Labour Disputes
Texto da decisão
REF. FPSD-20754
Decision of the
Dispute Resolution Chamber
passed on 17 December 2025
regarding an employment-related dispute concerning the Player Nassim
Haouari
COMPOSITION:
Andre DOS SANTOS MEGALE (Brazil)
CLAIMANT:
Nassim Haouari, Tunisia
Represented by Aymen Larguet
RESPONDENT:
Nojoom Alsabria, Libya
pg. 2
REF. FPSD-20754
I. Facts of the case
1.
On 13 January 2025, the Tunisian player Nassim Haouari (hereinafter: the Player or the
Claimant) and the Libyan club Nojoom Alsabria (hereinafter: the Club or the Respondent)
entered into an “Accord Financier” (hereinafter: the Agreement).
2.
According to the Agreement, the Player was entitled to USD 9,000 payable in 3 instalments:
-
The first instalment of USD 5,000,
The second instalment of USD 2,000, and
The third instalment of USD 2,000.
3.
On 27 August 2025, the Player sent a correspondence to the Libyan Football Federation
intended for the Club, requesting that the Club pay the amount of USD 7,000 within 10
days.
4.
In accordance with the information retrieved from the Transfer Matching System (TMS), the
2024/2025 Libyan season ended on 30 June 2025.
5.
In accordance with the information retrieved from TMS, the Player was transferred from
the Club to the Tunisian club Union Sportive Bou Salem, concluding an employment
contract with the latter on 15 September 2025.
II. Proceedings before FIFA
6.
On 9 September 2025, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Claim of the Claimant
7.
The Claimant filed a claim for overdue payables. According to the Player, the parties
concluded an employment contract (i.e., the Agreement) on 13 January 2025 for the season
2024/2025, which finalised on 30 June 2025.
8.
The Player further stated that the Club paid him USD 2,000 but failed to pay the remaining
USD 7,000.
9.
The Player requested the following request for relief:
« 1. Constater la défaillance du Club pour non-paiement de la rémunération contractuelle.
2. Astreindre le Club Al Nojoom Al Sabiria à payer au Joueur la somme de Sept mille dollars
américains (7 000 USD) au titre des arriérés contractuels.
pg. 3
REF. FPSD-20754
3. Condamner le Club au paiement des intérêts de retard au taux annuel de 5 % selon les
termes suivants
- 3000 Dollars Américains majorée d’un intérêt annuel au taux de 5% à compter du 13
Janvier 2025.
- 4000 Dollars Américains majorée d’un intérêt annuel au taux de 5% à compter du 30
Juin 2025.
4. Prononcer, en cas de non-exécution, les sanctions sportives prévues par l’article 12 RSTJ,
incluant l’interdiction d’enregistrer de nouveaux joueurs aux niveaux national et
international. »
Freely translated to English
«1. Acknowledge the Club’s default for non-payment of the contractual remuneration.
2. Order the Club to pay the Player the amount of seven thousand US dollars (USD 7,000)
as outstanding contractual arrears.
3. Condemn the Club to pay late interest at an annual rate of 5% under the following
terms:
USD 3,000 plus annual interest at 5% as from 13 January 2025.
USD 4,000 plus annual interest at 5% as from 30 June 2025.
4. Impose, in case of non-compliance, the sporting sanctions provided for in Article 12 of
the RSTP, including a ban on registering new players at both national and international
levels.”
b. Reply of the Respondent
10. Despite being invited to do so, the Respondent failed to provide its position to the claim.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
11. Firstly, 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 9 September 2025 and submitted
for decision on 17 December 2025. Taking into account the wording of arts. 32 and 34 of
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REF. FPSD-20754
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.
12. 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
a Tunisian player and a Libyan club.
13. 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
14. 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 TMS.
c. Merits of the dispute
15. 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
16. The Single Judge then moved to the substance of the matter, and noted that it concerned
a claim lodged by the Player against the Club for overdue payables arising from the
Agreement.
17. The Single Judge further noted that the Respondent failed to submit its reply to the Player’s
claim.
pg. 5
REF. FPSD-20754
18. In view of the foregoing and in accordance with art. 14 par. 1 and art. 21 par. 1 of the
Procedural Rules, the Single Judge decided that the matter would be assessed solely on the
basis of the documentation contained on file, namely the arguments and evidence
submitted by the Claimant.
19. The Single Judge noted that, although the Agreement indicated a starting date of 13 January
2025, it did not expressly specify an end date. The Single Judge further observed that the
Claimant had submitted evidence demonstrating that he had performed his duties as a
player for the Club. In addition, the Player stated that the Agreement had been concluded
for the 2024/2025 season, which, according to the information retrieved from TMS, ended
on 30 June 2025. The Single Judge also took note that the Player subsequently entered into
a new employment contract with another club on 15 September 2025.
20. In light of the foregoing, and in the absence of any objection from the Club regarding the
end date of the Agreement, the Single Judge concluded that the parties had indeed been
bound by an employment contract valid for the 2024/2025 season, which came to an end
on 30 June 2025.
21. The Single Judge then recalled that the Claimant had requested payment of USD 7,000 in
accordance with the Agreement. He further emphasized that, in the present case, the Club
bore the burden of proving that it had complied with its financial obligations under the
Agreement. However, the Club failed to provide any evidence of such compliance.
22. 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 USD 7,000.
23. In addition, taking into account 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 a rate of 5% p.a. on the outstanding amounts as from 1 July 2025 until the date of
effective payment. In this respect, the Single Judge observed that the Agreement did not
specify any payment dates and that no information or evidence regarding the dates on
which payments should have been made had been provided. Accordingly, the Single Judge
determined that the outstanding amounts were to be considered payable at the latest by
30 June 2025.
ii. Compliance with monetary decisions
24. 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.
pg. 6
REF. FPSD-20754
25. 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.
26. 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.
27. 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.
28. 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
29. 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.
30. 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.
31. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 7
REF. FPSD-20754
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Nassim Haouari, is partially accepted.
2.
The Respondent, Nojoom Alsabria, must pay to the Claimant the following amount(s):
- USD 7,000 as outstanding remuneration plus 5% interest p.a. as from 1 July 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. 8
REF. FPSD-20754
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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