Labour Disputes
Texto da decisão
REF. FPSD-20762
Decision of the
Dispute Resolution Chamber
passed on 22 December 2025
regarding an employment-related dispute concerning the player
El Mahdi Bellaaroussi
BY:
Andre DOS SANTOS MEGALE (Brazil)
CLAIMANT:
El Mahdi Bellaaroussi, Morocco
Represented by Slim Boulesnam
RESPONDENT:
El Soqour, Libya
Represented by Muah Tashani
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REF. FPSD-20762
I. Facts of the case
1.
On 14 September 2023, the Moroccan player El Mahdi Bellaaroussi (hereinafter: the
Claimant or the Player) and the Libyan club El Soqour (hereinafter: the Respondent or the
Club) concluded an employment contract (hereinafter: the Contract) valid as from its date
of signature until 30 July 2024.
2.
In accordance with the Contract, the Respondent undertook to pay the Claimant an
advance payment of USD 20,000 upon signing the Contract, as well as a monthly salary of
USD 2,000 payable at the end of each month.
3.
On 1 January 2025, the Claimant put the Respondent in default and requested payment
within 15 days of his outstanding remuneration under the Contract.
4.
On 26 April 2025, the Claimant put the Respondent in default and requested payment
within 15 days of his outstanding remuneration under the Contract.
5.
On 5 August 2025, the Claimant put the Respondent in default and requested payment
within 10 days of USD 20,000, corresponding to the monthly salaries from October 2023 to
July 2024.
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.
In its claim, the Claimant argued that the Respondent failed to fulfil its financial obligations
under the Contract.
8.
In this context, the Claimant requested payment from the Respondent of the following
outstanding amounts:
•
USD 2,000, i.e., the monthly salary for October 2023, plus 5% interest p.a. as from 1
November 2023;
•
USD 2,000, i.e., the monthly salary for November 2023, plus 5% interest p.a. as from
1 December 2023;
•
USD 2,000, i.e., the monthly salary for December 2023, plus 5% interest p.a. as from
1 January 2024;
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REF. FPSD-20762
•
USD 2,000, i.e., the monthly salary for January 2024, plus 5% interest p.a. as from 1
February 2024;
•
USD 2,000, i.e., the monthly salary for February 2024, plus 5% interest p.a. as from
1 March 2024;
•
USD 2,000, i.e., the monthly salary for March 2024, plus 5% interest p.a. as from 1
April 2024;
•
USD 2,000, i.e., the monthly salary for April 2024, plus 5% interest p.a. as from 1 May
2024;
•
USD 2,000, i.e., the monthly salary for May 2024, plus 5% interest p.a. as from 1 June
2024;
•
USD 2,000, i.e., the monthly salary for June 2024, plus 5% interest p.a. as from 1 July
2024; and
•
USD 2,000, i.e., the monthly salary for July 2024, plus 5% interest p.a. as from 1
August 2024.
b. Reply of the Respondent
9.
In its reply, the Respondent argued that the Claimant is only entitled to USD 13,500 as
outstanding remuneration under the Contract.
c. Replica of the Claimant
10. In his replica, the Claimant reiterated that he is entitled to USD 20,000 as outstanding
remuneration under the Contract and that, consequently, his requests for relief remained
unchanged.
d. Duplica of the Respondent
11. In its duplica, the Respondent reiterated that the Claimant is only entitled to USD 13,500
as outstanding remuneration under the Contract.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
12. 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
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REF. FPSD-20762
note that the present matter was presented to FIFA on 9 September 2025 and submitted
for decision on 22 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.
13. 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 Moroccan player and a Libyan club.
14. 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
15. 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
16. 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
17. The Single Judge then moved to the substance of the matter and took note of the fact that
the parties strongly dispute the payment of certain financial obligations by the Respondent
as per the Contract.
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REF. FPSD-20762
18. On one hand, the Single Judge took note of the position of the Player, according to which
he is entitled to payment by the Club of USD 20,000 under the Contract, i.e., the monthly
salaries from October 2023 to July 2024.
19. On the other hand, the Single Judge recalled that, according to the Club, the Player is only
entitled to USD 13,500 as outstanding remuneration under the Contract.
20. In this context, the Single Judge acknowledged that his task was to determine, based on
the evidence presented by the parties, whether the claimed amounts had in fact remained
unpaid by the Respondent and, if so, whether the latter had a valid justification for not
having complied with its financial obligations.
21. In the case at hand, the Single Judge first noted that the Respondent bore the burden of
proving that it indeed complied with the financial terms of the Contract concluded between
the parties. Nonetheless, the Single Judge observed that the evidence provided by the
Respondent does not prove the payment of the amounts claimed as outstanding by the
Claimant. Furthermore, the Single Judge highlighted that no reasonable justification was
presented by the Respondent for not having complied with the terms of the Contract.
22. The Single Judge further recalled, for the sake of completeness, the content of art. 13 par.
5 of the Procedural Rules, which stipulates that the party asserting a fact bears the burden
of proving it. In this respect, the Single Judge observed that the Respondent failed to
provide sufficient evidence to support its position that the Claimant’s outstanding
remuneration under the Contract amounts to USD 13,500 rather than the USD 20,000
claimed by the Claimant.
23. In view of the foregoing and bearing in mind the basic legal principle of pact sunt servanda,
which in essence means that agreements must be respected by the parties in good faith,
the Respondent is held liable to pay the Claimant the outstanding amounts deriving from
the Contract, namely USD 20,000 as the outstanding monthly salaries from October 2023
to July 2024.
24. 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 follows:
•
5% interest p.a. over the amount of USD 2,000 as from 1 November 2023 until the
date of effective payment;
•
5% interest p.a. over the amount of USD 2,000 as from 1 December 2023 until the
date of effective payment;
•
5% interest p.a. over the amount of USD 2,000 as from 1 January 2024 until the date
of effective payment;
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REF. FPSD-20762
•
5% interest p.a. over the amount of USD 2,000 as from 1 February 2024 until the
date of effective payment;
•
5% interest p.a. over the amount of USD 2,000 as from 1 March 2024 until the date
of effective payment;
•
5% interest p.a. over the amount of USD 2,000 as from 1 April 2024 until the date of
effective payment;
•
5% interest p.a. over the amount of USD 2,000 as from 1 May 2024 until the date of
effective payment;
•
5% interest p.a. over the amount of USD 2,000 as from 1 June 2024 until the date of
effective payment;
•
5% interest p.a. over the amount of USD 2,000 as from 1 July 2024 until the date of
effective payment; and
5% interest p.a. over the amount of USD 2,000 as from 1 August 2024 until the date
of effective payment.
•
ii. Art. 12bis of the Regulations
25. 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.
26. 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.
27. 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.
28. 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 second offense by the Respondent within the last two
years, the Single Judge decided to impose a reprimand on the Respondent in accordance
with art. 12bis par. 4 lit. a) of the Regulations.
29. 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.
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REF. FPSD-20762
iii. Compliance with monetary decisions
30. 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.
31. 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.
32. 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.
33. 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.
34. 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
35. 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.
36. 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.
37. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
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REF. FPSD-20762
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, El Mahdi Bellaaroussi, is accepted.
2.
The Respondent, El Soqour, must pay to the Claimant the following amount:
- USD 20,000 as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of USD 2,000 as from 1 November 2023 until the date
of effective payment;
- 5% interest p.a. over the amount of USD 2,000 as from 1 December 2023 until the date
of effective payment;
- 5% interest p.a. over the amount of USD 2,000 as from 1 January 2024 until the date of
effective payment;
- 5% interest p.a. over the amount of USD 2,000 as from 1 February 2024 until the date
of effective payment;
- 5% interest p.a. over the amount of USD 2,000 as from 1 March 2024 until the date of
effective payment;
- 5% interest p.a. over the amount of USD 2,000 as from 1 April 2024 until the date of
effective payment;
- 5% interest p.a. over the amount of USD 2,000 as from 1 May 2024 until the date of
effective payment;
- 5% interest p.a. over the amount of USD 2,000 as from 1 June 2024 until the date of
effective payment;
- 5% interest p.a. over the amount of USD 2,000 as from 1 July 2024 until the date of
effective payment; and
- 5% interest p.a. over the amount of USD 2,000 as from 1 August 2024 until the date of
effective payment.
3.
A reprimand is imposed on the Respondent.
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.
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REF. FPSD-20762
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
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REF. FPSD-20762
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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