Labour Disputes
Texto da decisão
REF. FPSD-21859
Decision of the
Dispute Resolution Chamber
passed on 20 January 2026
regarding an employment-related dispute concerning
the player Natalia Luana Oliveira Silva
BY:
Stella Maris JUNCOS, Argentina
CLAIMANT:
Natalia Luana Oliveira Silva, Brazil
Represented by Jorge Luis Goncalves dos Santos
RESPONDENT:
ZHFK Ljuboten, North Macedonia
pg. 2
REF. FPSD-21859
I. Facts of the case
1.
The parties to this dispute are:
•
•
2.
The Brazilian player Natalia Luana Oliveira Silva (hereinafter: the Player or the Claimant);
and
The North Macedonian club ZHFK Ljuboten (hereinafter: the Club or the Respondent).
On an unspecified date, a contact saved as “Dragoljub”, who, according to the Player, was
the Club’s director (hereinafter: the Club Director), made her the following proposal (quoted
verbatim):
“For Natalia Luana Our proposal for her is:
1. Profesional contract 4month plus optional 12month
2. Salary 40000den. Or 730usd per month
3. Return flight ticket
4. Accommodation in our Motel room with toilet only for her
5. Professional medical treatman for her (massage and injure recuperation if need it)
6. Food payed by club
7. Bonuses for champions league
In this moment this is our proposal for her because this is maximum according our
budget!”
3.
On 16 January 2024, the parties concluded an employment contract (hereinafter: the
Contract) valid as from the date of signature until 14 June 2024.
4.
Clause 13 of the Contract established:
“Salary
Article 13
Upon the performed work tasks, the football player has the right to salary.
The Employer regulates the categorization of the football players, salary, benefits,
premiums, penalties etc., with regulations on rewarding and disciplinary measures.
The monthly net salary cannot be lower than the minimum salary determined in a social
dialogue between the clubs and the Football Players’ Syndicate, confirmed by the
Executive Committee of FFM.
The monthly net salary of the football player amounts to 40000 denars.
The salary is paid once a month, no later than the fifteenth of the current month for the
previous month, on the transactions account of the football player.
With each paid salary the football player receives a written calculation for the gross
salary with paid contributions in accordance with the Law.”
5.
Clause 14 of the Contract provided as follows (quoted verbatim):
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REF. FPSD-21859
“Other incomes
Article 14
The football player has the right to other compensations and incomes determined by
Law and the collective agreement:
• travel expenses in 1. real amount / (2.) organized by the club
• food 1. real amount / (2.) organized by the club
If the football player has a different place of residence than the place where the
employer performs its activity/the seat of the club, then the employer shall provide the
football player with the appropriate accommodation.
• accommodation 1. real amount / (2.) organized by the club
The football player has the right to compensations and incomes determined with the
acts of the Employer in case of:
• work success - personal efforts, i.e. results of the team playing in the national
competition and international matches in accordance with the Employer’s Regulations
on Rewarding.
• compensation for transfer of the football player to the club.”
6.
During the 2023/2024 season, the Club obtained the first position in the league.
7.
On 8 October 2025, the Player put the Club in default and requested payment of EUR 1,400
within 15 days. The Player argued that this amount corresponded to her last salary and the
bonus stipulated in the Contract.
II. Proceedings before FIFA
8.
On 11 November 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
9.
The Player argued that the parties concluded the Contract, under which she was entitled
to MKD 40,000 per month, equivalent to EUR 650.24 at the time of concluding the Contract.
According to the Player, the Club failed to pay her last salary and the bonus for achieving
qualification for the UEFA Women’s Champions League™, resulting in a debt of EUR 1,300.
10. Regarding the bonus, the Player contended that the Club won the National League title,
thereby securing a Champions League spot that year. According to the Player, it was
promised to her in her contract proposal that she would receive a bonus. Notwithstanding,
the Club failed to pay her and never contacted her again.
11. The Player further explained that the bonus amounted to EUR 650 and that her salary was
always paid in EUR despite the Contract stipulating MKD 40,000. She argued that she placed
the Club in default on 8 October 2025, to no avail.
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REF. FPSD-21859
12. Based on the above, the Player made the following requests for relief:
“With all the facts and legal basis exposed, the Claimant requests:
a. That the RESPONDENT be formally summoned and present their defense.
b. That the RESPONDENT be condemned to pay the amount of EUR 1300.00 (thirteen
hundred euros) (USD 1505.96 (one thousand, five hundred and five dollars and ninetysix cents) that are overdue to the CLAIMANT with interests and currency correction.”
b. Position of the Respondent
13. In its reply, the Club partially rejected the Player’s claim. The Club acknowledged that the
last salary remained unpaid, which it was prepared to settle immediately. Nevertheless,
the Club rejected the claim for the bonuses.
14. Regarding the bonuses, the Club first remarked that the amounts indicated in the notice of
default differed from the amount requested in this claim. Furthermore, the Club stated
that, with regard to the WhatsApp communications, there was no mention of any specific
bonus amount, only that bonuses existed for the UEFA Women’s Champions League™. The
Club explained that these bonuses related to appearances and victories in the Champions
League, which, according to the initial agreement, were to apply in the additional 12-month
period.
15. In light of the above, the Club made the following requests for relief:
“We request that the other party withdraw the bonus claims, as no such bonuses are
provided in any signed contract, and that we conclude a settlement regarding the last
unpaid salary, which we are ready to pay within 7 days from the date of the agreement.”
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
16. First of all, the Single Judge of the Dispute Resolution Chamber (hereinafter: the Single Judge)
analysed whether she was competent to deal with the case at hand. In this respect, she
took note that the present matter was presented to FIFA on 11 November 2025 and
submitted for decision on 20 January 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.
17. 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
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REF. FPSD-21859
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 Brazilian player and a North Macedonian club.
18. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, she 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
19. 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 she 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
20. 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, she will refer only to the facts, arguments and documentary evidence,
which she considered pertinent for assessing the matter at hand.
i. Main legal discussion and considerations
21. The Single Judge then moved to the substance of the matter, noting that it concerned a
claim brought by a player against a club for outstanding remuneration.
22. The Single Judge recalled that, according to the Player, the Club failed to pay her last salary
and the bonus for qualifying for the UEFA Women’s Champions League™. Additionally, the
Single Judge noted that the Club acknowledged that the last salary remained unpaid but
rejected the claim regarding the bonus.
23. In this context, the Single Judge acknowledged that her task was to determine whether the
Player was entitled to the amounts claimed.
24. First, regarding the salary, the Single Judge noted that the Club acknowledged that it
remained unpaid. Although the Player requested this amount in EUR, indicating that the
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REF. FPSD-21859
salary used to be paid in EUR despite the Contract stipulating MKD, the Single Judge noted
that she failed to provide any evidence to support these allegations. Furthermore, the Club,
while accepting that it owed the last salary, did not expressly agree to pay it in EUR, thereby
deviating from the provisions of the Contract.
25. Thus, based on the standard practice of the Football Tribunal, the Single Judge decided to
award the amount in the currency stipulated in the Contract, i.e., MKD 40,000. Since the
Player made a generic request for interest and based on the standard practice of the
Football Tribunal, the Single Judge decided to award 5% interest p.a. over this amount as
from the date of the claim, i.e., 11 November 2025.
26. In connection with the bonus, the Single Judge noted that the Player argued that (i) the Club
Director promised her that she would receive a bonus for the UEFA Women’s Champions
League™ and (ii) the Club qualified for the UEFA Women’s Champions League™, thereby
triggering the obligation to pay a bonus equivalent to one month’s salary. Conversely, the
Club argued that there was no signed document establishing a bonus and that the
WhatsApp communications contained no mention of a specific amount.
27. In this case, the Single Judge considered that the Club’s position must prevail. While the
Club did not dispute the WhatsApp communications, the Single Judge recalled that the
message on which the Player relies only stated: “Bonuses for champions league”. In this
sense, the Single Judge did not find any specific promised amount for this alleged bonus,
nor any explanation of the triggering event - let alone that the Player would receive EUR
650 for qualifying for the UEFA Women’s Champions League™. Based on this message, the
Single Judge could not conclude that the Club undertook to pay an amount corresponding
to one month’s salary in case the Club qualified for the UEFA Women’s Champions
League™.
28. More importantly, the Single Judge considered that the Contract did not provide for any
specific bonus, as clause 14 was quite generic. In the Single Judge’s view, should the parties
have intended to agree upon a bonus equivalent to one monthly salary in case the Club
qualified for the UEFA Women’s Champions League™, they would have specifically included
it in the Contract, which novated the terms of any proposal that the Club could have made
to the Player, as it was the final and binding contract governing the employment
relationship.
29. In the absence of any specific provision or evidence demonstrating that the parties agreed
upon this alleged bonus, the Single Judge decided to reject this part of the claim due to lack
of contractual basis.
pg. 7
REF. FPSD-21859
ii. Art. 12bis of the Regulations
30. 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.
31. 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.
32. 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.
33. 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,
and bearing in mind that this is the fourth offense by the Respondent within the last two
years, the Single Judge decided to impose a warning and a fine of USD 750 on the
Respondent in accordance with art. 12bis par. 4 lit. a) and c) of the Regulations.
34. 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
35. 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.
36. 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.
37. 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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REF. FPSD-21859
38. 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.
39. 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
40. 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.
41. 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.
42. Lastly, the Single Judge concluded her deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 9
REF. FPSD-21859
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Natalia Luana Oliveira Silva, is partially accepted.
2.
The Respondent, ZHFK Ljuboten, must pay to the Claimant MKD 40,000 as outstanding
remuneration plus 5% interest p.a. as from 11 November 2025 until the date of effective
payment.
3.
Any further claims of the Claimant are rejected.
4.
A warning and a fine in the amount of USD 750 are imposed on the Respondent, which
must be paid to FIFA within 30 days of notification of this decision. Such fine must be
paid to the following bank account with a clear reference to the case FPSD-21859:
UBS Zurich
Account number 230-366677.61N (FIFA Players’ Status)
Clearing number 230
IBAN: CH12 0023 0230 3666 7761 N
SWIFT: UBSWCHZH80A
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.
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.
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REF. FPSD-21859
8.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
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REF. FPSD-21859
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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