Labour Disputes
Texto da decisão
REF. FPSD-21839
Decision of the
Dispute Resolution Chamber
passed on 17 December 2025
regarding an employment-related dispute concerning the player Kristijan
Lovric
BY:
Andre DOS SANTOS MEGALE, Brazil
CLAIMANT:
Kristijan Lovric, Croatia
Represented by Nikola Badovinac
RESPONDENT:
Amed Sportif Faaliyetler, Türkiye
pg. 2
REF. FPSD-21839
I. Facts of the case
1.
On 18 July 2025, the Croatian player Kristijan Lovric (hereinafter: the Player or the Claimant)
and the Turkish club Amed Sportif Faaliyetler (hereinafter: the Club or the Respondent)
entered into a termination and settlement agreement (hereinafter: the Agreement) by
means of which they settled the financial consequences of the employment relationship
previously initiated between them.
2.
The Agreement established inter alia the following:
“1.1. The parties have settled their disputes as set out below and have mutually
terminated their Contracts by signing this Termination and Settlement Agreement with
mutual consent. The Parties have agreed that the Player has a receivable due to the case
file (FPSD-19567) between the Player and the Club, which is actively pending before FIFA.
The Parties have agreed that the Club shall pay the Player the amount of net 710.000,00EUR in relation to the Player’s receivables. This amount of net 710.000,00-EUR shall be
paid as follows
•
•
•
•
•
350.000,00-EUR will be paid on signature date of this Settlement Agreement.
90.000,00-EUR will be paid on 10.08.2025.
90.000,00-EUR will be paid on 10.09.2025.
90.000,00-EUR will be paid on 10.11.2025.
90.000,00-EUR will be paid on 10.12.2025.
1.2. This Settlement Agreement shall enter into force upon payment of the first instalment
by the Club, i.e. upon the payment of 350.000,00-EUR. Until such payment is made, this
Settlement Agreement shall have no legal effect.
1.3. The Player accepts, declares and undertakes that he has no other receivables and
compensation from the aforementioned Club other than the amounts stated above in
accordance with all Protocols and agreements between the Player and the Club. This
contract has been made with the free will of the Player and the terms have been reached
as a result of mutual negotiations.
1.4. The parties agree that if the Club fails to pay part or all of the Settlement Agreement
on the above-mentioned due dates for any reason, the Player must send an official
notification to the Club. If payment is not made within 7 (seven) days from the date of
the notification, the Club shall be liable for the full amount of the unpaid balance, and
Club will pay a fine of 25,000- EUR to the Player. The provisions of this Clause shall not
apply to the first instalment of EUR 350.000,00- EUR as this Settlement Agreement shall
have no legal effect until the Club has paid the first instalment, in accordance with Clause
1.2.”
pg. 3
REF. FPSD-21839
3.
On 24 July 2025, the same parties entered into an “Amendment Protocol” (hereinafter: the
Protocol), by means of which they established that the first instalment of the Agreement
would be paid as follows:
“The date for the first installment payment of the Termination and Settlement Agreement
dated 18.07.2025 between the parties is amended as follows.
350.000,00-EUR will be paid on 24.07.2025
The first installment payment specified in the clause stating that the agreement will
become valid upon payment of the first installment specified in the Termination and
Settlement Agreement dated 18.07.2025 has been postponed to 24.07.2025.
For the avoidance of doubt, the payment date of the first installment specified in the
Termination and Settlement Agreement dated 18.07.2025 has been postponed to
24.07.2025. Therefore, the validity of the Termination and Settlement Agreement will
continue if the first installment is paid on 24.07.2025, by midnight, i.e., by 24.00 hours
CET. The Club is also obliged to send proof of payment (bank confirmation) by the same
deadline.
The provisions that remain unchanged with this Amendment Protocol shall remain in full
force and effect, but only if the Club makes the payment of the first installment by
24.7.2025. by midnight, i.e. 24.00 hours CET.”
4.
On 24 July 2025, the Club paid the Player the first instalment under the Agreement, as
amended in the Protocol (i.e., EUR 350,000).
5.
On 13 August 2025, the Player sent the Club a notice of default, demanding payment of
EUR 90,000 under the Agreement within 7 days. The Player pointed out that the failure
from the Club to remedy the breach would entail the acceleration of the entire debt and
trigger the contractual penalty.
6.
On 26 August 2025, the Club paid the Player the second instalment under the Agreement
(i.e., EUR 90,000).
7.
On 11 September 2025, the Player demanded payment of the third instalment under the
Agreement within 7 days.
8.
On 14 October 2025, and in the context of parallel proceedings in front of the Football
Tribunal (FPSD-21246), the Club paid the Player EUR 180,000.
pg. 4
REF. FPSD-21839
II. Proceedings before FIFA
9.
On 10 November 2025, the Player filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Claim of the Player
10. The Player referred to the terms of the Agreement, which was allegedly concluded in the
context of settling a prior dispute before the FIFA Dispute Resolution Chamber (DRC). He
also cited multiple notifications sent to the Club, emphasizing its repeated delays in
payment and ultimate failure to remit the balance of the Agreement and the contractual
penalty.
11. The Player asserted that the Club’s default, combined with the issuance of default notices,
triggered the acceleration and penalty clauses of the Agreement. On this basis, he claimed
entitlement to the outstanding amount of EUR 90,000, as well as a contractual penalty of
EUR 25,000, totalling EUR 115,000.
12. The Player requested the following relief, quoted verbatim:
“I. AMED SPORTIF FAALIYETLER, with registered seat at Firah Mah. Dorşin Street No: 50,
Diyarbakir, Turkey is hereby ordered to pay to the KRISTIJAN LOVRIĆ from Zagreb, the
total amount of EUR 115,000.00 including annual interest of 5% per annum until final
payment is made, all under threat of banning from registering new players in the next
two transfer windows and banning the participation in all competitions organized by
FIFA.
II. AMED SPORTIF FAALIYETLER, with registered seat at Firah Mah. Dorşin Street No: 50,
Diyarbakir, Turkey is a banned from registering any new players, either nationally or
internationally for two next entire and consecutive registration periods.
III. AMED SPORTIF FAALIYETLER, with registered seat at Firah Mah. Dorşin Street No: 50,
Diyarbakir, Turkey shall be ordered to pay a fine in the amount determined by the
Dispute Resolution Chamber as a sporting sanction pursuant to Article 12 of the FIFA
Regulations on the Status and Transfer of Players, due to its failure to comply with its
contractual obligations towards the Claimant.
IV. AMED SPORTIF FAALIYETLER, with registered seat at Firah Mah. Dorşin Street No: 50,
Diyarbakir, Turkey is hereby ordered to compensate the costs of these proceedings to the
KRISTIJAN LOVRIĆ from Zagreb, Croatia, including annual interest of 5% per annum
starting from the day this judgement is reached, until final payment is made, under
threat of banning from registering new players in the next two transfer windows and
banning the participation in all competitions organized by FIFA.”
pg. 5
REF. FPSD-21839
b. Reply of the Club
13. On 6 December 2025, the Club replied to the Player’s claim.
14. The Club claimed that the following payments should be taken into account and credited
against its debt:
•
•
•
•
•
EUR 70,000 on 1 November 2024;
EUR 36,850 on 1 November 2024;
EUR 350,000 on 24 July 2025;
EUR 90,000 on 26 August 2025;
EUR 180,000 on 14 October 2025.
15. The Club argued that the Player’s claim was premature, as the last instalment of the
Agreement was not yet due. It also alleged that the penalty was not applicable and, in any
event, disproportionate.
16. The Club requested:
“1. Dismiss the Claimant’s request for EUR 90,000 as it was not yet due,
2. Reject the claim for the contractual penalty,
3. Reject the claim for interest.”
c. Additional comments of the Player
17. At the request of the FIFA General Secretariat, the Player confirmed receipt of the payments
mentioned by the Club but insisted on his entitlement to the balance of the Agreement and
the penalty.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
18. First of all, the Single Judge of the DRC (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 10 November 2025 and submitted for decision on 17
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.
19. 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
pg. 6
REF. FPSD-21839
Regulations on the Status and Transfer of Players (hereinafter: the Regulations) (July 2025
edition), the DRC is competent to deal with the matter at stake, which concerns an
employment-related dispute with an international dimension between an nationality
player and a nationality club.
20. 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
21. 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
22. 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
23. The Single Judge then moved to the substance of the matter, noting that it concerned a
claim for overdue payables brought by a player against a club.
24. The Single Judge observed that the Player claimed to be entitled to a total of EUR 115,000
net, plus interest, based on the Agreement. Conversely, the Club alleged that it had
complied with its financial obligations and, alternatively, that the penalty clause was
excessive and should be set aside.
25. In light of the above, the Single Judge determined that the Club had the burden to prove
that it had complied with its obligations under the Agreement. However, with regard to the
partial payments made to the Player, the Single Judge found it clear and unequivocal that
(i) the Club defaulted inter alia on the payment of several instalments, particularly the third
(originally due by 10 September 2025); (ii) the Player placed the Club in default on 11
pg. 7
REF. FPSD-21839
September 2025 and granted a 7-day deadline as required pursuant to the Agreement; and
(iii) the breach was not fully remedied within this deadline, triggering the acceleration /
interest clauses contained in the Agreement (i.e., clause 1.4).
26. Contrary to the Club’s position, the Single Judge considered that the subsequent payment
was not a legal argument that justified a departure from the pacta sunt servanda. In fact,
the Single Judge noted that the Player apparently granted the Club enough opportunities
to avoid litigation, but to no avail.
27. Similarly, the Single Judge emphasized that the interest rate and the penalty clause
stipulated in the Agreement fell within the threshold accepted in the jurisprudence of the
Football Tribunal.
28. Therefore, the Single Judge ordered that the Player be awarded EUR 90,000 as the
outstanding balance of the Agreement, plus 10% interest p.a. from the date of decision (as
claimed) until the date of effective payment.
29. The Single Judge also confirmed that the Player is entitled to EUR 25,000 as contractual
penalty, with no interest (ne bis in idem).
30. For the sake of completeness, the Single Judge further noted that, as the Player did not
grant the Club a deadline of 10 days to remedy the breach, no sanction could be imposed
pursuant to art. 12bis of the Regulations.
ii. Compliance with monetary decisions
31. 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.
32. 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.
33. 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.
pg. 8
REF. FPSD-21839
34. 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.
35. 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
36. 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.
37. 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.
38. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 9
REF. FPSD-21839
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Kristijan Lovric, is partially accepted.
2.
The Respondent, Amed Sportif Faaliyetler, must pay to the Claimant the following
amount(s):
- EUR 90,000 as outstanding remuneration plus 5% interest p.a. as from 17 December
2025 until the date of effective payment; and
- EUR 25,000 as contractual penalty.
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. 10
REF. FPSD-21839
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