Labour Disputes
Texto da decisão
REF. FPSD-22181
Decision of the
Dispute Resolution Chamber
passed on 4 February 2026
regarding an employment-related dispute concerning
the player Moussa Coulibaly
BY:
Iñigo RIESTRA, Mexico
CLAIMANT:
Moussa Coulibaly, Mali
Represented by Roy Vermeer
RESPONDENT:
Al Khaldiya SC, Bahrain
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REF. FPSD-22181
I. Facts of the case
1.
On 12 August 2025, the Malian player Moussa Coulibaly (hereinafter: the Player or the
Claimant) and the Bahraini club Al Khaldiya SC (hereinafter: the Club or the Respondent)
entered into an employment contract (hereinafter: the Contract) valid as from 13 August
2025 and until 31 May 2026 or the end date of the sports season 2025-2026, whichever
came later.
2.
Clauses 2 and 3 of the Contract provided:
“2. The following laws and regulations form an integral part of this Contract:
A. Statutes and regulations of the Club and particularly the Disciplinary Code Technical
regulations for professionalizing with its amendments that occur from time to time to
period.
B. Statutes and regulations of the Bahrain Football Association, FIFA and AFC.
3. The Player acknowledges and accepts that the aforementioned laws and regulations
are strictly binding on him, and he read and understood their contents before signing
this Contract.”
3.
Clauses 6, 7 and 8 of the Contract established:
“• THE FINANCIAL TERMS AND BENEFITS
6. Player's Total Remunerations: for the entire Term of this Contract mentioned in
Clause 5 above, the Player will be entitled to the total amount of USD 230,000 (Two
Hundred Thirty Thousand USD only) Which is equivalent to 86,250 Bahraini dinars
(Eighty Six Thousand Two Hundred Fifty Bahraini dinars) only (Total Contract Value) to
be paid to the Player into 10 equal monthly payments, each of USD 23,000 (Twenty Three
Thousand USD only) equivalent to BHD 8,625 (Eight Thousand Six Hundred Twenty Five
Bahraini Dinars) each to be paid at the end of each calendar month starting from August
2025 until end of May 2026.
7. The Club shall pay the Player a monthly housing allowance of up to USD 1,066
(equivalent to BHD 400), provided that the Player submits a rental agreement or hotel
invoices for the purpose of determining the payable housing allowance. This allowance
shall be provided only for the duration of the contract, which is limited to the sports
season period, and shall not exceed the maximum amount stated above.
8. The Club shall pay the Player a monthly transportation allowance of up to USD 533
(equivalent to BHD 200 Bahrain dinars), provided that the Player submits a vehicle
rental agreement transportation invoices for the purpose of determining the payable
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REF. FPSD-22181
transportation allowance. This allowance shall be paid only for the duration of the
contract, which is limited to the sports season period, and shall not exceed the monthly
amount stated above.”
4.
Clause 23 lit. g) of the Contract provided as follows:
“g) The Player is obliged to pay any fine imposed by the BFA, Asian Football
Confederation and any other entity as a result of his action or statements before, during
and after the game.”
5.
Clause 24 of the Contract determined:
“• Disciplinary Measures
24. If the Player violates any of his duties, responsibilities, and obligations stipulated in
the Contract or commits a violation contrary to the Club's Disciplinary Code, the Club
shall have the right to apply one of the following disciplinary measures as per the
severity of the breach:
a.Warning.
b.Fines.
c. Suspension of the Contract for a particular period without payment.
d.Termination of the Contract.
Particularly, but not exclusively, the Club shall have the right to impose the above fines,
or the fines stipulated in the Professional Regulations:
a.If the Player misses a training session without a valid reason.
b.If the Player misses a match without a valid reason.
c. In case, according to the technical and medical staff report, the player's fitness and
performance were shown to have declined as a result of negligence of the Player.
d.In the event that it is evident, when conducting the medical examinations that the
club performs periodically, and/or according to the medical report approved by the
medical committee / medical team of the first team, that the Player behaves in a
manner that affect his performance as a football player, then the Club has the right to
impose disciplinary sanctions stipulated in this Contract or ones stipulated in the
professional regulations of the Club for the first time and in the event of a repeat by
the Player the club has the right to take the maximum measures against the Player
reach to the termination of this Contract.”
6.
Clauses 35 and 37 of the Contract established:
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REF. FPSD-22181
“35. Any variation or amendments to this Contract shall not be valid or binding and
shall not be part of this Contract unless it is in writing and signed by or on behalf of the
parties.
37. This Contract reflects the entire agreement of the Parties and supersedes all prior
agreements and contracts of the parties, whether written or otherwise. With respect to
the subject matter of this Contract.”
7.
On an unspecified date, the Club issued a payslip to the Player reflecting a monthly salary
of BHD 8,761.774 for October 2025. The Club deducted several amounts from the Player’s
salary, namely BHD 278.226 for “leaving training early”, BHD 562.50 for “AFC fine”, BHD
862.50 for “repeatedly being late to training”, and BHD 40 for “absence from team
gathering”. In total, the Club deducted BHD 1,743.226 from the October 2025 salary.
8.
On 10 November 2025, the Club issued a cheque in favour of the Player for BHD 6,881.775
and an invoice specifying the deductions. According to the Player, he signed this document
on 22 November 2025.
9.
On 14 November 2025, the Player sent a notice to the Club alleging that, on 11 November
2025, he received an email from the Club informing him that BHD 1,743.266 was to be
deducted from his salary of October 2025 on the basis of art. 23 lit. g) of the Club’s internal
regulations (hereinafter: the Internal Regulations). The Player stated that he rejected the
deductions as (i) he rejected any irregularities in relation to his participation, (ii) he did not
act improperly, and (iii) he was not informed of any fine imposed by the Asian Football
Confederation (AFC), while he, in any case, refuted that a fine for receiving a red card in the
course of play could be deducted from his salaries. Furthermore, the Player argued that
the Internal Regulations were not applicable to him as (i) this document was not made
available to him when he signed the Contract, and (ii) given the disproportionate content,
he refused to sign it when the Club presented it to him. Hence, the Player requested that
the Club confirm, within the following five days, that the October 2025 salary was to be paid
without any deductions.
10. On 18 November 2025, the Club replied to the letter stating that the Internal Regulations
were applicable to the Player based on clause 2 of the Contract. Moreover, the Club argued
that it conducted a full and objective review of the incident and established that the
measures were imposed in accordance with the Contract and the Internal Regulations. The
Club maintained that the Player shall also be responsible for the fine imposed by the AFC
regarding the red card and rejected the Player’s allegations. Lastly, the Club confirmed that
the deductions were lawful.
11. On 19 November 2025, the Player replied to the Club’s letter, reiterating the content of his
previous letter and remarking that he was never informed that the Club had initiated a
disciplinary process against him, let alone that he was invited to participate in such a
process, violating his right to be heard. The Player stated that the Club failed to provide
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REF. FPSD-22181
him with the alleged disciplinary code and mentioned that he would collect his salary for
October 2025, but that this would not imply acceptance of the deductions.
12. On 23 November 2025, the Player received a transaction notification from the Al Salam
Bank informing him that BHD 6,881.775 had been credited to his account.
II. Proceedings before FIFA
13. On 2 December 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
14. The Player argued that the parties concluded the Contract, under which he was entitled to
a monthly salary of USD 23,000 or BHD 8,625 per month, as well as to accommodation and
transportation. Furthermore, the Player stated that in October 2025, he was requested by
the Club to sign the Internal Regulations, which he refused, since he did not agree with the
excessive sanctions.
15. According to the Player, on 11 November 2025, he received an email by means of which he
was informed that BHD 1,743.266 was to be deducted from his salary of October 2025 for
various alleged disciplinary violations, based on the Internal Regulations. The Player further
contended that he rejected the deductions, but the Club insisted, arguing that the
deductions were imposed through a disciplinary review procedure and that he was subject
to the Internal Regulations and the Club’s disciplinary code. Nevertheless, the Player
mentioned that he had reiterated his position and that the Club never replied to him.
16. In this context, the Player argued that on 22 November 2025, he received a cheque dated
10 November 2025, which he cashed the following day, and also had to sign a payment
voucher dated 10 November 2025, which outlined the deductions.
17. The Player disputed that the fines were legitimately deducted based on the following
provisions:
•
•
•
The Contract did not specify that any deductions could be made on the basis of the
Internal Regulations, and those regulations were never mentioned in the Contract nor
given to the Player when he signed the Contract. Therefore, the Player affirmed that
the deductions cannot apply;
Moreover, the Player argued that he refused to sign the Internal Regulations due to the
excessive nature of the document. Hence, the Player asserted that he did not give his
consent;
Even if the Internal Regulations were applicable to him, there was no evidence of the
alleged violations, and the Player was never informed of the alleged irregularities;
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REF. FPSD-22181
•
•
He was never invited to state his position in any disciplinary process;
Although he acknowledges that he received a red card, he argued that he was also
never informed about a disciplinary process regarding this and that, based on standard
practice, he cannot be held liable for it, as the red card was part of the normal course
of a match.
18. The Claimant’s requests for relief were the following:
“C) Request for Relief:
As a consequence of all of the above, the Player is requesting the FIFA DRC to order the
Club to pay him the amount of BHD 1,744 plus 5% interest per annum as from 1
November 2025.”
b. Position of the Respondent
19. Despite having been invited to do so, the Respondent failed to reply to the claim within the
granted deadline, i.e., no later than 17 January 2026.
20. On 26 January 2026, the FIFA general secretariat acknowledged that no reply had been
received from the Respondent and informed the parties, inter alia, that the submissionphase was therefore closed (cf., art. 23 par. 1 of the Procedural Rules Governing the
Football Tribunal; hereinafter: the Procedural Rules).
21. On 27 January 2026, the Club filed an unsolicited correspondence.
22. On the same date, the FIFA general secretariat acknowledged receipt of the above
correspondence and informed the Club that its submission would be disregarded, based
on art. 23 par. 1 of the Procedural Rules.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
23. 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 2 December 2025 and submitted
for decision on 4 February 2026. Taking into account the wording of arts. 31 and 34 of the
January 2026 edition of the Procedural Rules, the aforementioned edition of the Procedural
Rules is applicable to the matter at hand.
24. 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-22181
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 Malian player and a Bahraini club.
25. 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
26. 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
27. 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
28. The Single Judge then moved to the substance of the matter and took note of the fact that
this was a claim brought by a player against a club for outstanding remuneration.
29. The Single Judge recalled that, according to the Player, the Club unlawfully deducted him
BHD 1,744 from the salary for October 2025.
30. Since the Respondent did not provide its position on the claim within the granted deadline,
the Single Judge determined that his decision should be taken based on the documentation
already in the file (i.e., the statements and documents presented by the Claimant) (cf., art.
21 par. 1 of the Procedural Rules).
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REF. FPSD-22181
31. In this context, the Single Judge acknowledged that his task was to establish whether the
Club was entitled to deduct the amount claimed by the Player and, if not, the ensuing
consequences.
32. First, the Single Judge recalled that, in line with established jurisprudence of the Football
Tribunal and the Court of Arbitration for Sport (CAS), clubs may, as a general principle,
impose on players and offset such amounts against salary only where the parties have
expressly agreed to the possibility of set-off. That said, CAS has applied a restrictive
approach to such mechanisms, emphasizing that any set-off of fines must not deprive an
employee of their basic salary nor be implemented in an abusive or disproportionate way
(see, for example, CAS 2018/A/5807). Moreover, according to the jurisprudence of the
Football Tribunal, financial penalties – including fines or any comparable monetary
sanctions – cannot be used by clubs as a tool to circumvent or reduce outstanding financial
obligations owed to players.
33. Furthermore, the Single Judge recalled that in previous cases addressing this issue, the
Football Tribunal has analysed whether a proper disciplinary process was followed by the
club and whether the player’s right to be heard was respected. Additionally, it has assessed
whether the fine was excessive or proportionate.
34. With all the above in mind, the Single Judge decided that he had to analyse whether (i) there
was an agreement expressly allowing set-off; (ii) a proper disciplinary process was followed
by the Club; and (iii) the penalty was proportionate.
35. Regarding the existence of an agreement between the parties, the Single Judge observed
that the Contract did not expressly provide that the Club was entitled to deduct any amount
from the Player’s salary; however, according to the Club’s letter dated 18 November 2025,
the Internal Regulations did.
36. In this regard, the Single Judge noted that the Player himself provided a copy of the Internal
Regulations but alleged that he was not bound by them, as he refused to sign them. The
Single Judge further observed that, in fact, the Player provided an unsigned copy of the
Internal Regulations and that the Club, by not replying to the claim, did not dispute this
allegation. Although the Single Judge was aware that clause 2 of the Contract established
that the Internal Regulations and the “disciplinary code” formed an integral part of the
Contract, the Player argued that he was not provided with these documents at the time he
signed the Contract.
37. Considering that it was the Club that made the deductions by arguing that they were based
on the Internal Regulations and the disciplinary code, the Single Judge interpreted that it
was the Club that bore the burden of demonstrating that the Player actually received the
Internal Regulations and expressly allowed the Club to make any set-off. The Single Judge
stressed that the fact that the Contract referred to the Internal Regulations was not
sufficient to determine that the Player accepted all their terms without expressing any
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REF. FPSD-22181
specific consent, as otherwise - as the Player mentioned - the Club could modify the terms
of these regulations without the Player’s consent at any time.
38. In the absence of any evidence demonstrating that there was an agreement expressly
allowing set-off, the Single Judge was already convinced that the deductions lacked
contractual basis.
39. Without prejudice to the above, the Single Judge underscored that even if it were
understood that the Player was actually bound by the Internal Regulations based on the
Contract, it could not be established that a proper disciplinary process was followed by the
Club.
40. In this regard, the Club failed to present any proof demonstrating that it duly notified the
Player that a disciplinary investigation had been initiated against him, which could lead to
the imposition of sanctions, and that he was granted a time limit to respond to the
allegations. In any event, the Single Judge was of the opinion that it was for the Club to
prove that such a defense was granted and it failed to discharge its burden of proof.
41. In the absence of such evidence, the Single Judge could not determine that the Player’s
right to be heard was actually respected.
42. Moreover, the Single Judge remarked that the Player denied having committed any of the
alleged infractions and the Club failed to provide any evidence in this regard. Therefore,
even if the Single Judge was to disregard the previous analysis (quad non), there was still
no evidence demonstrating that the alleged causes of the deductions actually occurred.
Although the Player acknowledged having received a red card, the Club failed to submit
any evidence that the AFC indeed imposed a fine in this respect.
43. Lastly, although the Player acknowledged that he signed a receipt that included a
breakdown of the deductions, the Single Judge noted that he argued that it was backdated.
In this context, the Single Judge observed that the Player, in his notice of 19 November
2025, expressly informed the Club that he would sign this document, which was consistent
with his argument. In any case, the Club failed to provide any evidence demonstrating that
the Player signed this document prior to sending his notice. In any event, the Single Judge
wished to point out that, had the Player signed this receipt before sending the notice, this
would not amount to an acceptance of the deductions, as he promptly reacted and sent a
notice rejecting them.
44. Based on all the above, the Single Judge determined that – from any angle – the Club was
not entitled to deduct any amounts from the Player’s salary.
45. Since the Player was entitled to a monthly salary of BHD 8,625 and, based on the evidence
provided by the Player, the Club deducted BHD 1,743.226, the Single Judge decided to
award the Player BHD 1,743.226. In addition, since the salary was payable at the end of
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REF. FPSD-22181
each month, the Single Judge decided to award 5% interest p.a. as from the day following
the due date, i.e., 1 November 2025.
ii. Compliance with monetary decisions
46. 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.
47. 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.
48. 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.
49. 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.
50. 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
51. 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.
52. 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.
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53. 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-22181
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Moussa Coulibaly, is partially accepted.
2.
The Respondent, Al Khaldiya SC, must pay to the Claimant BHD 1,743.226 as outstanding
remuneration plus 5% interest p.a. as from 1 November 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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