the time of termination,
coupled with the specific requests for relief of the Player, is equivalent to three salaries for
the months of April, May and June 2025 under the Contract, amounting to KM 15,500 net.
57. As a consequence, and in accordance with the general legal principle of pacta sunt servanda,
the Single Judge decided that the Respondent was liable to pay to the Claimant the
amounts which were outstanding under the contract at the moment of the termination, i.e.
KM 15,500 net.
58. 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 from the due dates until the
date of effective payment.
ii. Art. 12bis of the Regulations
59. The Single Judge then referred to art.12bis par. 2 of the Regulations, which stipulates that
any club found to have delayed a due payment for more than 30 days without a prima facie
contractual basis may be sanctioned, in accordance with art. 12bis par. 4 of the Regulations.
60. To this end, the Single Judge confirmed that the Claimant put the Respondent in default of
payment of the amounts sought, which had fallen due for more than 30 days, and granted
the Respondent with at least 10 days to cure such breach of contract.
61. Accordingly, the Single Judge also confirmed that the Respondent had delayed a due
payment without a prima facie contractual basis. It followed that the criteria enshrined in
art. 12bis of the Regulations were met in the case at hand.
62. The Single Judge further established that, by virtue of art. 12bis par. 4 of the Regulations
the Single Judge has competence to impose sanctions on the club. On account of the above,
and bearing in mind that this is the first offense by the Respondent within the last two
years, the Single Judge decided to impose a warning on the Respondent in accordance with
art. 12bis par. 4 lit. a) of the Regulations.
pg. 11
REF. FPSD-20363
63. The Single Judge also highlighted that a repeated offence will be considered as an
aggravating circumstance and lead to more severe penalty, in accordance with art. 12bis
par. 6 of the Regulations.
iii. Compliance with monetary decisions
64. 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.
65. 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.
66. 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.
67. 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.
68. 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.
d. Costs
69. 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.
70. 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.
pg. 12
REF. FPSD-20363
71. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 13
REF. FPSD-20363
IV. Decision of the Dispute Resolution Chamber
1.
The Football Tribunal has jurisdiction to hear the claim of the Claimant, Ivan Doric.
2.
The claim of the Claimant, Ivan Doric, is partially accepted.
3.
The Respondent, FK Igman, must pay to the Claimant the following amount(s):
- KM 15,500 net as outstanding remuneration plus 5% interest p.a. as follows:
-
5% interest p.a. over the amount of KM 4,500 net as from 31 May 2025 until the date of
effective payment;
-
5% interest p.a. over the amount of KM 5,500 net as from 1 July 2025 until the date of
effective payment;
-
5% interest p.a. over the amount of KM 5,500 net as from 31 July 2025 until the date of
effective payment.
4.
Any further claims of the Claimant are rejected.
5.
A warning is imposed on the Respondent.
6.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
7.
Pursuant to art. 24 of the Regulations on the Status and Transfer of Players, if full payment
(including all applicable interest) is not made within 45 days of notification of this decision,
the following consequences shall apply:
1. The Respondent 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.
8.
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.
pg. 14
REF. FPSD-20363
9.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 15
REF. FPSD-20363
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. 16