Labour Disputes
Texto da decisão
REF. FPSD-20887
Decision of the
Dispute Resolution Chamber
passed on 10 November 2025
regarding an employment-related dispute concerning the player Zach Muscat
BY:
Stijn BOEYKENS (Belgium)
CLAIMANT:
Zach Muscat, Malta
Represented by Enes Simsek
RESPONDENT:
Sanliurfaspor, Türkiye
Represented by Korhan Armağan
pg. 2
REF. FPSD-20887
I. Facts of the case
1.
On 3 February 2025, the Maltese player, Zach Muscat (hereinafter: the Player or the
Claimant) and the Turkish club, Sanliurfaspor (hereinafter: the Club or the Respondent)
entered into an employment contract (hereinafter: the Contract) valid as from 3 February
2025 until 30 June 2025.
2.
According to clause 3 of the Contract, the Player’s monthly salary was established as
“monthly wage.”
3.
On the same day, the parties signed an employment agreement (hereinafter: the
Employment Agreement).
4.
According to its clause 3, the Employment Agreement “governs and consists of the matters
which are included and/or not included in the Turkish Football Federation (‘TFF’) Standard
Contract prepared and signed/to be signed between the parties.
The Parties hereby unconditionally and irrevocably agree and undertake that they will duly
prepare and sign the Standard Contract in Turkey in accordance with the terms set out in this
Agreement and submit it to the TFF for the registration in the 2024/2025 football season.”
5.
According to clause 6 of the Employment Agreement, the parties agreed as follows:
“The Club is obliged to pay the amounts as written below to the Player in return of his services
subject to this Agreement, all payments indicated in the Agreement are to be considered as “NET”
payments.
According to the Turkish Regulations, the Player shall receive monthly legal minimum wage.
Below-given payments include the minimum wage sum and the Club is entitled to deduct the
minimum wage that will be paid to the Player from any of below-given payments.
For 2024/2025 Football Season
•
Net 7,000.-EUR (seven thousand euros) will paid as advance payment on 03.02.2025.
•
Net 28,000.-EUR (twenty-eight thousand euros) in total will be paid as monthly salary by
4 equal installments between March 2025 – June 2025 as net 7,000 EUR per months.
Bonus Payments
•
In the event that the Club is promoted to the Super League, the Club shall pay the Player
25,000.-EUR (twenty-five thousand euros) Super League promotion bonus.
pg. 3
REF. FPSD-20887
•
In the event that the Club qualifies for the play-offs in the 2024/2025 season, the Club
shall pay 15,000.-EUR (fifteen thousand euros) bonus to the Player.
•
Net 5,000.-EUR bonus will be paid if the Player contributes (scores or assists) 5 goals in
official league matches (excluding play-offs, cup etc other competitions) in the 2024/2025
football season. If the Player contributes 5 goals and then contributes a further 5 goals
(for a total of 10 goals), the Club will pay the Player a further 5,000 EUR again. If the Player
contributes 10 goals and then contributes a further 5 goals (for a total of 15 goals), the
Club will pay the Player a further 5,000 EUR again. For the sake of clarity, if the Player
contributes 16 goals in official league matches, the Club will pay the Player bonus as
15,000.-EUR net.
•
3,000-EUR (three thousand euros) net will be paid in tree equal installments, 1000.-EUR
net monthly for accommodation.
All the bonus payments agreed in this Agreement will be calculated according to the ratio (i.e.
according to the pro-rata principle) which can be found by taking into account the time played
by the Player in the official league competitions of the season and then the Player will be entitled
to the said bonus in proportion to the duration of the competitions in which he took part.
All payments indicated in this Agreement are to be considered as net payments
This contract will be valid and binding if the player signs the TFF Standard Player’s Contract and
the aforementioned contract is registered with Turkish Football Federation.”
6.
On 4 February 2025, the Club paid the Player the amount of EUR 5,000.
7.
On 26 March 2025, the Club paid the Player the amount of EUR 6,000.
8.
On 2 September 2025, the Player sent a default notice to the Club requesting EUR 28,000
net as salary that was to be paid as monthly salary in 4 equal instalments of EUR 7,000
between March 2025 and June 2025. The Player gave a 10-day deadline to the Club to
comply with its default.
II. Proceedings before FIFA
9.
On 17 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
10. The Player lodged the present claim requesting overdue payables that arose from the
Employment Agreement.
pg. 4
REF. FPSD-20887
11. The Player alleged that the amount of EUR 28,000 remained outstanding and provided the
following breakdown:
•
”4.000,- EUR as salary of March 2025 which was due on 31.03.2025 (requested from
01.04.2025),
•
7.000,- EUR as salary of April 2025 which was due on 30.04.2025 (requested from 01.05.2025),
•
1.000,- EUR as monthly living expenses of April 2025 which was due on 30.04.2025 (requested
from 01.05.2025),
•
7.000,- EUR as salary of May 2025 which was due on 31.05.2025 (requested from 01.06.2025),
•
1.000,- EUR as monthly living expenses of May 2025 which was due on 31.05.2025 (requested
from 01.06.2025),
•
7.000,- EUR as salary of June 2025 which was due on 30.06.2025 (requested from 01.07.2025),
•
1.000,- EUR as monthly living expenses of June 2025 which was due on 30.06.2025 (requested
from 01.07.2025).”
12. In view of the above, the Player requested the following relief:
“The Claimant respectfully requests from the FIFA Football Tribunal Dispute Resolution Chamber
to:
1. Issue a Proposal to the Respondent Club according to the FIFA regulations and regarding this
present case.
2. Condemn the Respondent Club Şanlıurfaspor Kulübü to pay the overdue amount of EUR
28,000 net to the Claimant with the interests p.a. with the following dates:
• 4.000,- EUR with the 5% interest p.a. from 01.04.2025,
• 7.000,- EUR with the 5% interest p.a. from 01.05.2025,
• 1.000,- EUR with the 5% interest p.a. from 01.05.2025,
• 7.000,- EUR with the 5% interest p.a. from 01.06.2025,
• 1.000,- EUR with the 5% interest p.a. from 01.06.2025,
• 7.000,- EUR with the 5% interest p.a. from 01.07.2025,
• 1.000,- EUR with the 5% interest p.a. from 01.07.2025.
3. Impose appropriate disciplinary sanctions on the Respondent in accordance with Article 12bis
FIFA RSTP, taking into account that the Club has failed to fulfill its written undertaking.
pg. 5
REF. FPSD-20887
4. Order the Respondent to bear the costs of these proceedings, as well as the Claimant’s legal
expenses and attorney’s fees.”
b. Reply of the Respondent
13. In its reply, the Club disputed the validity of the Employment Agreement alleging that this
document does not bear its signature.
14. The Club further alleged that it was “unilaterally drafted by or on behalf of the Claimant
without the consent, signature, or formal approval of the Respondent.” Therefore, according
to the Club the Employment Agreement is not binding, has no legal effect and cannot
support the Player’s claims.
15. In view of the above, the Club argued that the Player’s salary is the minimum wage as
established in the Contract (EUR 700) and the payments already made to the Player shall
not be used as an acknowledgment of debt.
16. The Club also stated that in case the DRC does not accept the above allegations, the Club
requests that the amount already paid be deducted from the total amount. In addition, it
requested that the interest rate shall start running as from the date of that the claim was
submitted.
17. Regarding the accommodation fee requested, the Club reiterated that the Employment
Agreement was unsigned and therefore any claims based on said document shall be
rejected.
18. In view of the above, the Club requested the following relief:
“In view of the foregoing, we respectfully request:
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.”
pg. 6
REF. FPSD-20887
c. Replica of the Claimant
19. The Player denied the Club’s allegations regarding the validity of the Employment
Agreement stating that it bears the Club’s signature and was signed on the same day as the
Contract.
20. The Player further asserted that, based on the proof of payments submitted by the Club,
he received a total of EUR 11,000. Had the Contract been the sole valid document, the
amount payable would have been limited to EUR 3,500 (calculated as 5 × EUR 700). This
discrepancy clearly demonstrates that both documents govern the parties’ employment
relationship.
21. Finally, the Player reiterated his request for relief.
d. Duplica of the Respondent
22. Despite being invited to do so, the Club did not provide its final comments.
pg. 7
REF. FPSD-20887
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
23. 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 17 September 2025 and submitted
for decision on 10 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.
24. 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 Maltese player and a Turkish club.
25. 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
26. 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
27. 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.
pg. 8
REF. FPSD-20887
i. Main legal discussion and considerations
28. The Single Judge then moved to the substance of the matter and took note of the fact that
the parties strongly dispute whether the Employment Agreement is valid and the amounts
that remain outstanding.
29. In this context, the Single Judge acknowledged that his task was to determine the validity
of the Employment Agreement and the amounts that remained outstanding.
30. Regarding the Employment Agreement, the Single Judge noted that the Club disputed its
validity alleging that it does not bear its signature.
31. However, the Single Judge noted that the document submitted by the Player bears the
Club’s duly executed signature, making it unclear why the Club contended that the
document was not signed at all, particularly given that no allegations of forgery had been
raised.
32. Therefore, the Single Judge concluded that the Employment Agreement is valid and binding
as it bears the signature of both parties.
33. Having established the above, the Single Judge moved to the determination of the
outstanding amounts that arose from the Employment Agreement.
34. The Single Judge noted that the Player requested the amount of EUR 28,000 net
corresponding to the following amounts:
“4,000.-EUR as salary of March 2025 which was due on 31.03.2025 (requested from
01.04.2025);
7,000.-EUR as salary of April 2025 which was due on 30.04.2025 (requested from 01.05.2025);
1,000.-EUR as monthly living expenses of April 2025 which was due on 30.04.2025 (requested
from 01.05.2025);
7,000.-EUR as salary of May 2025 which was due on 31.05.2025 (requested from 01.06.2025);
1,000.-EUR as monthly living expenses of May 2025 which was due on 31.05.2025 (requested
from 01.06.2025);
7,000.-EUR as salary of June 2025 which was due on 30.06.2025 (requested from 01.07.2025);
1,000.-EUR as monthly living expenses of June 2025 which was due on 30.06.2025 (requested
from 01.07.2025).”
pg. 9
REF. FPSD-20887
35. In addition, the Single Judge noted that the Club submitted two proofs of payment of EUR
5,000 and EUR 6,000, allegedly corresponding to salary payments. However, the translated
documents do not specify the purpose of these payments. Under the Employment
Agreement, the Player was entitled to EUR 7,000 as an advance payment, EUR 28,000 in
salaries, EUR 3,000 in allowances, and conditional bonuses.
36. Therefore, the total fix amount to be paid by the Club to the Player corresponded to at least
EUR 38,000.
37. The Single Judge determined that the amount of EUR 11,000 should not be deducted from
the total amount claimed, as the Club has failed to discharge its burden of proof to
demonstrate that these payments were made as salary (and not bonuses or advance of
payment for example). Consequently, the EUR 11,000 must remain part of the outstanding
amount.
38. For the sake of completeness, the Single Judge noted that clause 6 of the Employment
Agreement stated that the Club is entitled to deduct the minimum wage from any of the
amounts agreed upon in the Contract. However, the Single Judge considered that this
provision was generic, and the Club did not provide any evidence demonstrating that the
amounts of the Employment Agreement should have been reduced.
39. Consequently, the Single Judge decided to award the amount of EUR 28,000 net to the
Player as salaries and allowances (EUR 25,000 as salaries and EUR 3,000 as allowances).
40. 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 over the amount of EUR 4,000 as from 1 April 2025 until the date of
effective payment;
-
5% interest over the amount of EUR 8,000 as from 1 May 2025 until the date of
effective payment;
-
5% interest over the amount of EUR 8,000 as from 1 June 2025 until the date of
effective payment;
-
5% interest over the amount of EUR 8,000 as from 1 July 2025 until the date of
effective payment.
pg. 10
REF. FPSD-20887
ii. Art. 12bis of the Regulations
41. 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.
42. 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.
43. 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.
44. 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 fourth offense by the Respondent within the last two
years, the Single Judge decided to impose a fine of USD 3,000 on the Respondent in
accordance with art. 12bis par. 4 lit. c) of the Regulations.
45. 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.
iii. Compliance with monetary decisions
46. 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.
47. 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.
48. 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.
pg. 11
REF. FPSD-20887
49. 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.
50. 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
51. 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.
52. 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.
53. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 12
REF. FPSD-20887
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Zach Muscat, is partially accepted.
2.
The Respondent, Sanliurfaspor, must pay the Claimant the following amount(s):
- EUR 28,000 net as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of EUR 4,000 as from 1 April 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 8,000 as from 1 May 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 8,000 as from 1 June 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 8,000 as from 1 July 2025 until the date of
effective payment.
3.
Any further claims of the Claimant are rejected.
4.
A fine in the amount of USD 3,000 is imposed on the Respondent, which must be paid to
FIFA within 30 days of notification of this decision. Such fine must be paid to the
following bank account with a clear reference to the case FPSD-20887:
UBS Zurich
Account number 230-366677.61N (FIFA Players’ Status)
Clearing number 230
IBAN: CH12 0023 0230 3666 7761 N
SWIFT: UBSWCHZH80A
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.
pg. 13
REF. FPSD-20887
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.
8.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 14
REF. FPSD-20887
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. 15