Labour Disputes
Texto da decisão
REF. FPSD-21344
Decision of the
Dispute Resolution Chamber
passed on 22 January 2026
regarding an employment-related dispute concerning the player
Ahmad K. Saidy
BY:
Michele COLUCCI (Italy)
CLAIMANT:
Ahmad K. Saidy, Gambia
Represented by Sheriff Adeshina
RESPONDENT:
PFFAAB, Philippines
pg. 2
REF. FPSD-21344
I. Facts of the case
1.
On 19 September 2024, the Gambian player Ahmad K. Saidy (hereinafter: the Player
or the Claimant) and the Philippine club PFFAAB (hereinafter: the Club or the
Respondent) entered into an employment contract (hereinafter: the Contract), valid
as from 20 September 2024 until 19 August 2025.
2.
According to Annex A of the Contract, the Club undertook to pay the Player a
monthly salary in the amount of PHP 25,000.
3.
On an unspecified date, the Player and the Club signed a document titled “Player
Release Certification” (hereinafter: the Player’s Release Certification), which reads as
follows (quoted verbatim):
“The club acknowledges its obligation to pay Mr. Ahmad K. Saidy his one-month
salary, and commits to settling this amount despite the signing of the release form.
We wish him the best of luck on his next endeavor!”
4.
On 14 April 2025, the Player requested the payment of bonuses in the amount of
PHP 8,000 via WhatsApp from a contact identified as “Tristan Cosico”.
5.
On 23 September 2025, the Player contacted the Philippine Football Federation
claiming that one monthly salary in the amount of PHP 25,000, as well as various
bonuses totalling PHP 8,000, remained outstanding under the Contract.
II. Proceedings before FIFA
6.
On 14 October 2025, the Player filed the claim at hand before FIFA. A summary of
the parties’ respective positions is detailed below.
a. Position of the Player
7.
On 14 October 2025, the Player lodged a claim before FIFA for breach of contract.
8.
The Player alleged that the Club failed to pay him six monthly salaries in the amount
of PHP 150,000, as well as performance bonuses in the amount of PHP 8,000.
9.
The Player further submitted that the Player’s Release Certification had been duly
signed and, despite the Club’s acknowledgement of its obligation to pay him one
monthly salary therein, it failed to comply with its financial obligations.
10. The Player further asserted that the total outstanding amount was PHP 218,400,
broken down as follows:
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REF. FPSD-21344
-
PHP 150,000 corresponding to unpaid monthly salaries for the period
between March and August 2025;
-
PHP 25,000 corresponding to unpaid settlement amount equivalent to
one monthly salary;
-
PHP 8,000 corresponding to unpaid performance bonuses
-
PHP 25,000 as compensation for breach of the Contract; and
-
PHP 10,400 as accrued interest.
11. The Player requested the following relief (quoted verbatim):
“The Player, through his legal representative, respectfully requests the FIFA
Dispute Resolution Chamber to:
1. Declare that the Player terminated his contract with just cause under Article
9.3(a) of the employment contract and Article 14 of the FIFA RSTP;
2. Order Maharlika Taguig FC to pay the Player the total amount of ₱218,400,
broken down as above;
3. Award interest on all unpaid sums from the respective due dates until full
settlement;
4. Impose any disciplinary or financial sanctions on Maharlika FC under the
FIFA Disciplinary Code for persistent non-payment of wages; and
5. Confirm that the Player is free to register with any new club without
restriction or compensation payable to Maharlika FC.”
b. Position of the Club
12. Despite having been invited to do so, the Club failed to provide its position to the
claim.
pg. 4
REF. FPSD-21344
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
13. 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 14
October 2025 and submitted for decision on 22 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.
14. 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 Gambian player and a Philippine club.
15. 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 was
applicable to the matter at hand as to the substance.
b. Burden of proof
16. 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
17. 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 would refer only to the facts, arguments and documentary
evidence, which he considered pertinent for assessing the matter at hand.
pg. 5
REF. FPSD-21344
i. Main legal discussion and considerations
18. The Single Judge then moved to the substance of the matter and took note of the
fact that it concerns a claim of a player against a club for breach of contract.
19. In this respect, the Single Judge observed that the Player alleged the Club had
breached the Contract by failing to pay six monthly salaries in the total amount of
PHP 150,000, the settled amount acknowledged in the Player’s Release Certification
in the amount of PHP 25,000, performance bonuses in the amount of PHP 8,000,
compensation for breach of contract in the amount of PHP 25,000, as well as
accrued interest in the amount of PHP 10,400.
20. The Single Judge observed that the Club, for its part, failed to reply to the claim. As
a consequence, the Single Judge confirmed that his decision would be based on the
documentation on file, i.e., the statements and documents presented by the Player,
in accordance with art. 21 par. 1 of the Procedural Rules.
21. In this context, the Single Judge noted that the Player submitted a document
entitled the Player’s Release Certification, signed by both parties, in which the Club
expressly acknowledged that the amount due is one monthly salary, as follows
(quoted verbatim):
“The club acknowledges its obligation to pay Mr. Ahmad K. Saidy his one-month
salary, and commits to settling this amount despite the signing of the release form.
We wish him the best of luck on his next endeavor!”
22. Furthermore, the Single Judge noted that the date on which this document was
signed was unspecified.
23. Nevertheless, the Single Judge considered that, based on the very nature of said
document as well as the Player’s submissions, it can be reasonably inferred that it
was signed in connection with the termination of the employment relationship and
after the Player had already requested payment of the alleged bonuses in the
amount of PHP 8,000.
24. In addition, the Single Judge observed that the content of the Player’s Release
Certification is clear and unequivocal and does not give rise to any alternative
interpretation.
25. Moreover, the Single Judge held that, had the parties intended to include Any
additional outstanding amounts therein, they could have expressly stipulated so in
the aforementioned document.
pg. 6
REF. FPSD-21344
26. In view of the foregoing, and in application of the principle of pacta sunt servanda,
the Single Judge concluded that the Club had to pay the Player the amount of PHP
25,000, corresponding to the one monthly salary acknowledged in the Player’s
Release Certification.
27. In addition, taking into consideration the Player’s request as well as the constant
practice of the Football Tribunal in this regard, the Single Judge decided to award
the Player interest at the rate of 5% p.a. on the outstanding amounts from 14
October 2025 until the date of effective payment.
ii. Compliance with monetary decisions
28. 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.
29. 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.
30. Therefore, bearing in mind the above, the Single Judge decided that the Club must
pay the full amount due (including all applicable interest) to the Player within 45
days of notification of the decision, failing which, at the request of the Player, 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 Club in accordance with art. 24 par. 2, 4, and
7 of the Regulations.
31. The Club shall make full payment (including all applicable interest) to the bank
account provided by the Player in the Bank Account Registration Form, which is
attached to the present decision.
32. 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
33. 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,
pg. 7
REF. FPSD-21344
football agent, or match agent”. Accordingly, the Single Judge decided that no
procedural costs were to be imposed on the parties.
34. 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.
35. Lastly, the Single Judge concluded his deliberations by rejecting any other requests
for relief made by any of the parties.
pg. 8
REF. FPSD-21344
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Ahmad K. Saidy, is partially accepted.
2.
The Respondent, PFFAAB, must pay to the Claimant the following amount(s):
- PHP 25,000 as outstanding remuneration plus 5% interest p.a. as from 14 October 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. 9
REF. FPSD-21344
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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