Labour Disputes
Texto da decisão
REF. FPSD-22366
Decision of the
Dispute Resolution Chamber
passed on 17 March 2026
regarding an employment-related dispute concerning the Player Mohamed
Soueid
BY:
Angela COLLINS (Australia)
CLAIMANT:
Mohamed Soueid, Mauritania
Represented by Slim Boulasnem
RESPONDENT:
Naft Al Wasat SC, Iraq
pg. 2
REF. FPSD-22366
I. Facts of the case
1.
On 1 September 2025, the Mauritanian player Mohamed Soueid (hereinafter: the Player or
the Claimant) and the Iraqi club Naft Al Wasat SC (hereinafter: the Club or the Respondent)
entered into an employment contract (hereinafter: the Contract) valid as from 1 September
2025 to 31 May 2026.
2.
Pursuant to Schedule 1 of the Contract, the Player was entitled to:
“A total salary of IQD 60,750,000 payable in 9 instalments of IQD 6,750,000;
Round-trip ticket, once per season”.
3.
On 28 September 2025, the Player was presented as one of the Club’s players in its
Facebook account.
4.
On 20 November 2025, the Player put the Club in default requesting IQD 13,500,000
corresponding to the salaries between September 2025 and October 2025, within 15 days.
5.
On 6 December 2025, the Player sent a termination notice to the Club.
II. Proceedings before FIFA
6.
On 17 December 2025, the Player a claim with FIFA for just cause.
a. Position of the Claimant
7.
In the context of the claim, the Player argued that he had just cause to terminate the
Contract considering that the Club failed to pay three monthly salaries and therefore, he
requested the payment of his salaries and compensation for breach of contract.
8.
The Player requested the following:
”A/Arriérés
Étant donné que le joueur n’a pas reçu le montant suivant:
• 6750000 Dinars Iraquiens salaire du mois de septembre 2025 plus 5% d’intérêts
p.a. à partir du 1er octobre 2025;
• 6750000 Dinars Iraquiens salaire du mois d’octobre 2025 plus 5% d’intérêts p.a.
à partir du 1er novembre 2025
• 6750000 Dinars Iraquiens salaire du mois de novembre 2025 plus 5%
d’intérêts p.a. à partir du 1er décembre 2025
B/Valeur résiduelle 40500000 Dinars Iraquiens
pg. 3
REF. FPSD-22366
La valeur résiduelle s’élève à 40500000 Dinars Iraquiens auxquels s’ajoutent 5%
d’intérêts p.a. à compter de la date de résiliation soit le 6 décembre 2025,
représentant les salaires des mois allant de décembre 2025 au mois de mai 2026;
C/Billet d’avion 45437 MRU
Le billet d’avion retour du joueur a été payé par ce dernier (Billet) pour un montant
de 45437 MRU;
D/Indemnité Supplémentaire:
Au cas où le Joueur signe un nouveau contrat, et en vertu de l’article 17 al.1 ii. du RSTJ,
une indemnité supplémentaire égale à 6 mois de rémunération en raison du
caractère extrêmement abusif du comportement du club (Le joueur se trouve en Iraq
sans titre de séjour et est bloqué) sera versée au Joueur. La rémunération moyenne
du joueur revient à la formule suivante (Valeur totale du contrat 85000 USD/ nombre
de mois sachant que la saison sportive en Libye finit le 30 mai de chaque saison « 20
mois »)= 4250 USD par mois
En effet, le club a non seulement refusé de payer le joueur, mais cela a plongé le
joueur dans une situation de précarité inacceptable puisqu’il n’avait plus d’argent
pour se nourrir. Enfin, le club n’a jamais répondu au courrier du joueur, le forçant à
entamer une longue procédure devant les juridictions compétentes afin d’obtenir le
paiement des sommes contractuellement dues.
E/ Sanctions:
Vu que la résiliation est intervenue pendant la période protégée imposer une sanction
d’interdiction de deux périodes d’enregistrement”.
9.
Freely translated to English:
A / Outstanding Salaries
Given that the Player did not receive the following amounts:
• IQD 6,750,000 corresponding to the salary for September 2025, plus 5%
interest p.a. as from 1 October 2025;
• IQD 6,750,000 corresponding to the salary for October 2025, plus 5% interest
p.a. as from 1 November 2025;
• IQD 6,750,000 corresponding to the salary for November 2025, plus 5%
interest p.a. as from 1 December 2025.
B / Residual Value – IQD 40,500,000
The residual value amounts to IQD 40,500,000, to which 5% interest p.a. must be
added
as
from
the
termination
date,
6
December
2025.
This represents the salaries from December 2025 to May 2026.
C / Air Ticket – 45,437 MRU
pg. 4
REF. FPSD-22366
The Player paid for his own return flight ticket (invoice provided), amounting to 45,437
MRU.
D / Additional Compensation
If the Player signs a new contract, and pursuant to art. 17 par. 1(ii) of the FIFA RSTP,
an additional compensation equal to six months of remuneration shall be awarded
due to the extremely abusive behaviour of the Club (the Player was in Iraq without a
residence permit and was unable to leave).
The Player’s average monthly remuneration is calculated as follows:
Total contractual value USD 85,000 / 20 months (football season in Libya ends on 30
May each season) = USD 4,250 per month.
Indeed, the Club not only refused to pay the Player, but also placed him in an
unacceptable situation of hardship, as he no longer had money even for basic needs.
Finally, the Club never responded to the Player’s correspondence, forcing him to
initiate lengthy proceedings before the competent authorities in order to obtain
payment of the amounts contractually owed.
E / Sanctions
Since the termination occurred during the protected period, a sanction consisting of
a registration ban for two registration periods shall be imposed.
b. Position of the Respondent
10. The Respondent submitted that although a delay in the payment of certain financial
entitlements had occurred, such delay resulted from exceptional financial circumstances
that were beyond its control. It argued that this delay had been temporary and that, after
approximately three months, it had secured the necessary funds and settled the
outstanding salaries of all professional and local players. According to the Respondent,
these actions demonstrated its good faith and confirmed that the delay did not amount to
a serious contractual breach.
11. Furthermore, the Respondent held that the Player’s termination of the Contract, despite
being notified under Article 14 of the Regulations on the Status and Transfer of Players
(hereinafter: the Regulations), did not automatically render the Club fully liable. It
emphasized that the lawfulness and consequences of the termination had to be assessed
in light of the seriousness of the alleged breach, the conduct of both parties during the
contractual relationship, and the principles of proportionality and good faith. The
Respondent also stated that, following termination, the Player had left Iraq without
authorization, in breach of contractual obligations, and contended that certain cash
advances and free accommodation and meals provided to the Player had to be taken into
account to avoid unjust enrichment.
pg. 5
REF. FPSD-22366
12. The Club requested the following relief:
“In light of the above, Al-Naft Al-Wasat Sports Club respectfully requests that the
Honorable Committee:
1.Declare that the termination of the employment contract, even if carried out pursuant
to Article 14, does not automatically entail full liability on the part of the Club.
2.Give due consideration to the Club’s good faith and the exceptional financial
circumstances surrounding the contractual relationship.
Take into account, in any financial assessment or potential compensation.
The amounts paid outside the contractual framework; and
The value of accommodation and meals provided free of charge
4. Should any outstanding amounts be deemed payable, kindly facilitate an amicable
settlement in accordance with FIFA’s regulatory powers, ensuring fairness and
proportionality between the parties.”
c. Updated employment situation of the Coach
13. On 7 January 2026, the Player and the Mauritanian club, FC Nouadhibou, entered into an
employment contract valid as from the date of signature until 30 June 2026. The Player was
entitled to a total salary of USD 20,000.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
14. 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 17 December 2025 and
submitted for decision on 10 March 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.
15. Furthermore, the Single Judge referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations (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 Mauritanian player and an Iraqi club.
pg. 6
REF. FPSD-22366
16. 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
17. 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
18. 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
19. The Single Judge then moved to the substance of the matter and took note of the fact that
the matter is related to a breach of contract.
20. In this context, the Single Judge acknowledged that the Claimant argued that he terminated
the Contract with just cause as the Club failed to pay the 3 monthly salaries. The
Respondent on the other, mentioned that the termination does not render liable the Club,
as it acted in good faith.
21. In continuation, the Single Judge first acknowledged that two monthly salaries were
outstanding at the moment of default (September and October 2025), and that the
Claimant has provided written evidence of having put the Respondent in default on 20
November 2025, i.e., at least 15 days before unilaterally terminating the Contract on 6
December 2025.
22. Furthermore, the Single Judge also noted that the Club failed to submit evidence of
payment of the claimed amounts. Although the Club declared that some cash payments
were performed, no evidence of it was provided. In this context, the Single Judge
pg. 7
REF. FPSD-22366
considered that no payment can be recorded. Moreover, as to the financial circumstances
and on the basis of art. 13 par. 5 of the Procedural Rules, the Single Judge considered that
the Respondent failed to prove that, because of the foregoing, it was unable to meet its
financial obligations towards the Claimant. In any event the Single Judge underlined that
financial difficulties are not a valid reason, as per the Football Tribunal jurisprudence, for
the nonpayment of the Player’s salary.
23. In view of the foregoing, the Single Judge decided that the Claimant had just cause to
terminate the Contract in accordance with art. 14bis of the Regulations.
ii. Consequences
24. Having stated the above, the Single Judge turned her attention to the analysis of the legal
consequences arising from the Club’s breach.
Outstanding remuneration
25. The Single Judge observed that the outstanding remuneration at the time of termination
amounts to IQD 20,250,000 net, broken down as follows:
o
o
o
September salary: IQD 6,750,000;
October salary: IQD 6,750,000;
December salary: IQD 6,750,000.
26. As a consequence, and in accordance with the general legal principle of pacta sunt servanda,
the Single Judge decided that the Respondent is liable to pay to the Claimant the amounts
which were outstanding under the contract at the moment of the termination, i.e. IQD
20,250,000 net as detailed ut supra.
27. In addition, taking into consideration the Claimant’s request as well as the constant practice
of the Football Tribunal in this regard, the Single Judge decided to award the Claimant
interest at the rate of 5% p.a. on the outstanding amounts as follows:
o
over the amount of IQD 6,750,000 as from 1 October 2025 until the date of effective
payment;
o
over the amount of IQD 6,750,000 as from 1 November 2025 until the date of
effective payment;
o
over the amount of IQD 6,750,000 as from 1 December 2025 until the date of
effective payment.
Reimbursement of flight tickets
pg. 8
REF. FPSD-22366
28. In continuation, the Single Judge turned her attention to the fact that the Player itself paid
for his own return flight, in the total amount of MRU 45,437. Taking that into account, the
Single Judge decided that the Player is entitled to the reimbursement of the flight ticket of
MRU 45,437, as it was contractually stipulated and the Player provided evidence in this
respect. In this context, the Single Judge also underlined that, since the Claimant did not
request interest, it was not provided in accordance with the principle ne ultra petita.
Compensation for breach of contract
29. Having stated the above, the Single Judge turned to the calculation of the amount of
compensation payable by the Respondent in the case at stake. In doing so, the Single Judge
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.
30. In application of the relevant provision, the Single Judge held that it first of all 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 them in
the event of breach of contract. In this regard, the Single Judge established that no such
compensation clause was included in the employment contract at the basis of the matter
at stake.
31. As a consequence, the Single Judge 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 Single Judge recalled that, as a
general rule, 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 the player signed a new
contract following the termination of his previous contract (cf.,art. 17 par. 1 lit. i) of the
Regulations).
32. Bearing in mind the foregoing as well as the claim of the Player, the Single Judge proceeded
with the calculation of the monies payable to him under the terms of the Contract from the
date of its unilateral termination until its end date. Consequently, the Single Judge
concluded that the amount of IQD 40,500,000 net serves as the basis for the determination
of the amount of compensation for breach of contract.
33. In continuation, the Single Judge verified as to whether the Claimant 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 Football Tribunal 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
pg. 9
REF. FPSD-22366
calculation of the amount of compensation for breach of contract in connection with the
general obligation to mitigate his damages.
34. Indeed, the Player found employment with FC Nouadhibou. In accordance with the
pertinent employment contract, the Player entered into an employment contract valid as
from the date of signature until 30 June 2026, in which the Player was entitled to a total
salary of USD 20,000. Therefore, the Single Judge concluded that the Claimant mitigated
his damages in the total amount of USD 16,571, which is equal to IQD 21,332,843.
35. Subsequently, the Single Judge 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 Single Judge confirmed that the contract
termination took place due to said reason i.e., overdue payables by the Respondent and
therefore decided that the Claimant shall receive additional compensation.
36. In this respect, the Single Judge decided to award the amount of additional compensation
of IQD 20,250,000, i.e., three times the monthly remuneration of the player.
37. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Single Judge decided that the Respondent must pay the amount of
IQD 39,417,157 to the Claimant (i.e., IQD 40,500,000 minus IQD 21,332,843 plus IQD
20,250,000), which was to be considered a reasonable and justified amount of
compensation for breach of contract in the present matter.
38. Lastly, taking into consideration the Claimant’s request as well as the constant practice of
the Football Tribunal in this regard, the Single Judge decided to award the Claimant interest
on said compensation at the rate of 5% p.a. as from 7 December 2025 until the date of
effective payment.
iii. Compliance with monetary decisions
39. 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.
40. 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.
pg. 10
REF. FPSD-22366
41. 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.
42. 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.
43. 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
44. 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.
45. 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.
46. Lastly, the Single Judge concluded her deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 11
REF. FPSD-22366
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Mohamed Soueid, is partially accepted.
2.
The Respondent, Naft Al Wasat SC, must pay to the Claimant the following amounts:
- IQD 20,500,000 as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of IQD 6,750,000 as from 1 October 2025 until the
date of effective payment;
- 5% interest p.a. over the amount of IQD 6,750,000 as from 1 November 2025 until the
date of effective payment;
- 5% interest p.a. over the amount of IQD 6,750,000 as from 1 December 2025 until the
date of effective payment;
- MRU 45,437 as reimbursement for flight tickets;
- IQD 39,417,157 as compensation for breach of contract plus 5% interest p.a. as from 7
December 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.
pg. 12
REF. FPSD-22366
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 13
REF. FPSD-22366
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. 14