Labour Disputes
Texto da decisão
REF. FPSD-21371
Decision of the
Dispute Resolution Chamber
passed on 10 February 2026
regarding an employment-related dispute concerning the player Okechukwu
Godson Azubuike
BY:
Johan VAN GAALEN, South Africa
CLAIMANT:
Okechukwu Godson Azubuike, Nigeria
Represented by Arda Zengipeduk
RESPONDENT:
Erzurumspor FK, Türkiye
Represented by Enes Simsek
pg. 2
REF. FPSD-21371
I. Facts of the case
1.
On 21 August 2024, the Nigerian player Okechukwu Godson Azubuike (hereinafter: the
Player or the Claimant) and the Turkish club Erzurumspor FK (hereinafter: the Club or the
Respondent) entered into a document titled “PROFESSIONAL PLAYER’S CONTRACT”
(hereinafter: the Contract), valid from 21 August 2024 to 30 June 2025.
2.
Clause 3 of the Contract established that (quoted verbatim):
“3.1. 2024/2025 FOOTBALL SEASON
Signing on Fee : The Club has paid a total amount of 64,000,-EUR as signing on fee to the
Player on the signature date.
Salary: The Club shall pay a total of 200,000.-EUR as salary to the Player for the
2024/2025 season on the due dates set out below:
30.09.2024
31.10.2024
30.11.2024
31.12.2024
31.01.2025
28.02.2025
31.03.2025
30.04.2025
31.05.2025
30.06.2025
20,000.-EUR
20,000.-EUR
20,000.-EUR
20,000.-EUR
20,000.-EUR
20,000.-EUR
20,000.-EUR
20,000.-EUR
20,000.-EUR
20,000.-EUR
Conditional Payments:
•
5,000.-EUR bonus if the Player plays in the first eleven squad in the 10 official league
matches of the first half of the league
•
5,000.-EUR bonus if the Player plays in the first eleven squad of the league in 10
official league matches of the second half of the league
•
10,000.-EUR bonus if the Player scores in total 8 goals or assists in the official league
matches
•
10,000.-EUR bonus if the Club qualify for play-off matches
pg. 3
REF. FPSD-21371
•
50,000.-EUR bonus if the Club promotes to the Super League at the end of the
season (If the club promotes to the Super League via play-off matches the
entitlement of the Player will be 50,000,-EUR.)
Other Benefits (During the contractual relationship):
➢ 10,000.-EUR in total for living expenses that will be paid in 2 (two) equal
instalments as 5,000.-EUR on 30.09.2024 and 5,000.-EUR on 28.02.2025.
3.2. The aforementioned conditional payments shall be paid by the Club within 30 days
after the end of the relevant season, if the Player is entitled to them. Play-off and
promotion to the higher league bonuses shall be calculated and paid on a pro-rata basis
according to the number of official league games played by the Player in the relevant
season. In addition, friendly matches, cup matches and play-off matches will not be taken
into account in the calculation of bonus fees.
3.3. If a due date for the above-mentioned amounts falls on a Saturday, Sunday, or on a
day officially recognized as a public holiday in Republic of Turkey, then the due date shall
be deemed to be the next working day.
3.4. All payments to be made to the Player shall be NET and the Club shall be responsible
for the full payment of the withholding tax, income tax, stamp tax and any other tax
arising from this contract in accordance with the Turkish tax legislation in the territory in
Turkey. If the Player is to be held liable and pays any tax amount to the taxation
authorities, the Club will reimburse such amounts, plus their interests and the damages
suffered thereof, if any, within five days following the receipt of a written request by the
Player.”
3.
Clause 4 of the Contract established that (quoted verbatim):
“4 – OBLIGATIONS OF THE CLUB
The Club is obligated to:
a) do the payments, which are stated under this contract, in their due time,
b) to deal with the player in case of injury as it is stated in the related articles and take
necessary precautions in games, trainings, camps and travels,
c) to organize lessons, conferences, courses and get the necessary materials in order to
contribute to players’ development in his career,
d) to obey the rules and regulations of FIFA, UEFA and TFF, to protect and encourage the
ethical principles of football.
pg. 4
REF. FPSD-21371
The Club shall also be obligated to fulfill its duties also stated in Professional Players’
Status and Transfer Regulation of TFF.”
4.
On 20 August 2024, the Club paid the Player EUR 64,000.
5.
On 2 October 2024, the Club paid the Player EUR 20,000.
6.
On 1 November 2024, the Club paid the Player EUR 10,000.
7.
On 27 November 2024, the Club paid the Player EUR 10,000.
8.
On 27 November 2024, the Club paid the Player EUR 5,000.
9.
On 8 January 2025, the Club paid the Player EUR 20,000.
10. On 4 February 2025, the Club paid the Player EUR 20,000.
11. On 4 March 2025, the Club paid the Player EUR 20,000.
12. On 4 April 2025, the Club paid the Player EUR 20,000.
13. On 2 May 2025, the Club paid the Player EUR 20,000.
14. On 30 May 2025, the Club paid the Player EUR 20,000.
15. On 23 September 2025, the Player put the Club in default, claiming to it a total debt of EUR
65,000 and providing the Club a ten-day period to comply with its obligations.
16. On 15 October 2025, the Club paid the Player EUR 10,000.
II. Proceedings before FIFA
17. On 15 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
18. According to the Player, the Club failed to pay his monthly salaries for May and June 2025,
which in total amounted to EUR 40,000.
19. In addition, the Player pointed out that the Club finished in sixth place and qualified for the
play-offs of the 2024/2025 TFF Trendyol season, and that he played a total of 29 matches:
15 in the first half of the season and 14 in the second half, excluding the play-offs.
pg. 5
REF. FPSD-21371
20. In this regard, the Player argued that pursuant to the performance-based bonus provisions
of the Contract, he became entitled to the following bonus payments:
• EUR 5,000 for starting in the starting eleven in at least 10 official league matches
during the first half of the season;
• EUR 5,000 for starting in the starting eleven in at least 10 official league matches
during the second half of the season; and
• EUR 10,000 for the Club’s qualification for the play-off stage.
21. The Player established that, according to the Contract, the bonuses were due within 30
days after the end of the relevant season, but despite the expiry of that period, the Club
failed to comply with its obligations.
22. In particular, the Player alleged that the season concluded on 30 June 2025, the 30-day
period of payment expired on 30 July 2025, and consequently interest on the outstanding
bonuses should accrue as of 31 July 2025 until the date of effective payment.
23. The Player further argued that, under the “Other Benefits” section of the Contract, the Club
undertook to pay him EUR 10,000 for living expenses in two instalments of EUR 5,000 each,
the first due on 30 September 2024 and the second on 28 February 2025. The Player stated
that, as of 15 October 2025, the Club had failed to pay the second instalment, which fell
due on 28 February 2025.
24. According to the Player, the Club failed to comply with its contractual obligations by not
paying his monthly salaries, living expenses, and performance-related bonuses. Since the
due dates established in the Contract for each of these payments had already passed, the
Player requested the payment of the outstanding amounts together with the interest
accrued from the respective due dates.
25. Furthermore, the Player alleged that he served a formal legal notice on 23 September 2025
with the intention of placing the Club in default under art. 12bis of the FIFA Regulations on
the Status and Transfer of Players (hereinafter: the Regulations). He stated that he granted
the Club an additional 10 days to settle the total amount of EUR 65,000, but the Club failed
to remedy the debt within the prescribed period. For this reason, the Player requested the
imposition of sporting sanctions under art. 12bis of the Regulations.
26. The Player concluded by stating that he was entitled to a total amount of EUR 65,000,
consisting of EUR 40,000 in outstanding salaries, EUR 5,000 in outstanding living expenses,
and EUR 20,000 in outstanding performance bonuses.
27. In light of the above, the Player submitted the following request for relief (quoted verbatim):
pg. 6
REF. FPSD-21371
“1- To accept the claims of Player Okechukwu Godson Azubuike,
2-To condemn Respondent to payout standing monthly salaries which are;
a. The monthly payment for May 2025 equals EUR 20.000, plus %5 interest p.a. as from
01.06.2025,
b. The monthly payment for June 2025 equals EUR 20.000, plus %5 interest p.a. as from
01.07.2025
3-To condemn Respondent to pay EUR 20.000 as outstanding performance related
bonuses plus %5 interest p.a. as from 31.07.2025,
4-To condemn Respondent to pay EUR 5.000 as outstanding living expenses plus %5
interest p.a. as from 01.03.2025
5-To impose sanctions against the Respondent in accordance with Article 12bis and
Article 24 of the FIFA Regulations on the Status and Transfer of Players (including a
warning, fine, and/or a ban from registering any new players, either nationally or
internationally, for up to three entire and consecutive registration periods), due to the
failure to comply with the financial obligations despite the formal notice.
6-To establish that the costs of the present arbitration procedure shall be borne by the
Respondent.”
b. Position of the Club
28. In its reply, the Club stated that, under the Contract, the Player was entitled to a total
amount of EUR 294,000, composed of the following: (i) EUR 64,000 as a signing-on fee; (ii)
EUR 200,000 corresponding to his salaries (EUR 20,000 x 10); (iii) EUR 5,000 as a bonus for
starting in 10 official matches in the starting eleven during the first half of the league; (iv)
EUR 5,000 as a bonus for starting in 10 official matches in the starting eleven during the
second half of the league; (v) EUR 10,000 as a bonus for achieving a combined total of 8
goals and/or assists; and (vi) EUR 10,000 as a bonus for participating in the play-off
matches.
29. The Club further stated that, up to the date of the claim, it had paid a total of EUR 239,000
to the Player, as follows:
•
•
•
•
EUR 64,000 on 20 August 2024;
EUR 20,000 on 2 October 2024;
EUR 10,000 on 1 November 2024;
EUR 10,000 on 27 November 2024;
pg. 7
REF. FPSD-21371
•
•
•
•
•
•
•
•
EUR 5,000 on 27 November 2024;
EUR 20,000 on 8 January 2025;
EUR 20,000 on 4 February 2025;
EUR 20,000 on 4 March 2025;
EUR 20,000 on 4 April 2025;
EUR 20,000 on 2 May 2025;
EUR 20,000 on 30 May 2025; and
EUR 10,000 on 15 October 2025.
30. Thereby, the Club acknowledged the Player’s entitlement to a remaining unpaid receivable
equal to EUR 55,000.
31. The Club concluded its reply by stating that the Player filed his claim without considering
the last payment of EUR 10,000 made on 15 October 2025 and requested the Football
Tribunal to deduct the paid amounts from the Player’s request.
32. In light of the above, the Club submitted the following request for relief (quoted verbatim):
“(i) Deduct the paid amounts from the requested amount as outstanding receivables,
(ii) Decide that the Club be given additional time to settle the dispute between the parties
to pay the outstanding receivables of the Player.”
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
33. 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 15 October 2025 and submitted for
decision on 10 February 2026. Taking into account the wording of arts. 31 and 34 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.
34. 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 (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 Nigerian player and a Turkish club.
35. 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
pg. 8
REF. FPSD-21371
the Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Burden of proof
36. 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 TMS.
c. Merits of the dispute
37. 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
38. The Single Judge then moved to the substance of the matter, noting that it concerned a
claim for outstanding remuneration brought by a player against a club.
39. The Player argued that the Club had breached the Contract by failing to pay two monthly
salaries (EUR 20,000 each), a housing-expenses instalment (EUR 5,000), and performance
bonuses (EUR 20,000). As a result, the Player claimed entitlement to EUR 65,000 plus
interest and requested the imposition of sporting sanctions under art. 12bis of the
Regulations.
40. Conversely, the Club alleged that the Player was entitled to EUR 294,000 under the
Contract, as well as that it had already paid him EUR 239,000 through multiple instalments.
It acknowledged that a remaining balance of EUR 55,000 was still outstanding because the
Player filed his claim without accounting for the most recent payment of EUR 10,000 made
on 15 October 2025 and asked the Football Tribunal to deduct all amounts already paid
from the Player’s request.
41. In this context, the Single Judge acknowledged that his task was to establish the precise
quantum of the overdue payables and to evaluate the corresponding consequences
stemming from them.
pg. 9
REF. FPSD-21371
42. In this regard, the Single Judge began by recalling that, according to the Contract, the Player
was entitled to receive, as fixed compensation, a total amount of EUR 274,000 (i.e., EUR
64,000 corresponding to the signing bonus, EUR 200,000 corresponding to ten monthly
salaries, and EUR 10,000 corresponding to living expenses that had to be paid in 2
instalments of EUR 5,000 each).
43. The Single Judge also noted that the Club argued and submitted evidence of having paid
the Player a total amount of EUR 239,000, broken down as follows:
Payment Date
20 August 2024
2 October 2024
1 November 2024
Amount (EUR)
64,000
20,000
10,000
27 November 2024
10,000
27 November 2024
5,000
8 January 2025
4 February 2025
4 March 2025
4 April 2025
2 May 2025
30 May 2025
15 October 2025
20,000
20,000
20,000
20,000
20,000
20,000
10,000
TOTAL
239,000
Description
Signing bonus
Salary due on 30 September 2024
First partial payment of salary due on 31
October 2024
Partial payment of salary due on 31 October
2024
First instalment of living expenses due on 30
September 2024
Salary due on 30 November 2024
Salary due on 31 December 2024
Salary due on 31 January 2025
Salary due on 28 February 2025
Salary due on 31 March 2025
Salary due on 30 April 2025
Partial payment of salary due on 31 May
2025
44. Accordingly, the Single Judge established that the Club failed to comply with the salary
obligations claimed by the Player, namely those corresponding to May and June 2025, as
well as with the second instalment of the living expenses payment. Namely, a total amount
of EUR 45,000.
45. Nevertheless, the Single Judge also took notice that the Club made a partial payment of
EUR 10,000, which he considered as the equivalent of half of the salary for May 2025, on
the same day the Player filed his claim, i.e., 15 October 2025, which was not disputed.
According to the Single Judge, this partial payment had to be considered when determining
the outstanding amounts and the calculation of interest owed to the Player.
46. In this regard, the Single Judge established that the Club had to pay the Player EUR 35,000
as outstanding remuneration, plus interest, broken down as follows:
pg. 10
REF. FPSD-21371
•
EUR 10,000 corresponding to the balance of the salary of May 2025, plus 5% p.a.
from 1 June 2025 until the date of effective payment;
•
EUR 20,000 corresponding to the salary of June 2025, plus 5% p.a. from 1 July
2025 until the date of effective payment; and
•
EUR 5,000 corresponding to the second instalment of the living expenses, plus
5% p.a. from 1 March 2025 until the date of effective payment.
47. Additionally, the Single Judge acknowledged that the Player requested the amount of EUR
20,000 in conditional payments, consisting of: (i) EUR 5,000 for having been included in the
starting eleven in at least 10 official league matches during the first half of the season; (ii)
EUR 5,000 for having been included in the starting eleven in at least 10 official league
matches during the second half of the season; and (iii) EUR 10,000 for the Club’s
qualification for the play-off stage.
48. In this respect, the Single Judge also noted that the Club acknowledged a total debt of EUR
30,000 towards the Player, broken down as follows: (i) EUR 5,000 for starting 10 matches in
the starting eleven during the first half of the league; (ii) EUR 5,000 for starting 10 matches
in the starting eleven during the second half of the league; (iii) EUR 10,000 for reaching a
combined total of 8 goals and/or assists; and (iv) EUR 10,000 for participating in the playoff matches.
49. According to the Single Judge, despite the Club’s acknowledgement, and in accordance with
the principle of ne ultra petita, he decided to limit his award to EUR 20,000, plus interest at
a rate of 5% p.a. from 31 July 2025 until the date of effective payment.
ii. Art. 12bis of the Regulations
50. 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.
51. 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.
52. 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.
53. 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,
pg. 11
REF. FPSD-21371
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. b) of the Regulations.
54. 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
55. 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.
56. 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.
57. 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.
58. 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.
59. 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
60. 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.
pg. 12
REF. FPSD-21371
61. 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.
62. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 13
REF. FPSD-21371
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Okechukwu Godson Azubuike, is partially accepted.
2.
The Respondent, Erzurumspor FK, must pay to the Claimant the following amount(s):
- EUR 55,000 as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of EUR 5,000 as from 1 March 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 10,000 as from 1 June 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of EUR 20,000 as from 1 July 2025 until the date of
effective payment; and
- 5% interest p.a. over the amount of EUR 20,000 as from 31 July 2025 until the date of
effective payment.
3.
Any further claims of the Claimant are rejected.
4.
A reprimand is imposed on the Respondent.
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.
pg. 14
REF. FPSD-21371
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.
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. 15
REF. FPSD-21371
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. 16