Labour Disputes
Texto da decisão
REF. FPSD-22367
Decision of the
Dispute Resolution Chamber
passed on 9 February 2026
regarding an employment-related dispute concerning the player Moutir
Chajia
BY:
Johan VAN GAALEN, South Africa
CLAIMANT:
Moutir Chajia, Belgium
Represented by Mathieu Baert
RESPONDENT:
ACS Petrolul 52, Romania
Represented by Saksham Samarth
pg. 2
REF. FPSD-22367
I. Facts of the case
1.
The parties involved in this dispute are:
•
The Belgian player, Moutir Chajia (hereinafter: the Player or the Claimant);
•
The Romanian club, ACS Petrolul 52 (hereinafter: the Club or the Respondent),
affiliated to the Romanian Football Federation (FRF).
2.
On 9 September 2025, the Player and the Club concluded an employment contract
(hereinafter: the Contract) valid as from 9 September 2025 until 30 June 2026, with an option
for the Club to unilaterally extend the contract until 15 June 2027.
3.
Pursuant to the Contract, the Club undertook to pay the Player a monthly salary of EUR
4,000 net, payable no later than the 15th day of the following month.
4.
Furthermore, the Contract provided for a signing bonus of EUR 10,000 net, of which EUR
5,000 was due on 15 October 2025 and EUR 5,000 on 15 October 2026.
5.
On 21 November 2025, the Player, through his legal representative, sent the Club a written
notice of default, granting a deadline of 15 days, until 6 December 2025, to settle the
outstanding amounts in full. In particular, the Player alleged that the Club failed to pay a
total amount of EUR 13,000 net, broken down as follows:
•
the salary for September 2025 (EUR 4,000 net), due on 15 October 2025;
•
the salary for October 2025 (EUR 4,000 net), due on 15 November 2025; and
•
the first instalment of the signing bonus in the amount of EUR 5,000 net, due on
15 October 2025.
6.
On 26 November 2025, the Club seemingly proposed a termination/settlement agreement,
which was not signed by the Player.
7.
On 28 November 2025 and during the default period, the Club made a partial payment of
RON 20,000, corresponding to approximately EUR 3,928.58.
8.
On 8 December 2025, following the expiry of the default period and in light of the alleged
outstanding payments and working conditions, the Player terminated the employment
contract with immediate effect, citing (i) overdue payables, (ii) the purported pressure to
sign a termination agreement, and (iii) unlawful exclusion from training and unilateral
downgrading of the Player’s status.
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REF. FPSD-22367
9.
On the same date, the Respondent transferred an additional amount of RON 45,000,
corresponding to approximately EUR 8,838.09, to the Player.
10. The Player informed that he remained unemployed following the termination of the
Contract.
II. Proceedings before FIFA
11. On 17 December 2025, the Player filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Position of the Player
12. The Player maintained that the Club had failed to comply with its essential financial
obligations under the employment contract by not paying at least two monthly salaries and
a contractual bonus on their respective due dates.
13. The Player asserted that he had duly placed the Club in default in writing and had granted
a deadline of at least 15 days to remedy the breach, in accordance with art. 14bis of the
Regulations on the Status and Transfer of Players (hereinafter: the Regulations).
14. The Player argued that the Club had not fully complied with its financial obligations within
the granted deadline, as only a partial payment had been made during the default period.
15. The Player therefore submitted that he had been entitled to terminate the Contract with
just cause pursuant to art. 14bis of the Regulations.
16. In addition, the Player contended that the Club had engaged in abusive conduct aimed at
compelling him to accept a modification of the contractual terms, notably by exerting
pressure on him to sign an agreement deferring the payment of overdue remuneration
while the Club was already in payment default.
17. The Player further stated that such pressure had been exercised directly, despite the Club’s
knowledge that he was represented by legal counsel and despite his express request to be
assisted by his representative.
18. The Player also submitted that the Club had unlawfully excluded him from collective
training activities for prolonged periods, had downgraded his professional status, and had
prevented him from participating in official matches, without valid sporting, disciplinary, or
medical justification.
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19. According to the Player, this conduct had seriously affected his professional activity and
had deprived him of an essential part of his remuneration structure, including
match‑related bonuses.
20. The Player argued that, taken individually and cumulatively, the Club’s conduct had
constituted a serious breach of the employment relationship and had rendered the
continuation of the contractual relationship unreasonable.
21. On this basis, the Player maintained that his termination of the Contract on 8 December
2025 had occurred with just cause, pursuant to art. 14 and 14bis of the Regulations.
22. Consequently, the Player requested that the Club be held liable for the breach of contract
and be ordered to pay outstanding remuneration, compensation for breach of contract,
and interest, as well as that sporting sanctions be imposed in accordance with the
Regulations.
23. The Claimant’s request for relief was the following:
“18. In light of the above [the Player] respectfully requests the FIFA Dispute Resolution
Chamber – after sending this claim to [the Club] with a time limit for a statement or a
reply pursuant to Article 21 par.1 of the FIFA Procedural Rules – to declare that:
A. [The Club] failed to comply with its contractual obligations.
B. The claim of [the Player] is accepted and that the Employment Contract signed by and
between the parties was terminated with just cause by [the Player] on 8 December 2025
according to Article 14, par. 2 and 14bis of the FIFA RSTP.
C. [The Club] must pay [the Player] within 45 days as from the notification of the decision
of the Dispute Resolution Chamber the following amounts:
- EUR 232.52 net as outstanding remuneration plus 5% interest per annum as
follows:
•
5% interest p.a. over the amount of EUR 9,000 net as from 15 October 2025
until 15 November 2025;
•
5% interest p.a. over the amount of EUR 13,000 net as from 15 November 2025
until 28 November 2025;
•
5% interest p.a. over the amount of EUR 9,071.42 net as from 28 November
2025 until 8 December 2025;
•
5% interest p.a. over the amount of EUR 232.52 net as from 8 December 2025
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REF. FPSD-22367
until the date of effective payment;
- EUR 31,933.33 net as compensation for breach of contract plus 5% interest per
annum as from 9 December 2025 until the date of effective payment;
D. Impose, pursuant to Article 17, par. 4 of the RSTP, a ban on [the Club] from registering
any new players, either nationally or internationally, for two entire and consecutive
registration periods.
E. In case [the Club] fails to pay [the Player] within 45 days as from the notification of the
decision of the Dispute Resolution Chamber, the Dispute Resolution Chamber shall in
virtue of Article 24 of the RSTP impose additional sanctions on [the Club], including a ban
of three entire and consecutive registration periods.
F. In addition to the above, [the Club] shall bear any and all additional costs of the
proceedings that the Dispute Resolution Chamber may deem appropriate to levy as a
result of consideration of the case in question.”
b. Position of the Club
24. Despite having been invited to do so, the Club failed to reply to the claim.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
25. 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 17 December 2025 and submitted
for decision on 9 February 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.
26. 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 Belgian player and a Romanian club.
27. 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
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REF. FPSD-22367
the Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Burden of proof
28. 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
29. 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
30. The Single Judge then moved to the substance of the matter, noting that it concerned a
claim for breach of contract brought by a player against a club.
31. On one hand, the Single Judge noted that the Player claimed he terminated the Contract
with just cause on 8 December 2025 due to both overdue payables and a purported
abusive conduct by the Club.
32. Conversely, the Club failed to submit any reply to the Player’s claim, despite having been
duly notified. Consequently, the Single Judge determined that he should take a decision on
the basis of the documentation and arguments submitted by the Player (cf., art. 21, par. 1
of the Procedural Rules).
33. In particular, the Single Judge determined that his task was to determine the circumstances
of the termination and its ensuing consequences, which he proceeded to analyse in turn.
A. TERMINATION
34. As a departure point, the Single Judge observed that it remained undisputed that, at the
time the Player placed the Club in default on 21 November 2025, at least two monthly
salaries as well as a contractual bonus were outstanding.
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REF. FPSD-22367
35. The Single Judge further noted that the Player granted the Club a deadline of 15 days to
remedy the breach, in accordance with art. 14bis of the Regulations. However, the Club
made only a partial payment during the default period, and the outstanding amounts were
not fully settled by the expiry of the deadline on 6 December 2025.
36. In this sense, the Single Judge recalled that partial or belated payments made after the
expiry of the default period do not retroactively cure a breach within the meaning of art.
14bis of the Regulations.
37. Consequently, the Single Judge confirmed that at the time of the termination on 8
December 2025, the conditions of art. 14bis of the Regulations were fulfilled.
38. Therefore, the Single Judge concluded that the Player had just cause to terminate the
Contract due to overdue payables. As such, the Single Judge found no need to further
examine the other arguments listed by the Player to justify the termination.
B. CONSEQUENCES
39. Having stated the above, the Single Judge turned his attention to the question of the
consequences of such an unjustified breach of contract committed by the Club.
40. The Single Judge observed that the outstanding remuneration at the time of termination,
when considering the payments made by the Club on the same day, was equivalent to EUR
232.52.
41. Furthermore, in accordance with the constant practice of the Football Tribunal in this
regard, the Single Judge decided to award the Player interest at the rate of 5% p.a. on the
outstanding amounts as follows:
•
•
•
•
on EUR 9,000 net from 15 October 2025 until 15 November 2025;
on EUR 13,000 net from 15 November 2025 until 28 November 2025;
on EUR 9,071.42 net from 28 November 2025 until 8 December 2025; and
on EUR 232.52 net as from 8 December 2025 until the date of effective payment.
42. Having stated the above, the Single Judge turned to the calculation of the amount of
compensation payable by the Club 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.
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REF. FPSD-22367
43. In application of the relevant provision, the Single Judge held that he 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 the
contractual parties 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.
44. 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, 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).
45. 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 the Claimant 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 EUR 33,000 net serves as the basis for the determination of
the amount of compensation for breach of contract, broken down as follows:
•
•
•
•
•
•
•
•
EUR 4,000 net, corresponding to the monthly salary of December 2025;
EUR 4,000 net, corresponding to the monthly salary of January 2026;
EUR 4,000 net, corresponding to the monthly salary of February 2026;
EUR 4,000 net, corresponding to the monthly salary of March 2026;
EUR 4,000 net, corresponding to the monthly salary of April 2026;
EUR 4,000 net, corresponding to the monthly salary of May 2026;
EUR 4,000 net, corresponding to the monthly salary of June 2026;
EUR 5,000 net, corresponding to the second half of the signing bonus.
46. 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
calculation of the amount of compensation for breach of contract in connection with the
general obligation to mitigate his damages.
47. The Single Judge further observed that the Player did not secure new employment
following the termination of the relevant contract. Consequently, no mitigation or
additional compensation applied (cf., art. 17 par. 1 lit. ii) of the Regulations).
48. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Single Judge decided that the Club must pay the amount of EUR
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REF. FPSD-22367
33,000 net to the Player, which was to be considered a reasonable and justified amount of
compensation for breach of contract in the present matter.
49. Lastly, taking into consideration the Player’s request as well as the constant practice of the
Football Tribunal in this regard, the Single Judge decided to award the Player interest on
said compensation at the rate of 5% p.a. as of 8 December 2025 until the date of effective
payment.
ii. Compliance with monetary decisions
50. 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.
51. 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.
52. Therefore, bearing in mind the above, the Single Judge decided that the Club must pay the
full amount due (including all applicable interest) to the Player within 45 days of notification
of the decision, failing which, at the request of the Player, a ban from registering any new
players, either nationally or internationally, for the maximum duration of three entire and
consecutive registration periods shall become immediately effective on the Club in
accordance with art. 24 par. 2, 4, and 7 of the Regulations.
53. 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.
54. 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
55. 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.
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REF. FPSD-22367
56. 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.
57. 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-22367
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Moutir Chajia, is partially accepted.
2.
The Respondent, ACS Petrolul 52, must pay to the Claimant the following amount(s):
- EUR 232.52 net as outstanding remuneration plus 5% interest p.a. as follows:
-
on EUR 9,000 net from 15 October 2025 until 15 November 2025;
on EUR 13,000 net from 15 November 2025 until 28 November 2025;
on EUR 9,071.42 net from 28 November 2025 until 8 December 2025; and
on EUR 232.52 net as from 8 December 2025 until the date of effective payment.
- EUR 33,000 net as compensation for breach of contract plus 5% interest p.a. as from 8
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.
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
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REF. FPSD-22367
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. 13