Labour Disputes
Texto da decisão
REF. FPSD-21010
Decision of the
Dispute Resolution Chamber
passed on 24 November 2025
regarding an employment-related dispute concerning the player Joni Kauko
BY:
André DOS SANTOS MEGALE (Brazil)
CLAIMANT:
Joni Kauko, Finland
Represented by Jyri Paasonen
RESPONDENT:
Inter Kashi, India
pg. 2
REF. FPSD-21010
I.
Facts of the case
1.
On 5 August 20254, the Finnish player, Joni Kauko, (hereinafter: the Player or the Claimant)
and the Indian club, Inter Kashi, (hereinafter: the Club or the Respondent) entered into an
employment contract (hereinafter: the Contract) valid as from 5 August 2024 until 31 May 2025.
2.
Art. 1 of Schedule 1 to the Contract provided, quoted verbatim:
“
1. For the period from 05 August 2024 to 31 May 2025, the Club shall pay to the Player a
total fixed sum of EUR 83500/- (being Euro Eighty-Three Thousands and Five
Hundreds only) (the "Fee") which shall be paid in equal monthly instalments, from 05
August 2024 to 31 May 2025, on or before the 7th (seventh) day of the subsequent month
after the month for which the payment is being made, and the last instalment will be paid
in the last week of 31 May 2025.
2. The Fee thus payable will be a "Gross Payment", inclusive of the applicable withholding
taxes such as TDS (at 10%), but not inclusive of any indirect taxes such as GST (at 18%).
3. The Club retains its right to pay the Fees either in EUR or its equivalent amount in INR
(Indian Rupees), calculated in approximates based on mid-market rates. Further, each
instalment of the Fee, as mentioned herein above, shall be paid after the obligations are
performed and not in advance.
4. For the sake of clarity, the illustration below indicates the salary structure for the Player.
Payment Type
Payment Amount
Year 1 (from 05 August 2024 to 31 May 2025)
Gross Payment (Invoice Value)
EUR 83,500 per year
Net Payment (Paid to Bank)
EUR 75,150 per year
5. Notwithstanding anything to the contrary contained herein this Agreement, the Club shall
be entitled to make deductions from the Fee for provision of facilities by the Club that the
Player is not explicitly entitled to in this Agreement and the same shall be in accordance
with the Club Policy, at the Club's sole discretion.
6. The Player shall provide the Club with timely invoices for payment of each installment.
7. It is acknowledged that 10% of the Fee relates to the sponsorship and promotional
activities being performed in accordance with the terms of this Agreement.
8. The Fee also includes the payment for the Player Identification and the use of image
rights of the Player for the Term, mentioned in this Agreement, and it is hereby stated that
the Player shall not be entitled to any extra remuneration for the Player Identification.
pg. 3
REF. FPSD-21010
3.
Art. 3 of Schedule 1 to the Contract provided, quoted verbatim:
“3. Bonus:
3. 1. The Player may receive a bonus only if awarded by the Club at the Club's sole
discretion.
3.2 Notwithstanding anything contained herein, the Club agrees to pay the following
Bonuses through the course of this Contract.
3.2.1 The Club agrees to pay to the Player a fixed Bonus of EUR 230/- only (being Euro
Two Hundred and Thirty only) for every Goal scored by the Player ("Goal Bonus")
in any Match of any Competitions of the Club (except for any Friendlies and/or nonCompetitive Matches).
3.2.2. The Club agrees to pay to the Player a fixed Bonus of EUR 230/- only (being
Euro Two Hundred and Thirty only) for every goal Assisted by the Player ("Assist
Bonus") in any Match of any Competitions of the Club (except for any Friendlies and/or
non-Competitive Matches).
3.2.3 The Club agrees to pay to the Player a fixed Bonus of EUR 230/- only (being Euro
Two Hundred and Thirty only) for every Point secured by the Club ("Points
Bonus") in the main League Competition in which the Club participates in a particular
Season.
3.2.4 The Club agrees to pay to the Player a fixed Bonus of EUR 23,000/- only (being
Euro Twenty-Three Thousands only) as Championship Bonus if and only if the
Club secures First (1st) position at the conclusion of the 2024/25I-League
season("the League Competition")”
3.3. The Bonus mentioned above in Clause 3 are inclusive of any direct taxes such as
TDS (at 10%) but exclusive of any indirect taxes, such as GST (at 18%), if applicable. “
4.
On 9 August 2025, the Player, through his legal representative, sent a notice of default via email
to the Club stating that it had outstanding monthly salaries and bonuses amounting to EUR
45,937. The Player granted the Club a deadline of 10 days to remedy its default and proceed
with payment.
5.
On 13 September 2025, the Player, through his legal representative, emailed the Club stating
that he had not been paid the amounts claimed in his notice of default.
pg. 4
REF. FPSD-21010
II. Proceedings before FIFA
6.
On 24 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 Player asserted that the Club has failed to pay several monthly salaries and bonuses. In
particular the salaries of April and May 2025, amounting to EUR 15,087.
8.
The Player also claimed EUR 9,400 as performance bonuses, as follows, quoted verbatim:
1.Win (3 pts) –EUR 600(Schedule I)
2.Win (3 pts) + 3 assists –EUR 1,200(Schedule I)
3.Draw (1 pt) –EUR 200(Schedule I)
4.Draw (1 pt) + 1 assist –EUR 400(Schedule I)
5.0 pts –EUR 0
6.Win (3 pts) + 1 goal –EUR 800(Schedule I)
7.Win (3 pts) + 1 goal –EUR 800(Schedule I)
8.0 pts (injury) –EUR 0
9.Win (3 pts) (injured) –EUR 600(Schedule I)
10.0 pts (injured) –EUR 0
11.Draw (1 pt) –EUR 200(Schedule I)
12.Win (3 pts) –EUR 600(Schedule I)
13.0 pts –EUR 0
14.Win (3 pts) + 1 goal –EUR 800(Schedule I)
15.Draw (1 pt) –EUR 200(Schedule I)
16.Win (3 pts) –EUR 600(Schedule I)
17.0 pts –EUR 0
18.Win (3 pts) + 1 assist –EUR 800(Schedule I)
19.Draw (1 pt) –EUR 200(Schedule I)
20.Win (3 pts) –EUR 600(Schedule I)
21.Draw (1 pt) –EUR 200(Schedule I)
22.Win (3 pts) –EUR 600(Schedule I)
9.
The Player also claimed EUR 20,000 as a Championship bonus, EUR 600 as a Super cup
bonus, EUR 540 as an agreed reimbursement of expenses.
10. The Player therefore made the following request for relief, quoted verbatim:
“The Claimant respectfully requests the DRC to:
1. Order the Respondent to pay the Claimant the amount of EUR 45,937 representing outstanding
salaries and bonuses.
2.Order the Respondent to pay interest of 5% p.a. on the outstanding amounts as from the
respective due dates until effective payment.
3. Impose appropriate sporting sanctions against the Respondent in case of continued noncompliance, in accordance with Article 12bis(4) RSTP”
pg. 5
REF. FPSD-21010
b. Position of the Respondent
11. On 23 October 2025, the Club submitted that they made three payments to the Player.
12. The first on 1 October 2025 of INR 1,495,687 which it said was equivalent to EUR 14,380, the
second on 23 October 2025 of INR 72,055 which it said was equivalent to EUR 717, and the
third also on 23 October 2025 of INR 1,122. The Club provided evidence of each payment.
c. Further comments of the Claimant on alleged payments
13. On 29 October 2025, the FIFA general secretariat invited the Player to confirm whether he had
received the amounts the Club alleged having pay.
14. On the same day, the Player submitted that it had received the amounts paid by the Club but
maintained that EUR 30,540 remained outstanding, broken down as follows:
Match performance bonuses (22 games) – EUR 9,400
Championship bonus – EUR 20,000
Super Cup match bonus – EUR 600
Agreed expense reimbursement – EUR 540
pg. 6
REF. FPSD-21010
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
15. 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 24 September 2025 and submitted for decision
on 24 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.
16. 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), he is
competent to deal with the matter at stake, which concerns an employment-related dispute with
an international dimension between a Finnish player and an Indian club.
17. 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
18. 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
19. 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. 7
REF. FPSD-21010
i. Main legal discussion and considerations
20. The Single Judge then moved to the substance of the matter, and noted that it concerned a
claim by the Player against the Club for outstanding remuneration arising from his Contract,
including two monthly salaries, individual and collective performance bonuses as well as a
reimbursement of expenses.
21. In this regard, the Single Judge first noted that the Player had initially alleged that the Club had
failed to pay him his remuneration for the months of April and May 2025, however, he observed
that in the course of the proceedings, the Player acknowledged the receipt of a payment from
the Club covering these two monthly salaries.
22. The Single Judge then moved to the substance of the matter and took note that, notwithstanding
the foregoing, the Player maintained his claim for outstanding match bonuses valued at
EUR 9,400 and team performance bonuses amounting to EUR 20,600 for a total of EUR 30,000
outstanding.
23. The Single Judge recalled the wording of art. 3 of Schedule 1 of the Contract, quoted verbatim:
“3. Bonus:
3. 1. The Player may receive a bonus only if awarded by the Club at the Club's sole
discretion.
3.2 Notwithstanding anything contained herein, the Club agrees to pay the following
Bonuses through the course of this Contract.
3.2.1 The Club agrees to pay to the Player a fixed Bonus of EUR 230/- only (being Euro
Two Hundred and Thirty only) for every Goal scored by the Player ("Goal Bonus")
in any Match of any Competitions of the Club (except for any Friendlies and/or nonCompetitive Matches).
3.2.2. The Club agrees to pay to the Player a fixed Bonus of EUR 230/- only (being
Euro Two Hundred and Thirty only) for every goal Assisted by the Player ("Assist
Bonus") in any Match of any Competitions of the Club (except for any Friendlies and/or
non-Competitive Matches).
3.2.3 The Club agrees to pay to the Player a fixed Bonus of EUR 230/- only (being Euro
Two Hundred and Thirty only) for every Point secured by the Club ("Points
Bonus") in the main League Competition in which the Club participates in a particular
Season.
3.2.4 The Club agrees to pay to the Player a fixed Bonus of EUR 23,000/- only (being
Euro Twenty-Three Thousands only) as Championship Bonus if and only if the
Club secures First (1st) position at the conclusion of the 2024/25I-League
season("the League Competition")”
3.3. The Bonus mentioned above in Clause 3 are inclusive of any direct taxes such as
TDS (at 10%) but exclusive of any indirect taxes, such as GST (at 18%), if applicable. “
pg. 8
REF. FPSD-21010
24. Indeed, the Single Judge observed that the Player alleged that the bonus remuneration was
triggered, however the Single Judge recalled that art. 13 par. 5 of the Procedural Rules states,
quoted verbatim, “[a] party that asserts a fact has the burden of proving it.”
25. While the Player has demonstrated that the Contract provided for bonus remuneration based
on individual and collective performance, after careful consideration of the evidence and of the
submissions on file, the Single Judge determined that the Player did not provide any evidence
that the conditions for the bonus remuneration had been fulfilled.
26. In absence of evidence, the Single Judge concluded that the Player did not discharge his burden
of proof under art. 13 par. 5 of the Procedural Rules that the bonuses were indeed due and
decided against awarding the claimed bonuses to the Player.
27. The Single Judge then moved to the claim for reimbursement of expenses of an amount of
EUR 540. The Single Judge noted that the Player alleged that he had an agreement with the
Club for the reimbursement of this amount.
28. However, after careful consideration of the evidence and of the submissions on file, the Single
Judge observed that the Player did not provide evidence of this agreement with the Club. In
considering the above, the Single Judge determined that the Player did not discharge his burden
of proof under art. 13 par. 5 of the Procedural Rules that there was agreement between him and
the Club for the reimbursement an amount of EUR 540. Consequently, the Single Judge decided
not to award this amount.
29. Considering the above the Single Judge rejected the claim.
d. Costs
30. 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.
31. 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.
32. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for relief
made by any of the parties.
pg. 9
REF. FPSD-21010
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Joni Kauko, is rejected.
2.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 10
REF. FPSD-21010
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. 11