Labour Disputes
Texto da decisão
REF. FPSD-21514
Decision of the
Dispute Resolution Chamber
passed on 3 December 2025
regarding an employment-related dispute concerning the player Admir
Bajrovic
BY:
Calum BEATTIE, Scotland
CLAIMANT:
Admir Bajrovic, Sweden
Represented by Antonis Vogiatzakis
RESPONDENT:
Tirana, Albania
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REF. FPSD-21514
I. Facts of the case
1.
On 5 June 2025, the Swedish player Admir Bajrovic (hereinafter: the Player or the Claimant)
and the Albanian club Tirana (hereinafter: the Club or the Respondent) concluded a
termination agreement (hereinafter: the Termination Agreement), whereby they agreed on
the terms and conditions for the mutual termination of their employment relationship.
2.
Pursuant to clause 1 of the Termination Agreement, the Club undertook to pay the Player
as follows (quoted verbatim):
“Article 1
Subject
1. The Parties hereby agree to mutually terminate the employment relationship
established by the Employment Contract, with immediate effect. In addition, THE CLUB will
pay THE PLAYER a total sum of 60.333€ (Sixty Thousand Three Hundred and Thirty Three
Euro) net, which concludes all obligations the Club has towards the Player for their entire
working relationship and contract duration, including outstanding remuneration under
the Employment Contract and the agreed compensation against the premature
termination of the employment relationship between the Parties.
The abovementioned sum shall be paid in 3 installments:
20.000€ (Twenty Thousand Euro) until 31 August 2025.
20.000€ (Twenty Thousand Euro) until 31 October 2025.
20.333€ (Twenty Thousand Three Hundred and Thirty Three Euro) until 31 December 2025.
2. In cases of late payment, interest of 5% p.a. will be applied.
3. Further, upon default of THE CLUB in the payment of even one installment, according
to the payment schedule provided in Article 1.1 hereof, THE PLAYER will be entitled to notify
THE CLUB in writing about said default and provide THE CLUB with a deadline of five (5)
days to remedy it. In the event that THE CLUB will not pay the due installment(s) within the
above - mentioned deadline, all the remaining and unpaid installments, whether due or
not at the time said default occurred, shall become due and payable and THE PLAYER will
be entitled to pursue all legal remedies available.
4. All the amounts mentioned in this Agreement will be paid to THE PLAYER net of all taxes,
social security contributions, surcharges, levies, and costs incurred within the territory of
Albania, including any costs that may be due to the Albanian Football Association against
the registration of the present agreement. Further, THE CLUB remains obliged to pay all
kinds of taxes, social security contributions and other surcharges pertaining to the income
that the Player has already received under the Employment Contract. Accordingly, THE
PLAYER maintains the right to take recourse against THE CLUB if the latter has already
breached or will breach in the future, its obligations towards the Player regarding the
payment of all kinds of tax and/or social security obligations against the Albanian state,
in accordance with the terms of the Agreement. Therefore, and provided that THE PLAYER
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REF. FPSD-21514
will be obliged in the future to pay to all kinds of tax authorities and/or social security
services and/or the general public sector of Albania, any amount causally linked to his
employment as a professional football player by THE CLUB and/or to any income gained
under such capacity, THE PLAYER will be entitled, in accordance with the terms herein, to
take recourse against THE CLUB and to receive full compensation for all the sums he will
be required to pay according to the terms of this paragraph.”
3.
On 9 September 2025, the Player issued a default notice (hereinafter: the First Notice),
whereby it granted the Club a 5-day deadline to pay EUR 20,000, corresponding to the first
installment due under the Termination Agreement, which was payable by 31 August 2025.
4.
On 29 September 2025, the Player issued a second default notice (hereinafter: the Second
Notice), whereby it granted the Club a 5-day deadline to pay EUR 60,333, corresponding to
the original overdue instalment of EUR 20,000 plus the residual installments (EUR 40,333)
which were subject of the acceleration clause due to the Club’s failure to comply with the
First Notice.
II. Proceedings before FIFA
5.
On 23 October 2025, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Position of the Claimant
6.
The Player argued that the Club failed to pay the first instalment under the Termination
Agreement by the contractual deadline of 31 August 2025. Subsequently, on 9 September
2025, the Player issued the First Notice, granting the Club a five-day period to cure the
default. Nonetheless, he argued that the Club did not comply.
7.
As a result, the Player argued that pursuant to clause 1.3 of the Termination Agreement,
the acceleration clause was triggered, rendering all outstanding amounts under the
contract immediately due and payable. Accordingly, the Player argued being entitlement
to the full contractual sum together with the applicable interest.
8.
Therefore, the Player held that the Club should pay the “outstanding amount of the 60,333€
(sixty thousand three hundred and thirty-three euro) net with the applicable interest, at a rate
of 5% p.a., starting accrued as of 1 September 2025 for the amount of 20,000€ and as of 14
September 2025 for the residual amount of 40,333€.
9.
In light of the above, the Player requested the following relief (quoted verbatim):
“In light of the abovementioned, the Player hereby requests the Dispute Resolution Chamber
of the FIFA Football Tribunal to:
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REF. FPSD-21514
-
Uphold the present claim;
-
Order the football club “KLUBI I FUTBOLLIT TIRANA SH.A" to pay the player Admir Bajrovic
the total net amount of sixty thousand three hundred and thirty-three euro (60,333€)
according to the modalities of the Termination Agreement, with the applicable interest,
at the rate of 5% p.a., starting accrued as defined above and until the date of effective
payment;
-
Issue a proposal regarding the case at hand, further to Article 20(1) of the Procedural
Rules Governing the Football Tribunal;
-
Order "KLUBI I FUTBOLLIT TIRANA SH.A" to bear the entire procedural costs of the present
proceedings, if any.”
b. Position of the Respondent
10. In its reply dated 18 November 2025, the Club acknowledged that the first and second
instalments under the Termination Agreement were not paid due to “operational
challenges”, which “do not constitute grounds for acceleration of obligations or the imposition
of interest before the contractual deadline”. In this sense, it maintained that the third
instalment “cannot be included in the current claim, nor can any interest lawfully accrue” prior
to the contractual deadline.
11. In light of the above, the Club stated the following (quoted verbatim):
“In conclusion, based on the above, FK Tirana kindly states on its behalf for FIFA DRC the
following:
a. FK Tirana rejects the proposal from the FIFA General Secretariat.
b. FK Tirana partially opposes Admir Bajrovic claims as ungrounded by evidence and law.”
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REF. FPSD-21514
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
note that the present matter was presented to FIFA on 23 October 2025 and submitted for
decision on 3 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
an Swedish player and an Albanian club.
14. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, it 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.
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REF. FPSD-21514
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
this is a claim from a player against a club for overdue payables.
18. On one hand, the Player argued the Club breached its contractual obligation by failing to
pay the first instalment under the Termination Agreement by 31 August 2025 and did not
remedy the default within the five-day period granted in the First Notice. Consequently,
under clause 1.3 of the Termination Agreement, the acceleration clause was triggered,
rendering all outstanding amounts immediately due, along with applicable interest.
19. On the other hand, the Club acknowledged that it did not pay the first and second
instalments under the Termination Agreement, citing “operational challenges” as the
reason. However, it disputed the applicability of the acceleration clause, asserting that its
conduct “do not constitute grounds for acceleration of obligations or the imposition of interest
before the contractual deadline”.
20. In this context, the Single Judge acknowledged that his task was to assess whether the
Player is entitled to the amounts claimed, under what conditions such entitlement arises,
and to determine the corresponding consequences.
21. At the outset, the Single Judge noted that it is undisputed that the Club failed to pay the
first instalment under the Termination Agreement by 31 August 2025. It is equally
uncontested that the Player issued the First Notice on 9 September 2025, granting a fiveday period to remedy the default, and the Club did not comply within this timeframe.
22. Hence, the Single Judge deemed it necessary to establish whether the acceleration clause
of the Termination Agreement was valid and, ultimately, triggered.
23. The Single Judge recalled that acceleration clauses have been traditionally recognized by
the Football Tribunal and by the Court of Arbitration for Sport (CAS) and are not considered
as penalties stricto sensu, as such clauses do not entail the payment of additional amounts
different to the principal amounts whose payment was agreed, but rather trigger the
accelerated payment of the principal amounts due, which is a practice considered
proportional if the parties agreed on its application, as occurred in the present case.
24. In the Single Judge’s view, the acceleration clause in question constitutes a security in
benefit of the creditor since it encourages the debtor party to respect its financial
obligations towards the creditor party. In other words, said clause of the Termination
Agreement is an early maturity of the principal amount due, which – in casu – is
proportionate, in light of what was specifically agreed between the parties under the
Termination Agreement within their autonomy of the will (pacta sunt servanda).
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REF. FPSD-21514
25. Considering the foregoing, the Single Judge was of the opinion that the acceleration clause
set forth in clause 1.3 of the Termination Agreement is valid and was duly triggered on 15
September 2025.
26. In parallel, the Single Judge outlined that the Club has not provided any legal basis or
supporting evidence to substantiate its position, in accordance with art. 13 para. 5 of the
Procedural Rules.
27. Therefore, in line with the pacta sunt servanda principle, the Single Judge concluded that
the Player is entitled to the following amounts:
- EUR 20,000 net corresponding to the first instalment under the Termination Agreement
(originally payable by 31 August 2025); and
- EUR 40,333 net corresponding to the amount subject to the acceleration clause
(triggered on 15 September 2025, i.e., one day after the expiration of the deadline granted
by the First Notice).
28. Additionally, in view of the Player’s request for relief and the standard practice of the
Football Tribunal, the Single Judge decided to award the Player 5% interest p.a. over the
outstanding amounts accruing as from the day following each corresponding due date.
ii. Compliance with monetary decisions
29. 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.
30. 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.
31. 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.
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32. 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.
33. 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
34. 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.
35. 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.
36. 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-21514
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Admir Bajrovic, is partially accepted.
2.
The Respondent, Tirana, must pay to the Claimant the following amounts:
- EUR 20,000 net as outstanding remuneration plus 5% interest p.a. as from 1 September
2025 until the date of effective payment; and
- EUR 40,333 net as outstanding remuneration plus 5% interest p.a. as from 16
September 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
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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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