Labour Disputes
Texto da decisão
REF. FPSD-22220
Decision of the
Dispute Resolution Chamber
passed on 9 April 2026
regarding an employment-related dispute concerning the player Sallah
Moussaddaq Kerboub
COMPOSITION:
Lívia SILVA KÄGI (Brazil & Switzerland), Deputy Chairwoman
Andre DOS SANTOS MEGALE (Brazil), Member
Michele COLUCCI (Italy), Member
CLAIMANT / COUNTER-RESPONDENT:
Sallah Moussaddaq Kerboub, Spain
Represented by Fahmi Belhadj Mohamed
RESPONDENT / COUNTERCLAIMANT:
El Zamalek, Egypt
pg. 2
REF. FPSD-22220
I. Facts of the case
1.
On 6 February 2025, the Spanish player Sallah Moussaddaq Kerboub (hereinafter: the
Player or the Claimant / Counter-Respondent) and the Egyptian club El Zamalek (hereinafter:
the Club or the Respondent / Counterclaimant) entered into an employment contract
(hereinafter: the Contract) for four seasons (2024/2025 to 2027/2028), with a total value of
USD 1,020,000.
2.
Pursuant to clause 2 of the Contract, the Club undertook to remunerate the Player as
follows:
3.
•
Season 2024/2025: USD 120,000 net
o USD 30,000 net on 15 February 2025
o USD 30,000 net on 30 March 2025
o USD 30,000 net on 15 May 2025
o USD 30,000 net on 30 June 2025
•
Season 2025/2026: USD 250,000 net
o USD 62,500 net on 1 September 2025
o USD 62,500 net on 1 January 2026
o USD 62,500 net on 1 April 2026
o USD 62,500 net on 1 July 2026
•
Season 2026/2027: USD 300,000 net
o USD 75,000 net on 1 September 2026
o USD 75,000 net on 1 January 2027
o USD 75,000 net on 1 April 2027
o USD 75,000 net on 1 July 2027
•
Season 2027/2028: USD 350,000 net
o USD 62,500 net on 1 September 2027
o USD 62,500 net on 1 January 2028
o USD 62,500 net on 1 April 2028
o USD 62,500 net on 1 July 2028
Clause five of the Contract provided:
“Fifth: Termination of the contract:
1. The employment contract maybe terminated by mutual agreement.
2. The Player or Club cannot unilaterally terminate the contract unless the right to terminate
the contract is stipulated in the FIFA Regulations on the Status and Transfer of Players (FIFA
RSTP). Particular reference is made to art. 13, art 14, and art 14 bis and 17 of the FIFA RSTP,
pg. 3
REF. FPSD-22220
which state that a party may terminate a contract where there is just cause. If there is just
cause, the contract may be terminated at any time, even during the course of a season.
3. If the Player or Club unilaterally terminates the contract for a just cause reason the other
party will be liable to pay compensation, in accordance with the FIFA RSTP and the
jurisprudence of the FIFA DRC. Likewise if the Player or Club unilaterally terminates the
contract without just cause the party in breach will be liable to pay compensation, in
accordance with the FIFA RSTP and the jurisprudence of the FIFA DRC. In the event of a
dispute,
In the event of dispute:
1. All disputes that arises between the Club and a Player with the Egyptian nationality as a
result of or in connection with this Agreement will be submitted for a decision to the National
Dispute Resolution Chamber (NDRC) of the Egypt Football Association.
2. If the Player does not have the Egyptian nationality, a dispute that arises between the Club
and the Player as a result of or in connection with this Agreement may also be submitted by
him to the FIFA DRC.”
4.
On 3 November 2025, the Player sent a formal notice to the Club requesting payment of
the outstanding USD 62,500, granting a 15‑day deadline and warning of termination for
just cause.
5.
On 9 November 2025, the Club made a partial payment of USD 20,800.
6.
On 19 November 2025, upon expiry of the notice period, the Player terminated the
Contract citing just cause based on art. 14 and 14bis of the FIFA Regulations on the Status
and Transfer of Players (hereinafter: the Regulations).
7.
In January 2026, the Player entered into a new employment contract with the Moroccan
club WYDAD ATHLETIC CLUB (hereinafter: Wydad AC), which was originally valid from 8
January 2026 until 30 June 2027. Accordingly, the Player is entitled to the following fixed
remuneration:
•
•
•
8.
MAD 30,000 net as monthly salary;
MAD 570,000 net as signing fee; and
MAD 7,000 net as monthly accommodation allowance.
This contract also provided for an extension option for one extra season (2027/2028).
pg. 4
REF. FPSD-22220
II. Proceedings before FIFA
9.
On 4 December 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 submitted that the Club failed to pay the amount of USD 62,500, due on 1
September 2025. He argued that, in accordance with art. 14bis of the Regulations, he
placed the Club in default on 3 November 2025, granting a period of 15 days to remedy the
breach.
11. He contended that the Club only made a partial payment of USD 20,800 on 9 November
2025, which did not cure the substantial outstanding debt.
12. The Player asserted that the Club’s persistent failure to pay more than the equivalent of
two monthly salaries constituted a serious breach of contractual obligations. He alleged
that the failure to comply within the granted deadline entitled him to terminate the
Contract for just cause, which he did on 19 November 2025.
13. The Player then alleged entitlement to compensation corresponding to the residual value
of the Contract (USD 837,500), given that he was unemployed after contract termination.
He further argued that, due to overdue payables, he was entitled to additional
compensation of six monthly salaries (USD 127,500), citing the psychological, financial, and
procedural damage suffered.
14. The Player requested the following relief:
“In view of the documents and the FIFA RSTP (Articles 14, 14 bis, and 17), the FIFA Dispute
Resolution Chamber is requested to:
Declare and rule that the FIFA DRC is competent to hear the present dispute between
player Sallah Moussaddaq and Zamalek S.C.
Declare and rule that the player’s claim is well-founded and that:
– The termination of Mr. Sallah Moussaddaq’s contract occurred for just cause and is
attributable to the club.
Order Zamalek S.C. to pay the following amounts to the player:
– 41,700 USD, subject of the formal notice, with 5% annual interest from 03/11/2025 until
full payment.
pg. 5
REF. FPSD-22220
– 837,500 USD as compensation for premature termination, with 5% interest from the
date of the decision until full payment, detailed as follows:
2025/2026 season – total 187,500 USD:
– 62,500 USD payable on 01/01/2026
– 62,500 USD payable on 01/04/2026
– 62,500 USD payable on 01/07/2026
2026/2027 season – total 300,000 USD:
– 75,000 USD payable on 01/09/2026
– 75,000 USD payable on 01/01/2027
– 75,000 USD payable on 01/04/2027
– 75,000 USD payable on 01/07/2027
2027/2028 season – total 350,000 USD:
– 87,500 USD payable on 01/09/2027
– 87,500 USD payable on 01/01/2028
– 87,500 USD payable on 01/04/2028
– 87,500 USD payable on 01/07/2028
– 127,500 USD as additional compensation, with 5% interest from the decision date until
full payment.
Pronounce the disciplinary sanctions provided for in Article 24 bis in case of non-payment
within the prescribed deadline, including a ban on registering new players nationally or
internationally.”
b. Reply and counterclaim of the Club
15. On 11 January 2026, the Club provided its reply to the claim.
16. The Club argued that the claim is entirely unfounded and based on a fabricated narrative
of non-payment. It maintained that the Player terminated the Contract in bad faith with the
intention of leaving the Club during the transfer window and signing immediately with
another club, which he allegedly did with Wydad AC.
17. The Club submitted that the Player’s contractual remuneration was structured in quarterly
instalments, not monthly salaries. It argued that the Player improperly attempted to
reclassify these instalments as monthly payments to artificially create the appearance of
overdue salaries. The Contract allegedly contains no clause linking instalments to specific
calendar months.
18. The Club emphasised that the instalment due on 1 September 2025 was a quarterly
payment, and thus art. 14bis of the Regulations (two months’ salary overdue) could not be
applied based on a reinterpretation of the instalment. It further stated that the Player’s
pg. 6
REF. FPSD-22220
attempt to impose a “monthly salary interpretation” contradicted the Contract and FIFA
jurisprudence, which requires adherence to the written terms.
19. According to the Club, art. 14bis was not satisfied because:
•
Two months’ equivalent salary would amount to approximately USD 41,666,
calculated from the quarterly instalment;
•
The Club’s payment of USD 20,800 on 9 November 2025 occurred within the cure
period and therefore legally prevented termination;
•
In line with consistent jurisprudence of the Football Tribunal and the Court of
Arbitration for Sport (CAS), even partial payments made within the cure period
block termination rights.
20. Thus, the Player allegedly terminated the Contract prematurely and without just cause.
21. The Club asserted that any remaining balance was part of a quarterly instalment
undergoing settlement. According to the Club, art. 14bis applies only to serious and
persistent non-payment, not to minor, temporary delays. Therefore, the conditions for just
cause were not met.
22. The Club also disputed, in the alternative, the amount of compensation claimed by the
Player, as (i) the Player signed a new contract with Wydad AC that had not been considered;
and (ii) no additional compensation apply.
23. The Club requested the following relief:
“Zamalek Sporting Club respectfully requests the FIFA Dispute Resolution Chamber to:
1. Reject the Player’s claim in its entirety;
2. Declare that the Player terminated the contract without just cause;
3. Dismiss all financial claims, including residual and additional compensation;
4. Reject all sporting sanctions;
5. Order the Player to compensate Zamalek SC for breach of contract with the whole
value of his new contract with Wydad Club.”
c. Reply to the counterclaim of the Player
24. On 21 January 2026, the Player submitted his rejoinder on this matter.
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REF. FPSD-22220
25. The Player argued that the Club incorrectly attempted to requalify the contractually agreed
quarterly instalments as “monthly salaries.” He stressed that the Contract explicitly
provided four quarterly payments per year, with no monthly salary basis. He submitted
that this structure formed an essential contractual element and could not be unilaterally
rewritten by the Club.
26. The Player maintained that art. 14bis of the Regulations expressly provides that, when
salaries are not monthly, the equivalent of two monthly salaries must be calculated pro
rata solely to assess whether the threshold for termination is reached. He argued that the
Club’s interpretation – redividing the quarterly instalment into artificial “monthly segments”
– is contrary to the text and purpose of art. 14bis of the Regulations.
27. The Player contended that only full payment of the overdue amounts can cure the Club’s
default under art. 14bis par. 1 of the Regulations. He emphasised that the Club’s partial
payment of USD 20,800 did not extinguish its contractual debt and therefore did not
neutralise his right to terminate for just cause. He insisted that the relevant debt must be
analysed solely on the basis of the contractually due instalment, not on reconstructed
monthly equivalents.
28. The Player submitted that:
•
The amount overdue corresponded to more than two months’ salary
equivalence, since a quarterly instalment equals three months of pay.
•
A proper 15-day notice was issued.
•
The Club failed to fully cure the default within the prescribed time.
29. Accordingly, he reaffirmed that all conditions under art. 14bis were met and that his
unilateral termination was lawful and justified.
30. The Player expressly confirmed that he maintains all claims submitted in his initial
statement of claim, asserting that the Club’s reply provides no legal basis for dismissal.
d. Duplica of the Club
31. On 29 January 2026, the Club filed its final comments.
32. In its further submission, the Club reiterates that the arguments brought forward by the
Player remain legally unfounded and rely on an excessively formalistic interpretation of the
Contract. According to the Club, this interpretation contradicts well-established
jurisprudence of both FIFA and CAS, particularly regarding the correct application of art.
14bis of the Regulations.
pg. 8
REF. FPSD-22220
33. The Club further explained that, although the Contract provided for quarterly instalments,
this did not alter the fact that the Player’s remuneration must be regarded as monthly in
nature. FIFA and CAS decisions have repeatedly held that salaries paid on a quarterly,
semi-annual, or lump-sum basis do not lose their monthly legal character, because the
employment relationship is performed and evaluated on a monthly basis. The Club
therefore rejected the Player’s assertion that the quarterly payment schedule prevents a
pro rata analysis under art. 14bis.
34. The Club asserted that art. 14bis had a defined protective purpose, namely to allow
termination only when at least two monthly salaries are outstanding at the moment of
termination. Consequently, the Club maintained that the relevant benchmark is the
monthly value of the remuneration, not the contractual instalment as such. It highlighted
that art.14bis par. 2 explicitly requires a pro rata calculation when salaries are not paid
monthly, meaning that the outstanding balance must be converted into monthly terms
before assessing whether the threshold permitting termination has been reached.
35. Turning to the issue of partial payment, the Club argued that the Player’s position is legally
incorrect. According to consistent FIFA and CAS jurisprudence, partial payments must
always be deducted from the total amount due before evaluating whether the residual
debt reaches the equivalent of two monthly salaries. While a partial payment does not
necessarily extinguish a default, it does directly and materially affect the calculation of the
outstanding amount under art. 14bis. For this reason, the Club submitted that the Player’s
approach, which disregarded the reduction of the remaining debt after the payment made
on 9 November 2025, is contrary to established jurisprudence.
36. The Club also argues that the Player has failed to discharge the burden of proof imposed
by art. 13 par. 5 of the Procedural Rules. In its view, the Player did not provide precise
evidence establishing the amount outstanding at the date of termination, did not
demonstrate that such amount corresponded to at least two monthly salaries, and did not
show that this alleged situation persisted after the expiry of the 15-day notice period. As a
result, the Player’s allegations remain unsubstantiated and cannot satisfy the strict
evidentiary thresholds required in disputes involving termination for just cause.
37. Further, the Club concluded that, based on all legal and factual considerations, the
conditions of art. 14bis were not fulfilled at the moment of termination. It reiterated that
the Player was therefore not entitled to terminate his employment contract and that the
termination carried out on 19 November 2025 must be regarded as one effected without
just cause.
38. The Club provided the following:
“In light of the foregoing, the Respondent respectfully requests the FIFA Football Tribunal
to:
pg. 9
REF. FPSD-22220
1‑ Reject the Claimant’s arguments based on an alleged quarterly nature of
remuneration;
2‑ Confirm that the salary must be assessed on a monthly basis;
3‑ Find that the conditions of Article 14bis RSTP were not met at the time of termination;
4‑ Declare that the Player terminated the employment contract without just cause;
5‑ Dismiss all financial claims submitted by the Claimant in their entirety.”
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
39. First of all, the Dispute Resolution Chamber (hereinafter: the Chamber or DRC) analysed
whether it was competent to deal with the case at hand. In this respect, it took note that
the present matter was presented to FIFA on 4 December 2025 and submitted for decision
on 9 April 2026. Taking into account the wording of arts. 32 and 35 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.
40. Furthermore, the Chamber 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 an Spanish player and a Egyptian club.
41. Subsequently, the Chamber 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
42. The Chamber 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 Chamber stressed
the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which it 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
43. Having established the competence and the applicable regulations, the Chamber entered
into the merits of the dispute. In this respect, the Chamber started by acknowledging all
pg. 10
REF. FPSD-22220
the above-mentioned facts as well as the arguments and the documentation on file.
However, the Chamber emphasised that in the following considerations it will refer only to
the facts, arguments and documentary evidence, which it considered pertinent for
assessing the matter at hand.
i. Main legal discussion and considerations
44. The Chamber then moved to the substance of the matter, noting that it concerned a claim
and counterclaim for breach of contract between a player and a club.
45. The Chamber noted that the Player submitted that the Club failed to pay the full instalment
of USD 62,500 due on 1 September 2025 and, after having been placed in default on 3
November 2025 with a 15-day deadline, only made a partial payment of USD 20,800 that
did not extinguish the outstanding debt. He argued that pursuant to art. 14bis of the
Regulations, only full settlement blocks the right to terminate, and that the unpaid
quarterly instalment corresponds to more than two months of remuneration, thereby
satisfying the statutory threshold for just cause to terminate. He therefore terminated the
Contract on 19 November 2025 and seeks outstanding remuneration, compensation equal
to the residual value of the Contract, and additional compensation under art. 17 of the
Regulations, along with possible sporting sanctions.
46. Conversely, the Chamber recalled that the Club maintained that the claim was unfounded,
contending that even though the Contract provides for quarterly instalments,
remuneration must legally be considered monthly under consistent FIFA and CAS
jurisprudence. Therefore, the Club alleged that the outstanding amount should be
evaluated in monthly equivalents. Similarly, its partial payment within the notice period
reduced the outstanding balance below the two-month threshold of art. 14bis of the
Regulations, meaning just cause did not exist. It claimed the Player acted in bad faith by
manufacturing a termination to join another club and asserted that the Player failed to
prove that two months’ salary remained unpaid after the cure period. Accordingly, it
submitted the termination was without just cause and requests dismissal of all claims, as
well as compensation from the Player.
47. From the parties’ submissions, the DRC identified four core issues to be herein assessed:
A. Whether the quarterly instalment may be treated as the basis for assessing
overdue payables, or whether a monthly assessment must prevail under art.
14bis of the Regulations.
B. Whether the partial payment of USD 20,800 made during the cure period affected
the running of the 15‑day default notice and reduced the outstanding amount
below the “two‑monthly‑salary” threshold.
pg. 11
REF. FPSD-22220
C. Whether the Player had just cause to terminate the Contract on 19 November
2025.
D. The consequences arising from these conclusions.
48. The Chamber then proceeded to analyse each of these issues in turn.
A. QUARTERLY INSTALMENT VS. MONTHLY‑SALARY ASSESSMENT
49. The Chamber initially recalled that the Player emphasised that the parties explicitly agreed
to quarterly remuneration and that such instalments are contractually indivisible; thus, the
overdue amount should be evaluated as the unpaid quarterly amount of USD 62,500,
which corresponded to three months’ remuneration. He submitted that art. 14bis par. 2 of
the Regulations requires only a pro rata calculation to verify the threshold, not a recharacterisation of instalments as “monthly salaries.”
50. On the other hand, the Chamber noted that the Club argued that, regardless of payment
periodicity, FIFA and CAS consistently treat player remuneration as monthly in nature,
meaning that overdue payments must be assessed in monthly equivalents. It maintained
that quarterly payment schedules do not alter the monthly legal character of earnings and
that the Player’s argument contradicts established jurisprudence.
51. In assessing these positions, the DRC underscored that – as rightly pointed out by the
Player - art. 14bis par. 2 of the Regulations explicitly anticipates situations where salaries
are not paid monthly and requires a pro rata calculation to determine whether two monthly
salaries are outstanding.
52. The Chamber then established that in the present case the unpaid quarterly instalment
contractually represented three months’ remuneration:
•
•
12 months / 4 instalments = 3 months per instalment
Monthly salary = USD 20,833.33
53. Accordingly, the DRC concluded that even under a pro rata approach, the unpaid amount
exceeded the two-month threshold established under art. 14bis of the Regulations.
B. EFFECT OF THE PARTIAL PAYMENT OF USD 20,800
54. The Chamber then recalled that the Player argued that only full payment of all overdue
amounts cures the default under art. 14bis of the Regulations, and that partial settlement
cannot block the right to terminate. He contended that the relevant amount is the
contractual quarterly instalment, not reconstituted monthly sums, and that the Club never
paid the full instalment within the 15‑day deadline.
pg. 12
REF. FPSD-22220
55. Conversely, the Club asserted that partial payments must legally be deducted from the
outstanding balance when assessing the threshold of two months’ remuneration. It argues
that because it paid USD 20,800 within the cure period, the remaining amount fell below
the equivalent of two monthly salaries.
56. In this regard, the Chamber identified that the decisive question under art. 14bis of the
Regulations was whether two months’ salary were fully paid at the expiry of the notice
period. However, the DRC determined that even after deducting the USD 20,800 partial
payment, the outstanding amount remained approximately USD 41,700.
57. The Chamber then established that the partial payment did not cure the breach of contract
and did not extinguish the Club’s default.
C. EXISTENCE OF JUST CAUSE TO TERMINATE UNDER ART. 14BIS
58. Next, the Chamber took note that the Player properly issued a written notice granting 15
days to remedy the default and, at the expiry of the notice period, the Club had not fully
paid the overdue instalment. Consequently, the DRC confirmed that the Club remained in
default (indeed, beyond the threshold envisioned in art. 14bis of the Regulations), and the
Player was entitled to terminate the Contract.
59. For the sake of completeness, the Chamber emphasised that the Club’s allegations of bad
faith remained unsubstantiated and, in any event, they did not override the mandatory
financial-default mechanism of art. 14bis of the Regulations.
60. As a result, the Chamber decided that the Player terminated the Contract with just cause
and the Club should be liable to the ensuing consequences. Conversely, the counterclaim
of the Club is rejected.
D. CONSEQUENCES
61. Having stated the above, the Chamber turned its attention to the question of the
consequences of such unjustified breach of contract committed by the Club.
62. First and foremost, the Chamber concluded that the counterclaim lodged by the Club
should be rejected.
63. Next, and in accordance with the general legal principle of pacta sunt servanda, the
Chamber decided that the Club is liable to pay to the Player the amounts which were
outstanding under the Contract at the moment of the termination.
64. In this respect, the Chamber pointed out that the overdue instalment was USD 62,500.
Furthermore, the Club paid USD 20,800 on 9 November 2025, leaving USD 41,700 unpaid.
pg. 13
REF. FPSD-22220
65. Consequently, the DRC decided that the Player was entitled to USD 41,700 as outstanding
remuneration, plus 5% interest p.a. as from 3 November 2025, as claimed and in
accordance with the principle of ne ultra petita.
66. Subsequently, the Chamber turned to the calculation of the amount of compensation
payable by the Club in the case at stake. In doing so, the Chamber firstly recapitulated that,
in accordance with art. 17 par. 1 of the Regulations, the amount of compensation shall be
calculated, in particular and unless otherwise provided for in the contract at the basis of
the dispute, taking into account the damage suffered, according to the “positive interest”
principle, having regard for the individual facts and circumstances of each case, and with
due consideration for the law of the country concerned.
67. In application of the relevant provision, the Chamber held that it first had to clarify as to
whether the pertinent employment contract contained a provision by means of which the
parties had beforehand agreed upon an amount of compensation payable by the
contractual parties in the event of breach of contract. In this regard, the Chamber
established that no such compensation clause was included in the employment contract at
the basis of the matter at stake.
68. As a consequence, the Chamber determined that the amount of compensation payable by
the Club to the Player had to be assessed in application of the other parameters set out in
art. 17, par. 1 of the Regulations. In this respect, the Chamber recalled that, as a general
rule, the compensation to be paid to a player by a club shall be equal to the residual value
of the contract that was prematurely terminated, unless this player signed a new contract
following the termination of his previous contract (cf., art. 17 par. 1 lit. i) of the Regulations).
69. Bearing in mind the foregoing as well as the claim of the Player, the Chamber proceeded
with the calculation of the monies payable to the Player under the terms of the Contract
from the date of its unilateral termination until its end date. Consequently, the Chamber
concluded that the amount of USD 837,500 serves as the basis for the determination of the
amount of compensation for breach of contract, broken down as follows:
•
•
•
Remaining instalments for 2025/26 (3 × 62,500 = 187,500)
2026/27 season (300,000)
2027/28 season (350,000)
70. In continuation, the Chamber verified as to whether the Player had signed an employment
contract with another club during the relevant period of time, by means of which he would
have been enabled to reduce his loss of income. According to the constant practice of the
DRC as well as art. 17 par. 1 lit. ii) of the Regulations, such remuneration under a new
employment contract shall be taken into account in the calculation of the amount of
compensation for breach of contract in connection with the general obligation to mitigate
his damages.
pg. 14
REF. FPSD-22220
71. Indeed, the Player found employment with Wydad AC. In accordance with the pertinent
employment contract, the Player was entitled to MAD 37,000 per month plus a signing fee
of MAD 570,000. Therefore, the Chamber concluded that the Player mitigated his damages
in the total amount of MAD 1,236,000, which corresponded to approx. USD 132,739 with
the exchange rate at the time of the signature of the new contract.
72. Subsequently, the Chamber referred to art. 17 par. 1 lit. ii) of the Regulations, according to
which a player is entitled to an amount corresponding to three monthly salaries as
additional compensation should the termination of the employment contract at stake be
due to overdue payables. In the case at hand, the Chamber confirmed that the contract
termination took place due to said reason i.e., overdue payables by the Club and therefore
decided that the Player should receive additional compensation.
73. In this respect, the DRC decided to award the amount of additional compensation of USD
62,500, i.e., one quarterly payment under the Contract.
74. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Chamber decided that the Club must pay the amount of USD
767,261 to the Player (i.e., USD 837,500 minus USD 132,739 plus USD 62,500), which was to
be considered a reasonable and justified amount of compensation for breach of contract
in the present matter.
75. Lastly, taking into consideration the Player’s request, the Chamber decided to award the
Player interest on said compensation at the rate of 5% p.a. as of the date of its decision
until the date of effective payment.
ii. Sporting Sanctions
76. In continuation, the Chamber focused on the further consequences of the breach of
contract in question and, in this respect, it addressed the question of sporting sanctions
against the club in accordance with art. 17 par. 4 of the Regulations. The cited
provision stipulates that, in addition to the obligation to pay compensation, sporting
sanctions shall be imposed on any club found to be in breach of contract during the
protected period.
77. In this respect, the Chamber referred to item 7 of the “Definitions” section of the
Regulations, which stipulates inter alia that the protected period shall last “for three entire
seasons or three years, whichever comes first, following the entry into force of a contract, where
such contract is concluded prior to the 28th birthday of the professional, or two entire seasons
or two years, whichever comes first, following the entry into force of a contract, where such
contract is concluded after the 28th birthday of the professional”.
78. In the present matter, the Chamber took note that the Player was born on 23 March 1998
and that the Contract was concluded on 6 February 2025. Furthermore, the Chamber noted
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REF. FPSD-22220
that the Player terminated the Contract with just cause on 19 November 2025, thus the
breach of contract occurred within the protected period.
79. The Chamber then recalled that the Club had already been held liable for breaching other
players’ employment contracts without just cause in several recent occasions, in particular
in cases FPSD-15538, FPSD-18310 and FPSD-22395. In the Chamber’s view, the Club’s
status as a repeat offender warranted the imposition of additional consequences in order
to uphold the principle of contractual stability enshrined in the Regulations.
80. Consequently, the Chamber decided that, by virtue of art. 17 par. 4 of the Regulations, the
Club shall be sanctioned with a ban from registering any new players, either nationally or
internationally, for two entire and consecutive registration periods.
iii. Compliance with monetary decisions
81. Finally, taking into account the applicable Regulations, the Chamber 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.
82. In this regard, the DRC 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.
83. Notwithstanding the above, the DRC wished to remark that in accordance with art. 24 par.
3 of the Regulations, the aforementioned consequences may be excluded where the
pertinent FIFA deciding body has already imposed on the same party a sporting sanction
on the basis of article 12bis, 17 or 18quater of the Regulations.
84. In this respect, considering that art. 17 par. 4 of the Regulations applies in the matter, the
Chamber established that art. 24 par. 2 of the Regulations shall not apply, insofar as
in case the Club fails to comply with the decision at hand, the application of a further ban
from registering any new players on top of the one already being served by the Club would
be moot and against the spirit of the Regulations, in particularly the enforcement
mechanism established under art. 24 of the Regulations.
85. In view of the above, the DRC decided that, if the aforementioned sum plus interest is not
paid within 30 days of notification of this decision, the present matter shall be submitted,
upon request of the Player, to the FIFA Disciplinary Committee for its consideration and
formal decision.
pg. 16
REF. FPSD-22220
86. 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.
d. Costs
87. The Chamber 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 Chamber decided that no procedural costs were to be
imposed on the parties.
88. Likewise, and for the sake of completeness, the Chamber recalled the contents of art. 25
par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
89. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
pg. 17
REF. FPSD-22220
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant / Counter-Respondent, Sallah Moussaddaq Kerboub, is
partially accepted.
2.
The counterclaim of the Respondent / Counterclaimant, El Zamalek, is rejected.
3.
The Respondent / Counterclaimant, must pay to the Claimant / Counter-Respondent the
following amount(s):
- USD 41,700 as outstanding remuneration plus 5% interest p.a. as from 3 November
2025 until the date of effective payment; and
- USD 767,261 as compensation for breach of contract plus 5% interest p.a. as from 9
April 2026 until the date of effective payment.
4.
Any further claims of the Claimant / Counter-Respondent are rejected.
5.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
6.
The Respondent / Counterclaimant shall be banned from registering any new
players, either nationally or internationally, for the two next entire and consecutive
registration periods following the notification of the present decision.
7.
If full payment is not made within 30 days of notification of this decision, the present
matter shall be submitted, upon request of the Claimant / Counter-Respondent, to the FIFA
Disciplinary Committee.
8.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 18
REF. FPSD-22220
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. 19