Labour Disputes
Texto da decisão
REF. FPSD-20560
Decision of the
Dispute Resolution Chamber
passed on 2 April 2026
regarding an employment-related dispute concerning the player Odera Peter
Ofornadu
COMPOSITION:
Frans DE WEGER (The Netherlands), Chairperson
Peter LUKASEK (Slovakia), Member
Dana MOHAMED AL-NOAIMI (Qatar), Member
CLAIMANT:
Odera Peter Ofornadu, Nigeria
Represented by Loizos Hadjidemetriou
RESPONDENT:
P. O. Achironas Onisilos, Cyprus
pg. 2
REF. FPSD-20560
I. Facts of the case
1.
2.
3.
The parties to this dispute are:
•
the Nigerian player Odera Peter Ofornadu (hereinafter: the Player or the Claimant);
and
•
the Cypriot club P. O. Achironas Onisilos (hereinafter: the Club or the Respondent).
On 20 December 2023, the Official Gazette of the Republic of Cyprus published a decree
that entered into force on 1 January 2024 concerning the minimum wage law. The decree
set the minimum monthly wage for any employee in the Republic of Cyprus at EUR 1,000
for full-time employment as of 1 January 2024. It also established a minimum monthly wage
of EUR 900 for full-time employees who had not completed six months of continuous
employment with the same employer, with the wage increasing to EUR 1,000 upon
completion of six months of continuous employment. p
From 11 July to 12 July 2024, the Player engaged in WhatsApp communications with a
contact saved as “Leo Agent”, who, based on the Player’s submission, appears to be his
agent (hereinafter: Leo Agent), within a group titled “Odera Group Chat”. During these
exchanges, Leo Agent informed the Player that an offer was available consisting of a
monthly salary of EUR 1,000 plus a housing allowance of EUR 300. Leo Agent subsequently
sent the Player a PDF document consisting of an offer with the header of the Club, for the
2024/2025 season providing 9 monthly salaries of EUR 1,000 and EUR 300 per month for
accommodation allowances, but without the signature of the Club. Based on the Player’s
submission, it seems that the Player returned this offer signed to Leo Agent. Leo Agent
then sent the Player another PDF document titled “Employment Agreement” and
containing the Club’s logo, which the Player allegedly signed and returned to Leo Agent. In
addition, Leo Agent and the Player exchanged further PDF documents during the same
period.
4.
According to the Player, he entered into a document titled “EMPLOYMENT AGREEMENT”
(hereinafter: the Purported Contract), which formalised his employment relationship with
the Club, valid from 1 September 2024 to 30 April 2025. The Purported Contract established
a monthly gross salary of EUR 1,200, equivalent to EUR 1,000 net, and a monthly
accommodation allowance of EUR 300, and it was signed only by the Player.
5.
The Player further submitted another version of the Purported Contract, with the same
duration but providing a monthly gross salary of EUR 180, EUR 150 net and with no
accommodation allowance (hereinafter: the Registered Contract). The Registered Contract
was purportedly signed by both parties, however, the Player alleged that he did not sign it
and that it was forged by the Club.
6.
On 25 July 2024, the Club published a post on Facebook featuring a photograph of the
Player and announcing his acquisition for a one-year term. The post also included
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REF. FPSD-20560
additional personal information about the Player, such as his height and date of birth, and
formally welcomed him to the Club.
7.
On 6 August 2024, the Club published a post on Facebook featuring a photograph of the
Player during a training session.
8.
On 20 August 2024, the Club published a post on Facebook featuring a photograph of the
Player training.
9.
From 16 January 2025 to 20 January 2025, the Player engaged in WhatsApp conversations
with a contact saved as “Efstathios Smyris”, who, according to the Player, is the Secretary
General of the Club (hereinafter: Efstathios Smyris) concerning the payment of outstanding
salaries.
10. On 24 January 2025, the Player exchanged further WhatsApp messages with Leo Agent
regarding attending the Cyprus Football Association (CFA) to collect a copy of his contract,
during which the Player learned that the monthly salary stated in the Registered Contract
amounted to EUR 180 (EUR 150 net).
11. On an unspecified date, the Player exchanged WhatsApp messages with a contact saved as
“Spyros Sport Repr”, who, based on the Player’s submission, appears to be a representative
of the Club (hereinafter: Spyros Sport Representative), asserting that the signature appearing
on the Registered Contract was not his own.
12. On 27 January 2025, the Player exchanged WhatsApp messages with Efstathios Smyris
regarding the collection of the Registered Contract from the CFA. During the same
communications, the Player claimed the outstanding salaries owed to him, and Efstathios
Smyris communicated to the Player that the Club proposed paying EUR 500 that night in
exchange for him signing a mutual termination agreement, with the remaining amount to
be paid one month later.
13. On 14 February 2025, the website “in-cyprus” published a report concerning the arrest of
certain Club officials on suspicion of fraud and contract forgery.
14. On 11 June 2025, the Ministry of Labour and Social Insurance of Cyprus sent a letter to the
CFA, the Pan-Cyprian Footballers’ Association, and the Coaches Association stating that a
player’s contract must not provide for a salary lower than EUR 900 at the commencement
of employment and EUR 1,000 after six months of service, and announcing that inspections
would be carried out to ensure compliance.
15. On the same day, the Cyprus Footballers’ Association published an article reporting that
the Ministry of Labor and Social Insurance ruled that the statutory minimum wage applied
to all professional footballers, irrespective of division or gender. The article stated that the
decision prohibits employment contracts below the minimum wage, revealed the existence
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REF. FPSD-20560
of double and undeclared contracts, and called for investigations and sanctions against
clubs that fail to comply with the law.
16. During the 2024/2025 season, the Player participated in a total of 12 official matches,
starting in every appearance.
II. Proceedings before FIFA
17. On 27 August 2025, the Player filed the claim at hand before FIFA. A summary of the parties’
respective positions is detailed below.
a. Position of the Player
18. According to the Player, the Club was interested in signing him. To that end, a Club
representative contacted the Player’s agent (i.e., Leo Agent) and submitted an offer.
19. The Player alleged that he accepted the offer and sent it to Leo Agent for signature. As per
the Player, the offer terms included: (i) a duration covering the 2024/2025 season; (ii) a
monthly salary of EUR 1,000; and (iii) an accommodation allowance of EUR 300 per month.
20. The Player stated that he signed the offer and returned it to Leo Agent to forward to the
Club. He further stated that, on 12 July 2024, Leo Agent sent him the employment
agreement for signature (i.e., the Purported Contract); he signed it and sent it back to Leo
Agent.
21. The Player alleged that, on 25 July 2024, the Club announced him as a new signing on its
official Facebook page. Following this announcement, he began participating in the Club’s
pre-season training sessions and/or matches from late July 2024 and throughout August
2024. The Player stated that he visited the Club’s offices during pre-season to sign the
Purported Contract in person.
22. The Player argued that the Club failed to pay his salaries and other remuneration on time
and in full.
23. The Player stated that, on 12 January 2025, the Club informed him that, due to budget cuts,
it would terminate their employment relationship. The Player indicated he was willing to
sign a mutual termination agreement provided the Club paid all outstanding amounts,
namely EUR 2,000 for December 2024 and January 2025. According to the Player, the Club
rejected this proposal.
24. The Player added that the Club only offered to pay the salary for December 2024. He
further alleged that he consistently contacted the Club between 16 and 27 January 2025,
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REF. FPSD-20560
to inquire about payment of his outstanding salaries and the issuance of his release
documents, which the Club had allegedly promised to provide.
25. The Player claimed that, on 22 January 2025, he was removed from the Club’s squad list on
Transfermarkt, despite not having signed a termination agreement nor having formally
terminated his contract, and that the Club then stopped allowing him to train and excluded
him from the squad for the remainder of the season.
26. The Player argued that, due to the imminent closing of the transfer window, he had to
remain with the Club until the end of the Purported Contract.
27. The Player stated that the Club registered, before the relevant government authorities and
the CFA, a different version of the contract with different terms, including a monthly salary
of EUR 150 (i.e., the Registered Contract), an agreement he claimed he had never signed,
was never presented with, and never agreed to at any stage of negotiations.
28. The Player submitted that labour regulations in Cyprus changed in January 2024, raising
the minimum monthly salary to EUR 1,000 gross, and that a player cannot be lawfully
remunerated below the nationally mandated minimum wage.
29. The Player further argued that even the Club’s General Secretary (i.e., Efstathios Smyris)
acknowledged that the valid contract was the one he signed with a monthly salary of EUR
1,000 and requested recognition of the Purported Contract rather than the version the Club
presented to the authorities and the CFA, namely the Registered Contract.
30. The Player claimed EUR 5,000 in outstanding salaries for the period from December 2024
through April 2025 (i.e., EUR 1,000 × 5).
31. In light of the above, the Player submitted the following request for relief:
"1. The Claimant requests the FIFA DRC to order the Respondent to pay the Claimant, in
the bank account seen in exhibit 2, the following amounts:
i. EUR 5,000 net, plus legal interest from the date when each payment became due, until
full settlement.”
b. Position of the Club
32. Despite being invited to do so, the Club failed to submit its reply to the claim.
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REF. FPSD-20560
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
33. 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 27 August 2025 and submitted for decision
on 2 April 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.
34. Furthermore, the Chamber referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations on the Status and Transfer of Players (hereinafter: the Regulations) (July 2025
edition), the Dispute Resolution Chamber is competent to deal with the matter at stake,
which concerns an employment-related dispute with an international dimension between
a Nigerian player and a Cyprus club.
35. 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
36. The Chamber recalled the basic principle of burden of proof, as stipulated in art. 13
par. 5 of the Procedural Rules, according to which a party claiming a right on the basis of
an alleged fact shall carry the respective burden of proof. Likewise, the Chamber stressed
the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which it may consider
evidence not filed by the parties, including without limitation the evidence generated by or
within the Transfer Matching System (TMS).
c. Merits of the dispute
37. 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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REF. FPSD-20560
i. Main legal discussion and considerations
38. The Chamber then moved to the substance of the matter and took note of the fact that it
concerned a claim for overdue payables brought by a player against a club.
39. The Chamber recalled that the Player contended that the binding contract was the
employment agreement he had signed on 12 July 2024 (i.e., the Purported Contract), which
provided a monthly salary of EUR 1,000 plus EUR 300 for housing. In this respect, he
asserted that the Club failed to pay him several salaries.
40. The Club did not provide its position on the claim, hence the decision shall be taken based
on the documentation available in the case file (i.e., the statements and documents
presented by the Player) (cf., art. 21 par. 1 of the Procedural Rules).
41. In this context, the Chamber acknowledged that its task was to determine what was the
valid contract and whether the Player was entitled to the amounts claimed.
A. The contractual basis governing the parties’ employment relationship
42. Initially, the Chamber considered that it was undisputed that both parties held an
employment relationship, as proven, inter alia, by the welcome Facebook post of the Club
to the Player and by the statistics published in the official site of the CFA that demonstrate
that the Player made several appearances and played 974 minutes for the Club during the
season 2024/2025.
43. Nevertheless, the Chamber noted that the Player provided two contracts related to this
employment relationship: the Purported Contract and the Registered Contract. In this
context, the Chamber observed the Player’s arguments according to which the Purported
Contract was the document governing the employment relationship - specifically regarding
the stipulated salary - and his signature on the Registered Contract was forged.
44. Based on this, the Chamber decided that it had to determine which contract was valid and,
consequently, which terms governed the employment relationship.
45. First, the Chamber noted that, since the Club failed to reply to the claim, it was undisputed
that the Registered Contract was signed by the Club, which was also not disputed by the
Player. However, the Chamber recalled that the Player argued that, conversely, his
signature on the Registered Contract was forged.
46. At this point, the DRC outlined that FIFA is not a criminal court and therefore possesses
limited investigatory powers to determine the authenticity of documents. Consequently,
the Chamber pointed out that it was incumbent upon the parties to support their claims
with supplementary evidence.
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REF. FPSD-20560
47. Notwithstanding the above, the Chamber noted that the Player did not provide any
evidence of this alleged forgery and/or any supplementary evidence that could support his
position that the Registered Contract had been manipulated. For example, the Player did
not provide an expert report, a forensic analysis of his signature, or any other supporting
documentation to prove that he did not sign this document. In addition, the Chamber did
not find any other handwritten signature of the Player in the file that could be used for
comparison with the signature appearing in the Registered Contract.
48. Based on the above, the Chamber considered that the Player did not discharge his burden
of proving that the signature on the Registered Contract was forged.
49. Having established the above, the Chamber proceeded to determine whether the
Purported Contract was also concluded between the parties and whether this document
could prevail over the Registered Contract, which, in essence, would imply that the Player’s
salary would be the one established in the Purported Contract and not in the Registered
Contract.
50. At this point, the Chamber observed that the Purported Contract was not signed by the
Club, which was not disputed by the Player. However, the Chamber recalled that the
jurisprudence of the Football Tribunal had consistently established that the actual
signature of the contract is not the sole or even a necessary element to determine whether
there was a contract governing an employment relationship. Instead, the validity and the
enforcement of the contract should be established on the basis of a comprehensive
understanding of all the facts and actions taken by the parties within the context of their
relationship.
51. Specifically, (i) the conclusion of a contract can sometimes, in very specific and limited
circumstances, be proved without a formal signature, provided that such proof meets
certain standards of confidence, and (ii) decisions determining that a contractual
relationship was formed, without having a copy of a signed contract on file, must require a
high standard of proof.
52. With the above in mind, the Chamber established that the main legal issue in the present
case concerned the absence of the Club's signature and whether other robust evidence
existed in the case file to establish mutual consent to be governed by the Purported
Contract and not the Registered Contract or evidence of the execution of the terms of the
Purported Contract and not of the terms of the Registered Contract.
53. In the present case, the Chamber observed that the evidence presented by the Player in
favour of his position, namely, that the Purported Contract was the document governing
the employment relationship, was composed of:
•
WhatsApp communications dated 11 and 12 July 2024, in which Leo Agent shared
with him the Purported Contract, which established that his monthly salary
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REF. FPSD-20560
would be EUR 1,000 net and that he would also be entitled to EUR 300 of
accommodation allowances;
•
The offer that the Player received through Leo Agent on 12 July 2024, and that
contained the header of the Club, with its logo, and that stipulated the same
conditions mentioned by Leo Agent;
•
News related to the labour law of Cyprus, which established the minimum wage
at EUR 1,000 as well as labour regulations establishing that this minimum wage
applied to all professionals and workers in Cyprus;
•
Further communications from the Ministry of Labour and Social Insurance of
Cyprus sent a letter to the CFA, the Pan-Cyprian Footballers’ Association, and the
Coaches Association stating that a player’s contract must not provide for a salary
lower than EUR 900 at the commencement of employment and EUR 1,000 after
six months of service.
54. In connection with the above, the Chamber noted that the Player failed to demonstrate
how Leo Agent received the so-called offer or, more importantly, that such offer was ever
issued by the Club. The Player did not submit any evidence indicating the source of the
document and how it was transmitted to Leo Agent. As a result, the origin of the offer
remained entirely unproved for the Chamber.
55. According to the Chamber, this evidentiary gap was further aggravated by the fact that the
alleged offer lacked any signature or confirmation from the Club. Without a signature or
stamp, it was not possible for the Chamber to establish (i) whether the document was
genuinely issued by the Club, (ii) by whom it was allegedly issued, or (iii) whether it was ever
communicated to the Player. Consequently, the offer could not be attributed to the Club
and carried no probative value regarding the terms governing the employment
relationship.
56. Additionally, the Chamber considered it was worth emphasising that the Player failed to
submit any evidence regarding the execution or performance of the Purported Contract he
invoked. By claiming only the salaries from December 2024 to April 2025, the Player
implicitly acknowledged that prior monthly salaries were paid by the Club. Therefore, in
the view of the Chamber, if the Purported Contract truly governed the employment
relationship with a monthly remuneration of EUR 1,000 net, the Player could have easily
provided proof of receipt of such payments for the months he admits having been paid.
The Player, however, failed to produce any such payment evidence, such as bank
statements, receipts, or transfer confirmations.
57. Likewise, the Chamber established that the Player could have provided evidence of the EUR
300 accommodation allowances allegedly due under the Purported Contract. Nevertheless,
the Chamber noted that no documentation was submitted in this regard. Similarly, the
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REF. FPSD-20560
Player had never put the Club in default and/or made an express reference to his monthly
entitlements.
58. Finally, as previously noted, the Chamber recalled that the Player also failed to prove how
Leo Agent received the offer and whether it originated from the Club, combined with the
absence of the Club’s signature, thereby preventing this body from establishing either (i)
that the Purported Contract was ever executed, or (ii) that it effectively governed the
employment relationship.
59. In conclusion, in the view of the Chamber the only fact that the Player proved was the
existence of a contractual relationship, an element that was undisputed. None of the
evidence submitted in favour of the execution of the Purported Contract established the
origin, authenticity, or issuance by the Club of it, nor did it demonstrate performance under
the Purported Contract through proof of salary or allowance payments.
60. Furthermore, the Chamber highlighted that, while the Player referred to Cypriot minimum
wage regulations, the mere fact that the legal minimum salary in Cyprus exceeds the
amount stated in the Registered Contract only indicates a potential breach of labour
legislation by the Club. However, it does not lead to an automatic increase of the Player’s
contractual salary, nor does it suffice to modify the terms of the Registered Contract.
61. Therefore, the Chamber concluded that the Player’s evidence failed to substantiate the
claim that the Purported Contract governed the employment relationship in the manner
alleged or that the Club issued the offer he relies upon. Consequently, the Chamber
established that the Registered Contract should be taken as valid and binding on the
parties.
B. The Player’s entitlement
62. Having stated which was the contract ruling the employment relationship, the Chamber
turned its attention to determine whether the Player was entitled to the amounts claimed
vis-à-vis the Registered Contract.
63. In this regard, the Chamber noted that, in accordance with the practice of the Football
Tribunal, once a player alleged that there were outstanding payables under a contract, and
demonstrated that his claim had a contractual basis, the burden of proof shifts, requiring
the Club to prove that it has indeed paid the salaries in accordance with the provisions of
the said contract. Therefore, the Club bore the burden of proving compliance with all the
terms of the Registered Contract.
64. In the present case, the Chamber observed that the Club failed to respond to the Player’s
claim. As such, it considered that the Club failed with its burden of proof and that, based
on the principle of pacta sunt servanda, the Player was entitled to the amounts claimed, i.e.,
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REF. FPSD-20560
the monthly salaries for the months of December 2024 through April 2025 plus interest
broken down as follows:
•
•
•
•
•
EUR 150 net for the monthly salary of December 2024, plus a 5% p.a. from 1
January 2025 to the date of effective payment;
EUR 150 net for the monthly salary of January 2025, plus a 5% p.a. from 1 February
2025 to the date of effective payment;
EUR 150 net for the monthly salary of February 2025, plus a 5% p.a. from 1 March
2025 to the date of effective payment;
EUR 150 net for the monthly salary of March 2025, plus a 5% p.a. from 1 April
2025 to the date of effective payment; and
EUR 150 net for the monthly salary of April 2025, plus a 5% p.a. from 1 May 2025
to the date of effective payment.
ii. Compliance with monetary decisions
65. 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.
66. In this regard, the Chamber 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.
67. Therefore, bearing in mind the above, the Chamber 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.
68. 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.
69. The Chamber 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.
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d. Costs
70. 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.
71. 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.
72. Lastly, the Chamber concluded its deliberations by rejecting any other requests for relief
made by any of the parties.
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IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Odera Peter Ofornadu, is partially accepted.
2.
The Respondent, P. O. Achironas Onisilos, must pay to the Claimant the following
amount(s):
- EUR 750 net as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of EUR 150 net as from 1 January 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 150 net as from 1 February 2025 until the date
of effective payment;
- 5% interest p.a. over the amount of EUR 150 net as from 1 March 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 150 net as from 1 April 2025 until the date of
effective payment; and
- 5% interest p.a. over the amount of EUR 150 net as from 1 May 2025 until the date of
effective payment.
3.
Any further claims of the Claimant are rejected.
4.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
5.
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.
6.
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.
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7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
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NOTE RELATED TO THE APPEAL PROCEDURE:
According to art. 50 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf., art. 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
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
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