Labour Disputes
Texto da decisão
REF. FPSD-22552
Decision of the
Dispute Resolution Chamber
passed on 2 April 2026
regarding an employment-related dispute concerning the player Redon
Xhixha
COMPOSITION:
Frans DE WEGER (The Netherlands), Chairperson
Dana MOHAMED AL-NOAIMI (Qatar), Member
Peter LUKASEK (Slovakia), Member
CLAIMANT:
Redon Xhixha, Albania
Represented by Lorin Burba
RESPONDENT:
Chabab Riadhi de Belouizdad, Algeria
pg. 2
REF. FPSD-22552
I. Facts of the case
1.
On 10 July 2025, the Albanian player, Redon Xhixha (hereinafter: the Player or the Claimant),
and the Algerian club, Chabab Riadhi de Belouizdad (hereinafter: the Club or the
Respondent) entered into an employment contract (hereinafter: the Contract) valid as from
the date of signature for the seasons 2025/2026 and 2026/2027.
2.
According to clause 1 of the Contract, the Player was entitled to a total annual net salary of
EUR 312,000 “payable in arrears and payable in Algerian Dinar equivalent.” In addition, the
parties agreed on the following (quoted verbatim):
“An amount of sixty-two thousand four hunder euros (EUR 62,400), representing 20% of the
annual salary for the 2025/2026 season payable in Algerian Dinar equivalent, shall be paid
in advance as a signing fee, and the remaining balance shall be paid in monthly instalments
of twenty thousand eight hundred euros (EUR 20,800) payable in Algerian Dinar equivalent.
For the 2026/2027 season, the Player’s monthly net salary is set at twenty-six thousand Euros
(EUR 26,000) payable in Algerian Dinar equivalent. The Club shall be responsible for all taxes
and social charges, ensuring the player receives the full stated net amount.”
3.
On 9 October 2025, the Player sent the Club a default notice requesting the payment of the
amount of EUR 118,761.29 by no later than 24 October 2025. In addition, the Player
provided the following breakdown:
20% of the annual salary representing the signing bonus:
Salary for the month of July 2025 starting from 10 July 2025:
Salary for the month of August 2025:
Salary for the month of September 2025:
Total:
4.
EUR 62,400
EUR 14,761.29
EUR 20,800
EUR 20,800
EUR 118,761.20
On 4 December 2025, the Player sent a second default notice to the Club requesting
payment of the total amount of EUR 97,961.29 within 15 days. The Player claimed that said
amount corresponded to the following amounts (quoted verbatim):
-
-
“The salary of July 2025, calculated pro rata for the period July 10, 2025, until July 31,
2025, amounting to EUR 14,761.29 (fourteen thousand seven hundred sixty-one euros
and twenty-nine cents);
The full salary of August 2025, amounting to EUR 20,800 (twenty thousand eight hundred
euros);
The full salary of September 2025, amounting to EUR 20,800 (twenty thousand eight
hundred euros);
The full salary of October 2025, amounting to EUR 20,800 (twenty thousand eight hundred
euros); and
pg. 3
REF. FPSD-22552
-
The full salary of November 2025, amounting to EUR 20,800 (twenty thousand eight
hundred euros);
In Total, EUR 97,961.29 (ninety-seven thousand nine hundred sixty-one euros and twentynine cents).”
5.
On 23 December 2025, the Player sent a termination notice to the Club referring to his
default notice of 5 December 2025 arguing that the requested amount had not been paid.
6.
On 13 January 2026, the Club sent a letter to the Player alleging that it fulfilled all
contractual and administrative obligations, including paying the signing fee, covering
housing and transport, and diligently completing all work permit and visa procedures. Once
the Player obtained the visa and returned to Algeria, the Club provided everything
necessary and was ready to finalize the work permit process. Despite this, the Player
unilaterally terminated the contract without justification after being absent from the team.
7.
The Club considered this an unjustified breach causing financial and sporting prejudice and
therefore seeks recognition of the termination as being solely attributable to the player.
8.
On 1 January 2026, the Player signed a new employment contract with the Albanian club,
Tirana (hereinafter: the New Contract) valid as from 1 January 2026 until 31 May 2026. The
Player’s monthly salary corresponds to EUR 830. In addition, the Player is entitled to a fixed
payment of EUR 20,000 on 1 February 2026.
II. Proceedings before FIFA
9.
On 6 January 2026, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Claim of the Claimant
10. On 30 December 2025, the Player lodged a claim with FIFA for breach of contract and
overdue payables.
11. The Player argued that after his default notice of 3 October 2025, the Club proceeded to
the payment of EUR 62,400 on 22 October 2025 but failed to pay the salaries of July, August
and September 2025.
12. He later sent a new default notice on 4 December 2025 as 4 monthly salaries remained
outstanding.
13. However, the Club did not comply with its financial obligations vis-avis the Player and
therefore 19 days after having sent the default notice the Player terminated the Contract
pg. 4
REF. FPSD-22552
alleging just cause based on art. 14bis of the Regulations as 5 salaries remained
outstanding.
14. Regarding the outstanding salaries, the Player argued that at the moment of the
termination the salaries of July to November 2025 remained outstanding of EUR 20,800
each plus the pro rata salary of December 2025 of EUR 15,432.26.
15. Concerning the compensation, the Player contended that the total residual value of the
Contract corresponded to EUR 448,206.45.
16. In view of the above, the Player requested the following relief (quoted verbatim):
“1. The claim of the Claimant, Redon Xhixha is fully accepted.
2. The Respondent, SSPA Chabab Riadhi Belouizdad Athletic is ordered to pay to the Claimant,
Redon Xhixha the outstanding obligations of EUR 113,393.55 (one hundred thirteen thousand
three hundred ninety-three euros and fifty-five cents), plus interests as follows:
• 5 % p.a. over the amount of EUR 62,400 (sixty-two thousand four hundred euros) as
from the date July 10, 2025, until October 22, 2025;
• 5 % p.a. over the amount of EUR 14,761.29 (fourteen thousand seven hundred sixtyone euros and twenty-nine cents) as from the date August 1, 2025, until the effective
payment by the Respondent;
• 5 % p.a. over the amount of EUR 20,800 (twenty thousand eight hundred euros) as
from the date September 1, 2025, until the effective payment by the Respondent;
• 5 % p.a. over the amount of EUR 20,800 (twenty thousand eight hundred euros) as
from the date October 1, 2025, until the effective payment by the Respondent;
• 5 % p.a. over the amount of EUR 20,800 (twenty thousand eight hundred euros) as
from the date November 1, 2025, until the effective payment by the Respondent;
• 5 % p.a. over the amount of EUR 20,800 (twenty thousand eight hundred euros) as
from the date December 1, 2025, until the effective payment by the Respondent;
• 5 % p.a. over the amount of EUR 15,432.26 (fifteen thousand four hundred thirty-two
euros and twenty-six cents) as from the date December 24, 2025, until the effective
payment by the Respondent.
3. The Respondent, SSPA Chabab Riadhi Belouizdad Athletic is ordered to pay to the
Claimant, Redon Xhixha compensation for breach of contract amounting to EUR
448,206.45 (four hundred forty-eight thousand two hundred six euros and forty-five cents)
plus interests of 5 % p.a. as from the date December 24, 2025, until the effective payment
by the Respondent.
4. All procedural costs related to the present dispute to be covered by the Respondent, SSPA
Chabab Riadhi Belouizdad Athletic in full (if any).”
pg. 5
REF. FPSD-22552
b. Reply of the Respondent
17. In its reply, the Player disputed all the Player’s allegations.
18. In particular, the Club invoked the Algerian national law according to which the Player
would not be entitled to any salaries before the issuance of his work permit, i.e. before 7
December 2025.
19. In addition, the Club alleged that it had not received any default notice without however
taking position regarding the proofs of receipt of the emails provided by the Player in his
claim.
20. In view of the above, the Club requested the following relief (quoted verbatim):
« Le Club rejette intégralement la réclamation et sollicite respectueusement de la Chambre
de :
-
-
Rejeter la demande de paiement d’arriérés (overdue payables) de 113 393,55 € et
intérêts de 5 % p.a. ;
Rejeter la demande de compensation pour rupture de contrat de 448 206,45 € et
intérêts de 5 % p.a. ;
Constater que le Joueur a résilié unilatéralement le contrat sans juste cause ;
Condamner le Joueur à indemniser le Club pour rupture sans juste cause
conformément à l’article 17 du RSTP (valeur résiduelle du contrat + préjudices),
majorée des intérêts de 5 % p.a. ;
Condamner le Joueur aux dépens de la procédure. »
“The Club entirely rejects the claim and respectfully requests the Chamber to:
-
-
Dismiss the claim for payment of arrears (overdue payables) in the amount of EUR
113,393.55, plus interest at 5% p.a.;
Dismiss the claim for compensation for breach of contract in the amount of EUR
448,206.45, plus interest at 5% p.a.;
Declare that the Player unilaterally terminated the contract without just cause;
Order the Player to compensate the Club for termination without just cause in
accordance with Article 17 of the RSTP (residual value of the contract plus damages),
increased by interest at 5% p.a.;
Order the Player to bear the costs of the proceedings.” (Freely translated in English)
21. However, the Club did not complete its counterclaim in line with art. 18 par. 3 of the
Procedural Rules Governing the Football Tribunal within the deadline set by the FIFA
general secretariat and therefore, the counterclaim has been disregarded.
pg. 6
REF. FPSD-22552
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
22. 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 30 December 2025 and submitted for decision
on 2 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.
23. 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 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
an Albanian player and an Algerian club.
24. 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
25. 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
26. 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
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.
pg. 7
REF. FPSD-22552
i. Main legal discussion and considerations
27. The Chamber then moved to the substance of the matter, and took note of the fact that
the parties strongly dispute whether the Player had just cause to terminate the Contract.
28. In this context, the Chamber acknowledged that its task was to assess whether the Player
had just cause to prematurely terminate the Contract and determine the consequences
thereof.
29. In this regard, the Chamber noted that the Player claimed to have just cause to terminate
the Contract, asserting that five monthly salaries were outstanding at the time of the
termination and that he had previously placed the Club in default by granting a 15-day
deadline to remedy the breach. In particular, the Player alleged that at the moment of the
termination the salaries from July to November 2025 remained outstanding.
30. The Club however, contended that none of these salaries were outstanding, arguing that
the Player’s work permit had not yet been issued. In this respect, the Club maintained that,
under Algerian national law, it had no legal obligation to pay salaries that fell due prior to
the issuance of the work permit.
31. The Chamber recalled that according to art. 14bis of the Regulations, if a club unlawfully
fails to pay a player at least two monthly salaries on their due dates, the player will be
deemed to have a just cause to terminate his contract, provided that he has put the debtor
club in default in writing and has granted a deadline of at least 15 days for the debtor club
to fully comply with its financial obligation(s).
32. In the case at hand, the Chamber observed that the Player alleged not having received the
salaries corresponding to the months of July to November 2025 as well as the balance of
the month of December 2025 (i.e., 5,5 monthly salaries) and has provided written evidence
of having put the Respondent in default on 4 December 2025, i.e. at least 15 days before
the unilateral termination of the Contract, on 23 December 2025.
33. With regard to the Club’s argument concerning the Player’s work permit, such circumstance
cannot absolve the Club from its contractual financial obligations towards the Player.
34. In view of the above, the Chamber considered that the Claimant indeed had just cause to
terminate the Contract due to having at least 2 outstanding salaries and having provided
the Respondent with at least 15 days’ notice to comply with their default.
ii. Consequences
35. Having stated the above, the Chamber turned its attention to the question of the
consequences of such unjustified breach of contract committed by the Respondent.
pg. 8
REF. FPSD-22552
36. The Chamber observed that the outstanding remuneration at the time of termination,
coupled with the specific requests for relief of the Player, is equivalent to EUR 118,761.29
salaries under the contract, corresponding to the pro rata salary of July 2025 (EUR
14,761.29) as well as to the salaries between August and December 2025 of EUR 20,800
each.
37. As a consequence, and in accordance with the general legal principle of pacta sunt servanda,
the Chamber 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. EUR
118,761.29.
38. In addition, taking into consideration the Claimant’s request as well as the constant practice
of the Football Tribunal in this regard, the Chamber decided to award the Claimant interest
at the rate of 5% p.a. on the outstanding amounts as follows:
-
5% interest over the amount of EUR 16,761.29 as from 1 August 2025 until the date
of the effective payment;
5% interest over the amount of EUR 20,800 as from 1 September 2025 until the date
of effective payment;
5% interest over the amount of EUR 20,800 as from 1 October 2025 until the date of
effective payment;
5% interest over the amount of EUR 20,800 as from 1 November 2025 until the date
of effective payment;
5% interest over the amount of EUR 20,800 as from 1 December 2025 until the date
of effective payment;
5% interest over the amount of EUR 20,800 as from 23 December 2025 until the date
of effective payment.
39. In addition, the Chamber decided to award 5% interest over the amount of EUR 62,400 as
from 10 July 2025 until 22 October 2025 corresponding to the sing-on fee.
40. Having stated the above, the Chamber turned to the calculation of the amount of
compensation payable by the Respondent 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.
41. In application of the relevant provision, the Chamber 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 the
contractual parties in the event of breach of contract. In this regard, the Chamber
pg. 9
REF. FPSD-22552
established that no such compensation clause was included in the employment contract at
the basis of the matter at stake.
42. 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).
43. Bearing in mind the foregoing as well as the claim of the Claimant, the Chamber 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 Chamber
concluded that the amount of EUR 436,800 (i.e., the residual value of the Contract) serves
as the basis for the determination of the amount of compensation for breach of contract,
broken down as follows:
•
•
From January until June 2026 (EUR 20,800 x 6 months= EUR 124,800)
From July 2026 until June 2027 (EUR 26,000 x 12 months= EUR 312,000)
44. In continuation, the Chamber 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 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.
45. Indeed, the Player signed the New Contract. In accordance with the New Contract the
Player was entitled to approximately EUR 830 per month and a fixed payment of EUR
20,000. Therefore, the Chamber concluded that the Claimant mitigated his damages in the
total amount of EUR 24,150, that is, EUR 830 times 5 plus EUR 20,000.
46. 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 Respondent and
therefore decided that the Claimant shall receive additional compensation.
47. In this respect, the DRC decided to award the amount of additional compensation of EUR
62,400, i.e., three times the monthly remuneration of the Player.
pg. 10
REF. FPSD-22552
48. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Chamber decided that the Respondent must pay the amount of
EUR 436,800 to the Claimant (i.e., EUR 436,800 minus EUR 24,150 plus EUR 62,400 capped
to the initial amount of compensation), 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 Claimant’s request as well as the constant practice of
the Football Tribunal in this regard, the Chamber decided to award the Claimant interest
on said compensation at the rate of 5% p.a. as of 24 December 2025 until the date of
effective payment.
iii. Compliance with monetary decisions
50. 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.
51. 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.
52. Therefore, bearing in mind the above, the DRC 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.
53. 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.
54. The DRC 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.
pg. 11
REF. FPSD-22552
d. Costs
55. 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.
56. 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.
57. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
pg. 12
REF. FPSD-22552
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Redon Xhixha, is partially accepted.
2.
The Respondent, Chabab Riadhi de Belouizdad, must pay to the Claimant the following
amounts:
- EUR 118,761.29 as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest over the amount of EUR 14,761.29 as from 1 August 2025 until the
date of effective payment;
- 5% interest over the amount of EUR 20,800 as from 1 September 2025 until the
date of effective payment;
- 5% interest over the amount of EUR 20,800 as from 1 October 2025 until the date
of effective payment;
- 5% interest over the amount of EUR 20,800 as from 1 November 2025 until the
date of effective payment;
- 5% interest over the amount of EUR 20,800 as from 1 December 2025 until the
date of effective payment;
- 5% interest over the amount of EUR 20,800 as from 24 December 2025 until the
date of effective payment.
- 5% interest over the amount of EUR 62,400 as from 10 July 2025 until 22 October
2025.
- EUR 436,800 as compensation for breach of contract plus 5% interest p.a. as from 24
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.
pg. 13
REF. FPSD-22552
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
pg. 14
REF. FPSD-22552
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
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396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
pg. 15