Labour Disputes
Texto da decisão
REF. FPSD-20598
Decision of the
Dispute Resolution Chamber
passed on 20 January 2026
regarding an employment-related dispute concerning the player Aleksandra
Popovic
BY:
Khadija TIMERA (Senegal)
CLAIMANT:
Aleksandra Popovic, Montenegro
Represented by Giorgio Romano
RESPONDENT:
ZNK Split, Croatia
pg. 2
REF. FPSD-20598
I. Facts of the case
1.
On 15 August 2023, the Montenegrin player, Aleksandra Popovic (hereinafter: the Player or
the Claimant) and the Croatian club, ZNK Split (hereinafter: the Club or the Respondent)
entered into an employment contract (hereinafter: the First Contract) valid as from 15
August 2023 until 30 June 2024.
2.
According to the Contract, the Player was entitled to a monthly net salary of EUR 1,000
payable at the “latest on the 15th every next month cash on receipt.”
3.
In addition, the parties agreed that “the Club is responsible for providing daily (7 days a week)
Lunch and Dinner (sportsmanlike healthy nutrition) or to refund the costs the player incl. for
shopping at grocery store or eating out at restaurant) indicated by the club)... up to EUR 150 per
Player per month.”
4.
On 31 August 2023, the parties signed a second employment contract (hereinafter: the
Second Contract) valid for one year.
5.
According to article 4, “The Employee shall commence employment immediately upon
obtaining a work and residence permit, as well as a personal identification number (OIB), and
no later than October 01, 2023.”
6.
According to article 10, “The Employee’s base salary for performing the duties under Article 2
of this Contract amounts to €700.00 gross. The base salary referred to in paragraph 1 of this
Article shall be increased by supplements determined in the Club’s Work and Remuneration
Regulations. The salary and salary supplements specified above shall be paid monthly, no later
than the 30th day of the month, for the previous month.”
7.
On 14 September 2023, the Player filled out the “application for issuance of stay and work
permit.”
8.
On 30 November 2023, the Club sent a letter to the Player stating the following (quoted
verbatim):
“Internal Contract Cancellation from 30.11.2023
Please accept this letter as formal notice that Ženski nogometni Klub Split is canceling its
contract agreement with Aleksandra Popovic, effective from 15.08.2023. We appreciate the
services the football player has provided to date and kindly request the return of all club dressing
equipment received at the start of the season.
WFC Split duties after canceling contract:
- Salary payment for the period 15.08–30.11 to the player's bank account
- Return ticket to home destination
pg. 3
REF. FPSD-20598
-
Club determination documents for next registration
Player duties after canceling contract:
- Return of club dress equipment
- Cancellation of player apartment”
9.
On 30 July 2025, the Player sent a default notice to the Club asking for the payment of the
following amounts within 10 days:
-
EUR 500 for November 2023
EUR 1,000 for December 2023
EUR 1,000 for January 2024
EUR 1,000 for February 2023
EUR 1,000 for March 2024
EUR 1,000 for April 2024
EUR 1,000 for May 2024
EUR 1,000 for June 2024
EUR 1,250 for food expenses.
10. On 14 August 2024, the Club explained that it faced a severe financial crisis at the end of
2023, leading to the former president resigning and cancelling all contracts he had
personally financed, including the Player’s. The Club argued that the former president had
paid her from his own funds, not from the Club’s account. The Club also stated that it
arranged a Croatian residence permit for her, which she never collected, causing
administrative issues. When the new president took over, he offered her a short-term
return with a reduced salary of EUR 500 and accommodation, which she accepted and
played until June 2024.The Club claimed it made several payments to her and that the
former president covered significant amounts personally.
11. On 19 August 2025, the Club sent a letter stating that the former president had offered the
Player an unsigned contract and paid her personally, but after his resignation all such
agreements were cancelled. The Club further argued in its letter that she did not collect
her residence permit and later became irregular in Croatia. When she returned in March
2024, the new president verbally agreed on EUR 800 plus housing, paid her in cash due to
blocked accounts, and claimed to have proof of payments. Finally, the Club stated that the
former president also agreed to contribute EUR 1,000 toward settling what remains owed.
II. Proceedings before FIFA
12. On 14 September 2023, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
pg. 4
REF. FPSD-20598
a. Claim of the Claimant
13. On 29 August 2025, the Player lodged a claim with FIFA for overdue payables.
14. According to the Player, the following amounts remain outstanding:
-
EUR 7,000 corresponding to 7 monthly salaries between December 2023 and June
2024 as well as EUR 700 for the balance of the salary of November 2023.
-
EUR 1,250 for the “costs for food and meals”.
15. In view of the above, the Player requested the following relief (quoted verbatim):
“The Respondent, has to pay to the Claimant, Miss POPOVIC ALEKSANDRA, the amount of
7.700,00 euros as outstanding remuneration, plus 5% interest p.a. on the above sum as follows:
• 5% interest p.a. on the amount of euro 700,00 as from 15 November 2023 until the date
of effective payment;
• 5% interest p.a. on the amount of euro 1.000,00 as from 1 December 2023 until the date
of effective payment;
• 5% interest p.a. on the amount of euro 1.000,00 as from 1 January 2024 until the date of
effective payment;
• 5% interest p.a. on the amount of euro 1.000,00 as from 1 February 2024 until the date
of effective payment.
• 5% interest p.a. on the amount of euro 1.000,00 as from 1 March 2024 until the date of
effective payment.
• 5% interest p.a. on the amount of euro 1.000,00 as from 1 April 2024 until the date of
effective payment.
• 5% interest p.a. on the amount of euro 1.000,00 as from 1 May 2024 until the date of
effective payment.
• 5% interest p.a. on the amount of euro 1.000,00 as from 1 June 2024 until the date of
effective payment.
Plus the Respondent has to pay player, the amount of euros 1.250,00 for meals and food costs.
Sanctions according to article 12bis of the FIFA Regulations on the Status and Transfer of Players
is imposed on the Respondent.”
b. Reply of the Respondent
16. In its reply, the Club merely provided various documents without a written reply.
17. One of the documents provided was titled: “Internal Contract cancellation from 30.11.2023.”
pg. 5
REF. FPSD-20598
c. Replica of the Claimant
18. In view of the termination letter provided by the Club, the Player alleged that she had never
received it, and she never signed or accepted the termination of the Contract.
19. In addition, she argued that the lack of sponsors invoked in the termination letter does not
constitute just cause to terminate a contract under art. 14 of the Regulations.
d. Duplica of the Respondent
20. In its duplica, the Club argued that following the departure of the former president and the
Club’s financial reorganization at the end of 2023, all the employment contracts between
the Club and the players were terminated. The Club argued that “this was a club-wide
measure, not directed at the Claimant.”
21. Finally, the Club claimed the following (quoted verbatim):
“The Respondent has not accused the Claimant; it has stated verified facts.
After the end-2023 reorganization, the club offered renewed cooperation in early 2024. The
Claimant verbally accepted, and compensation terms were agreed verbally with the president.
The club again sought to formalize and settle the matter, but the Claimant refused
communication.
Other players in the same situation reached professional settlements, confirming the
Respondent’s good faith and consistent approach.”
pg. 6
REF. FPSD-20598
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
22. 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 29 August 2025 and submitted
for decision on 20 January 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.
23. 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 Montenegrin player and a Croatian club.
24. 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
25. 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
26. 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.
pg. 7
REF. FPSD-20598
i. Main legal discussion and considerations
27. As a preliminary remark, the Single Judge pointed out that the Player lodged the present
claim seeking outstanding remuneration. However, based on the documentation on file,
the Single Judge observed that the Contract was unilaterally terminated by the Club on 30
November 2024. In addition, the Single Judge took note that two different employment
contracts were submitted before the FIFA Football Tribunal, i.e. the First and the Second
Contract.
28. Accordingly, the Single Judge acknowledged that her task was determine:
(i) which contract shall be taken into account for the determination of the salary;
(II) whether the Club had just cause to terminate the Contract; and
(III) the consequences thereof.
29. In this respect, the Single Judge first noted that the parties had executed two separate
agreements: the First Contract concluded on 15 August 2023 and the Second Contract
signed on 30 August 2023.
30. The Single Judge further observed that the Player claimed the amounts stipulated in the
First Contract, and that the Second Contract does not reference the First Contract nor
indicate that it superseded it.
31. Moreover, the Single Judge noted that the Second Contract specified that the Player’s
annual salary was EUR 700 (as opposed to EUR 1,000 under the First Contract) and included
the provision that “the base salary referred to in paragraph 1 of this Article shall be increased
by supplements determined in the Club’s Work and Remuneration Regulations.”
32. Accordingly, the Single Judge considered that the Second Contract represented the
standard agreement outlining the “base salary”, whereas the First Contract contained the
detailed terms governing the Player’s employment.
33. Additionally, the Single Judge noted that the Club did not contest the amounts claimed by
the Player nor the validity of the contract upon which her claim was based.
34. Consequently, the Single Judge concluded that, although both contracts were valid and
binding as they are duly signed by the parties, it was the First Contract that has to be taken
into account for the determination of the outstanding payments and the compensation.
35. Having established the above, the Single Judge turned her attention to the determination
of just cause and noted that the termination letter sent to the Player on 30 November 2023
did not mention the reason why the contract was terminated. However, the Single Judge
observed that the Club explained in its submission that the reason for the termination was
the lack of funding and the change of the president of the Club.
pg. 8
REF. FPSD-20598
36. In this regard, the Single Judge reminded that art. 14 of the Regulations state that “A
contract may be terminated by either party without consequences of any kind (either payment
of compensation or imposition of sporting sanctions) where there is just cause. In general, just
cause shall exist in any circumstance in which a party can no longer reasonably and in good
faith be expected to continue a contractual relationship.”
37. In view of the above, the Single Judge considered that the termination due to lack of funding
and organizational changes of the Club cannot constitute just cause under art. 14 of the
Regulations. In other words, the termination under these reasons cannot be considered as
a measure of ultima ratio.
38. Consequently, the Single Judge concluded that the Club terminated the Contract without
just cause in breach of art. 14 of the Regulations.
ii. Consequences
39. Having stated the above, the Single Judge turned her attention to the question of the
consequences of such unjustified breach of contract committed by the Respondent.
40. 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 the balance of
the November 2023 salary under the contract, amounting to EUR 700.
41. As a consequence, and in accordance with the general legal principle of pacta sunt servanda,
the Single Judge decided that the Respondent is liable to pay to the Claimant the amounts
which were outstanding under the contract at the moment of the termination, i.e. EUR 700
(the balance of the salary of November 2023).
42. Regarding the request for the amount of EUR 1,250 for the “costs for food and meals”, the
Single Judge noted that the Contract stated that the Player was entitled to a “refund” of such
costs.
43. However, the Single Judge observed that the Player did not provide any supporting
documentation justifying that the amount of EUR 1,250 indeed corresponded to expenses
related to meals. Therefore, the Single Judge decided to reject the request of EUR 1,250.
44. 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 30 November 2023 until
the date of effective payment.
45. Having stated the above, the Single Judge turned to the calculation of the amount of
compensation payable by the Respondent in the case at stake. In doing so, the Single Judge
firstly recapitulated that, in accordance with art. 17 par. 1 of the Regulations, the amount
pg. 9
REF. FPSD-20598
of compensation shall be calculated, in particular and unless otherwise provided for in the
contract at the basis of the dispute, taking into account the damage suffered, according to
the “positive interest” principle, having regard for the individual facts and circumstances of
each case, and with due consideration for the law of the country concerned.
46. In application of the relevant provision, the Single Judge held that she first of all had to
clarify as to whether the pertinent employment contract contained a provision by means
of which the parties had beforehand agreed upon an amount of compensation payable by
the contractual parties in the event of breach of contract. In this regard, the Single Judge
established that no such compensation clause was included in the employment contract at
the basis of the matter at stake.
47. As a consequence, the Single Judge determined that the amount of compensation payable
by the Club to the Player had to be assessed in application of the other parameters set out
in art. 17, par. 1 of the Regulations. In this respect, the Single Judge recalled that, as a
general rule, the compensation to be paid to a player by a club shall be equal to the residual
value of the contract that was prematurely terminated, unless this player signed a new
contract following the termination of his previous contract (cf., art. 17 par. 1 lit. i) of the
Regulations).
48. Bearing in mind the foregoing as well as the claim of the Claimant, the Single Judge
proceeded with the calculation of the monies payable to the Claimant under the terms of
the Contract from the date of its unilateral termination until its end date. Consequently,
the Single Judge concluded that the amount of EUR 7,000 (i.e., December 2023 until June
2024: EUR 1,000 x 7 months) serves as the basis for the determination of the amount of
compensation for breach of contract.
49. In continuation, the Single Judge verified as to whether the Claimant had signed an
employment contract with another club during the relevant period of time, by means of
which she would have been enabled to reduce his loss of income. According to the constant
practice of the Football Tribunal as well as art. 17 par. 1 lit. ii) of the Regulations, such
remuneration under a new employment contract shall be taken into account in the
calculation of the amount of compensation for breach of contract in connection with the
general obligation to mitigate his damages.
50. The Single Judge further observed that the Player did not secure new employment
following the termination of the relevant contract. Consequently, no mitigation or
additional compensation applied (cf., art. 17 par. 1 lit. ii) of the Regulations).
51. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Single Judge decided that the Respondent must pay the amount of
EUR 7,000 to the Claimant (i.e., EUR 1,000 x 7 months), which was to be considered a
reasonable and justified amount of compensation for breach of contract in the present
matter.
pg. 10
REF. FPSD-20598
52. Lastly, 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
on said compensation at the rate of 5% p.a. as of 29 August 2025 until the date of effective
payment.
iii. Compliance with monetary decisions
53. 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.
54. 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.
55. 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.
56. 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.
57. 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
58. 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.
pg. 11
REF. FPSD-20598
59. 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.
60. Lastly, the Single Judge concluded her deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 12
REF. FPSD-20598
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Aleksandra Popovic, is partially accepted.
2.
The Respondent, ZNK Split, must pay to the Claimant the following amounts:
- EUR 700 as outstanding remuneration plus 5% interest p.a. as from 30 November 2023
until the date of effective payment;
- EUR 7,000 as compensation for breach of contract plus 5% interest p.a. as from 29
August 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.
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 13
REF. FPSD-20598
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