Labour Disputes
Texto da decisão
REF. FPSD-20493
Decision of the
Dispute Resolution Chamber
passed on 17 November 2025
regarding an employment-related dispute concerning the player Jack
Karadogan
BY:
Andre DOS SANTOS MEGALE, Brazil
CLAIMANT:
Jack Karadogan, Great Britain
Represented by Buruchan Duzgun
RESPONDENT:
Sanliurfaspor, Türkiye
Represented by Korhan Armağan
pg. 2
REF. FPSD-20493
I. Facts of the case
1.
On 8 July 2024, the British player, Jack Karadogan (hereinafter: the Player or the Claimant),
and the Turkish club, Sanliurfaspor (hereinafter: the Club or the Respondent), entered into a
document titled “Additional Protocol” (hereinafter: the Contract), valid for the 2024/2025
season. The Contract included an option for the Club to extend it for 1 year for the
2025/2026 season.
2.
In accordance with the Contract, the Respondent undertook to pay to the Claimant inter
alia a monthly salary of EUR 2,200 net.
3.
As to the dispute resolution mechanism, clause 6 of the Contract established that the
following:
“The disputes arising from the present Contract may be referred by either party to FIFA Federation International Football Association, headquartered in Zurich, Switzerland, as
the competent party for solving any queries arising from this Agreement and Court of
Arbitration for Sports (CAS) as the appeal body. And also player can choose to apply the
TFF bodies too.”
4.
On 10 September 2024, the Club transferred TRY 80,000 to the Player, which, according to
the Club, equals to EUR 2,132,76.
5.
On 16 October 2024, the Club transferred TRY 30,000 to the Player, which, according to the
Club, equals to EUR 805.15.
6.
On 9 November 2024, the Club transferred TRY 25,000 to the Player, which, according to
the Club, equals to EUR 677.50.
7.
On 13 December 2024, the Club transferred TRY 50,000, which, according to the Club,
equals to EUR 1,367.61.
8.
On 22 January 2025, the Club transferred TRY 80,000, which, according to the Club, equals
to EUR 2,173.91.
9.
On 13 February 2025, the Club transferred TRY 80,000, which, according to the Club, equals
to EUR 2,142.47.
10. In accordance with the information retrieved from FIFA Transfer Matching System (TMS),
the season 2024/2025 in Türkiye concluded on 1 July 2025. Similarly, the parties do not
dispute that the Contract was not renewed for the subsequent season.
11. The parties have not submitted any correspondence exchanged between them.
pg. 3
REF. FPSD-20493
II. Proceedings before FIFA
12. On 22 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
13. In his claim, the Player established that he was entitled to a total remuneration of EUR
22,000 under the Contract, of which the Club only paid EUR 9,155. As a result, the Player
claimed that the Club owes the Player the balance of EUR 12,845.
14. The Claimant’s requests for relief were the following:
“5.1. The Claimant would like to request you to make a decision that the Respondent shall
pay 12.845,00 EUR for the unpaid salaries with their interests as clearly stated in the
Contract.
5.2. We request club to be entitled to FIFA diciplinary (sic) measures and consequences
(cf. Article 24 paragraph 7 and Annexe 2, article 8 paragraph 7 of the RSTP) in circle of
FIFA regulations.”
b. Position of the Respondent
15. On 17 September 2025, the Club filed its response to the Player’s claim.
16. In its reply, the Club challenged the jurisdiction of “the FIFA Judicial Bodies” (sic). According
to the Club, the dispute resolution clause added to the Contract was ambiguous. It lacked
legal certainty, as it simultaneously grants jurisdiction to both FIFA and the Turkish Football
Federation's National Dispute Resolution Chamber (hereinafter: the TFF NDRC). In light of
this, the Club argued that the clause was pathological and invalid under Swiss Law and
Turkish Law.
17. Concerning the merits of the dispute, the Club stated that it had “fully and duly complied
with all its contractual obligations” under the Contract. The Club also noted that certain
documents from the previous administrative period were inaccessible due to changes in
the Club’s management but would be made available in due course.
18. The Club then stated that it paid the Player “minimum EUR 9,300.00” (approximately TRY
453,737.79) and that this amount should be credited against the debt.
19. The Club also objected to the commencement dates of interest proposed by the Player,
requesting that interest be calculated from the date on which the claim was filed.
pg. 4
REF. FPSD-20493
20. The Respondent’s requests for relief were the following:
•
“That to decide arbitration clause stipulated under contract is null and void, therefore
FIFA Judicial Bodies are not authorized to solve the dispute,
•
In any cases, that all claims of the Claimant be dismissed in their entirety;
•
In the event that the Tribunal reaches a contrary conclusion, deduct the Payments
made by the Club from the Player’s earnings,
•
In any case we respectfully also request that the claim be dismissed at least in respect
of the unclear interest commencement dates and rule that the interest shall be start
from the date of filing of the claim.”
c. Additional comments from the Claimant
21. On 19 September 2025, the FIFA General Secretariat invited the Player to provide
comments exclusively on the Club's challenge to FIFA's jurisdiction and the alleged
payments.
22. Also on 19 September 2025, the Player filled in his additional comments.
23. In response to the jurisdictional challenge, the Player argued, first, that even if FIFA's
jurisdiction under the Contract were considered optional, this would imply that the Player
had the right to choose it.
24. Second, the Player further added that pursuant to art. 22 of the FIFA Regulations on the
Status and Transfer of Players (hereinafter: the Regulations), disputes of an international
dimension between players and clubs belonging to different associations fall under the
exclusive jurisdiction of FIFA.
25. The Player claimed that, since the present dispute involved parties affiliated with different
associations, and there was no valid and exclusive “national-level jurisdiction clause meeting
with FIFA’s requirements”, the competence lay exclusively with the FIFA Football Tribunal.
26. On the merits, the Player insisted that he had only received EUR 9,155 from the Club. He
argued that the difference of EUR 145 proposed by the Club was seemingly related to the
conversation between the Turkish Lira (TRY) and the Euro (EUR). However, as the Club failed
to justify the conversion rates it used, his initial claim should be upheld.
27. The Player therefore reiterated his requests for relief, detailing the request for interest as
follows:
pg. 5
REF. FPSD-20493
“We request an interest rate of 5% p.a. from the respective due dates until the effective
date of payment. All partial payments made under this contract shall be applied to the
earliest outstanding instalments. Any remaining unpaid amounts shall accrue interest to
be calculated on the most recent outstanding instalments.
➢
➢
➢
➢
➢
➢
1845 EUR net as outstanding remuneration plus 5% interest p.a. as from 1st
February 2025
2200 EUR net as outstanding remuneration plus 5% interest p.a. as from 1st
March 2025
2200 EUR net as outstanding remuneration plus 5% interest p.a. as from 1st
April 2025
2200 EUR net as outstanding remuneration plus 5% interest p.a. as from 1st May
2025
2200 EUR net as outstanding remuneration plus 5% interest p.a. as from 1st June
2025
2200 EUR net as outstanding remuneration plus 5% interest p.a. as from 1st July
2025
Request for relief:
In light of the foregoing, we respectfully request your honorable Chamber:
a) To reject the Respondent s arguments concerning the partial dismissal of the case and
the alleged deduction from the claimed amount.
b) To order the Respondent to pay to the Claimant the outstanding salaries in the amount
of EUR 12,845.00, together with interest at a rate of 5% p.a. as from the above mentioned
respective due dates until the effective date of payment.
c) To order the Respondent to bear the procedural/judicial costs of these proceedings, as
the Claimant was forced to initiate this case due to the Respondent’s default.
d) To declare that, in case of non-compliance with the decision, the Respondent shall be
subject to the disciplinary measures and consequences stipulated under the FIFA
Regulations on the Status and Transfer of Players, in particular Article 24 paragraph 7
and Annexe 2, Article 8 paragraph 7 of the RSTP.”
pg. 6
REF. FPSD-20493
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
28. 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 22 August 2025 and submitted for
decision on 17 November 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.
29. 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 (July 2025 edition), the Dispute Resolution Chamber is in principle competent
to deal with the matter at stake, which concerns an employment-related dispute with an
international dimension between a British player and a Turkish club.
30. Nonetheless, the Single Judge recalled that the Club challenged the jurisdiction of the
Football Tribunal, arguing that clause 2.6 of the Contract is pathological since it grants
jurisdiction to both FIFA and TFF at the same time.
31. The Single Judge noted that the Player, conversely, stated that: (i) even if FIFA's jurisdiction
under the Contract were considered optional, this would imply that the Player had the right
to choose it; (ii) pursuant to art. 22 of the Regulations, disputes of an international
dimension between players and clubs belonging to different associations fall under the
exclusive jurisdiction of FIFA; and (iii) since the present dispute involves parties affiliated
with different associations, and there is no valid and exclusive “national-level jurisdiction
clause meeting with FIFA’s requirements”, the competence lies exclusively with the FIFA
Football Tribunal.
32. In this context, the Single Judge first recalled that, according to art. 22 par. 1, lit. b) of the
Regulations, FIFA is inter alia competent to hear:
“1. Without prejudice to the right of any player, coach, association, or club to seek redress
before a civil court for employment-related disputes, FIFA is competent to hear:
[…]
b) employment-related disputes between a club and a player of an international
dimension; the aforementioned parties may, however, explicitly opt in writing for such
disputes to be decided by a national dispute resolution chamber (NDRC), or a national
dispute resolution body operating under an equivalent name, that has been officially
pg. 7
REF. FPSD-20493
recognised by FIFA in accordance with the National Dispute Resolution Chamber
Recognition Principles. Any such jurisdiction clause must be exclusive and included
either directly in the contract or in a collective bargaining agreement applicable
to the parties.” (emphasis added by the Single Judge).
33. As this dispute has an international dimension (i.e., British player vs. Turkish club) and is
employment-related (i.e., outstanding remuneration under an employment contract), the
Single Judge considered that FIFA’s jurisdiction would only be prevented in the hypothesis
of (1) a clear and exclusive jurisdiction clause in favour of the civil courts; OR (2) a clear and
exclusive jurisdiction clause included or in an applicable CBA in favour of a National Dispute
Resolution Chamber (NDRC) “that has been officially recognised by FIFA in accordance with the
National Dispute Resolution Chamber Recognition Principles”.
34. The Single Judge then found that in order for FIFA to decline its jurisdiction in favour of a
NDRC, the interested party challenging the Football Tribunal’s should demonstrate that the
parties have validly agreed to refer any such dispute to the relevant decision-making body
and that such body is recognised by FIFA. These conditions are cumulative and must all be
met.
35. In the present case, the Single Judge concluded that none of these conditions were fulfilled.
36. First, the Single Judge recalled that clause 2.6 of the Contract contained a provision in
favour of, inter alia, FIFA, as follows:
“The disputes arising from the present Contract may be referred by either party to FIFA
- Federation International Football Association, headquartered in Zurich,
Switzerland, as the competent party for solving any queries arising from this Agreement
and Court of Arbitration for Sports (CAS) as the appeal body. And also player can choose
to apply TFF bodies too.” (emphasis added by the Single Judge)
37. The Single Judge considered that clause 2.6 is not vague or ambiguous, as claimed by the
Club. On the contrary, it clearly grants FIFA jurisdiction to resolve any disputes arising from
the Contract, with the Court of Arbitration for Sport (CAS) serving as the appeal body.
Additionally, it provides the Player with the option to choose the TFF NDRC instead.
38. Accordingly, the Single Judge considered that it is not a clear and exclusive clause to a
decision-making body different than FIFA.
39. Furthermore, the Single Judge also observed that the TFF NDRC is not included in the official
list of recognised NDRCs.
40. For those reasons, the Single Judge decided that the Football Tribunal has jurisdiction over
the Player’s claim.
b. Burden of proof
pg. 8
REF. FPSD-20493
41. 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 TMS.
c. Merits of the dispute
42. 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
43. The Single Judge then moved to the substance of the matter and took note of the fact that
the parties strongly disputed whether there was any outstanding remuneration under the
Contract.
44. The Single Judge recalled that, according to the Player, he was entitled to a remaining
balance of EUR 12,845 under the Contract, calculated as the amount agreed upon by the
parties (EUR 22,000) minus the sum that he had allegedly received from the Club (EUR
9,155).
45. The Single Judge noted that, although the Club initially contended that it had settled the
full debt, it later implicitly acknowledged having evidence of payment of a “minimum of EUR
9,300”.
46. Accordingly, the Single Judge acknowledge that the dispute between the parties centred on
a discrepancy of EUR 155 between their respective calculations.
47. In this respect, the Single Judge noted that, to support its position, the Club submitted
evidence of several payments made to the Player between 10 September 2024 and 13
February 2025, purportedly amounting to a total of EUR 9,299.40.
48. Notwithstanding the foregoing, the Single Judge observed that, as correctly raised by the
Player, the Club failed to provide evidence of the applicable exchange rates used for each
payment. In fact, the Club merely submitted calculations without any supporting
documentation.
pg. 9
REF. FPSD-20493
49. Given that the Club bore the burden of proving compliance with the Contract and it failed
to substantiate its allegations, the Single Judge concluded that the calculations provided by
the Player should prevail. As such, the Single Judge decided to award the Player the full
amount claimed, namely EUR 12,845.
50. Furthermore, considering the Player’s request for relief and the Football Tribunal practice
in similar matters, the Single Judge decided to award him interest on each overdue amount
as from the day following the due date (i.e., the first day of each subsequent month), as
follows:
•
•
•
•
•
•
5% interest for EUR 1,845 from 1 February 2025;
5% interest for EUR 2,200 from 1 March 2025;
5% interest for EUR 2,200 from 1 April 2025;
5% interest for EUR 2,200 from 1 May 2025;
5% interest for EUR 2,200 from 1 June 2025; and
5% interest for EUR 2,200 from 1 July 2025.
ii. Compliance with monetary decisions
51. 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.
52. 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 up to three entire and
consecutive registration periods.
53. 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.
54. 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.
pg. 10
REF. FPSD-20493
55. 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
56. 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.
57. 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.
58. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 11
REF. FPSD-20493
IV. Decision of the Dispute Resolution Chamber
1.
The Football Tribunal has jurisdiction to hear the claim of the Claimant, Jack Karadogan.
2.
The claim of the Claimant, Jack Karadogan, is partially accepted.
3.
The Respondent, Sanliurfaspor, must pay the Claimant the following amount(s):
- EUR 12,845 as outstanding remuneration plus 5% interest p.a. as follows:
-
5% interest p.a. over the amount of EUR 1,845 as from 1 February 2025
until the day of effective payment;
5% interest p.a. over the amount of EUR 2,200 as from 1 March 2025 until
the day of effective payment;
5% interest p.a. over the amount of EUR 2,200 as from 1 April 2025 until
the day of effective payment;
5% interest p.a. over the amount of EUR 2,200 as from 1 May 2025 until the
day of effective payment;
5% interest p.a. over the amount of EUR 2,200 as from 1 June 2025 until the
day of effective payment;
5% interest p.a. over the amount of EUR 2,200 as from 1 July 2025 until the
day of effective payment;
4.
Any further claims of the Claimant are rejected.
5.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
6.
Pursuant to art. 24 of the Regulations on the Status and Transfer of Players, if full payment
(including all applicable interest) is not made within 45 days of notification of this decision,
the following consequences shall apply:
1. The Respondent shall be banned from registering any new players, either nationally or
internationally, up until the due amount is paid. The maximum duration of the ban shall
be of up to three entire and consecutive registration periods.
2. The present matter shall be submitted, upon request, to the FIFA Disciplinary Committee
in the event that full payment (including all applicable interest) is still not made by the
end of the three entire and consecutive registration periods.
7.
The consequences shall only be enforced at the request of the Claimant in accordance
with art. 24 par. 7 and 8 and art. 25 of the Regulations on the Status and Transfer of Players.
pg. 12
REF. FPSD-20493
8.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 13
REF. FPSD-20493
NOTE RELATED TO THE APPEAL PROCEDURE:
According to art. 50 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf., art. 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
Fédération Internationale de Football Association – Legal & Compliance Division
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
pg. 14