Labour Disputes
Texto da decisão
REF. FPSD-22674
Decision of the
Dispute Resolution Chamber
passed on 26 March 2026
regarding an employment-related dispute concerning the player Endri Cekici
COMPOSITION:
Clifford J. HENDEL (USA & France), Deputy Chairperson
Oleg ZADUBROVSKIY (Russia), Member
Khadija TIMERA (Senegal), Member
CLAIMANT:
Endri Cekici, Albania
Represented by Çağlar Akoğlu
RESPONDENT:
Chabab Riadhi de Belouizdad, Algeria
pg. 2
REF. FPSD-22674
I. Facts of the case
1.
On 29 July 2025, the Albanian player, Endri Cekici (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 until the end of the 2026/2027 season.
2.
According to clause 1 of the Contract, the parties agreed on the following (quoted verbatim):
“1.1 The Player’s total annual net salary is set at three hundred thousand euros (€300,000)
for the 2025/2026 season and for the 2026/2027 season, payable in arrears and payable in
Algerian Dinar equivalent, effective from the date of signature of the contract, i.e.,
29/07/2025.
1.2 An amount of sixty thousand euros (€60,000), 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.
1.3 The Club shall be responsible for all taxes and social charges, ensuring the player receives
the full stated net amount.
1.4 The Club hereby covenants and agrees, under the terms of this Agreement, to ensure the
unconditional and full (100%) payment of the Player’s net salary for the entire duration of the
Contract, in accordance with the Player’s valuation and standing, without prejudice to any
other rights conferred upon the Player under this Agreement.”
3.
On 17 December 2025, the Player sent a default notice to the Club stating that it has only
paid the amount of EUR 58,650 and still owed the Player the amount of EUR 81,350
corresponding to EUR 1,350 as the balance of the sign-on fee, EUR 20,000 for the salary of
August 2025, EUR 20,000 for the salary of September 2025 and EUR 20,000 for the salary
of November 2025. The Player gave a 15-day notice to the Club to comply with its default.
4.
On 6 January 2025, the Player sent a termination letter to the Club.
5.
On an unspecified date, the Player signed a new employment contract with the Iraqi club,
Zakho SC valid as from 10 January 2026 until 1 July 2026 (hereinafter: the New Contract). The
Player is entitled to a monthly salary of USD 10,000.
pg. 3
REF. FPSD-22674
II. Proceedings before FIFA
6.
On 16 January 2025, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Claim of the Claimant
7.
The Player lodged the present claim for overdue payables.
8.
The Player alleged that he had just cause to terminate his Contract as more than 2 monthly
salaries remained outstanding and he put the Club in default giving it 15 days to comply
with its financial obligations.
9.
In view of the above, the Player requested the following relief (quoted verbatim):
“The Claimant would like to request form the FIFA Football Tribunal to decide that the
Claimant terminated the contract with just cause.
The Claimant would like to request from the FIFA Football Tribunal to decide that the
Respondent has to pay the amount of 101,350 EURO net with its interest of 5% p.a. as stated
above until the effective payment date.
The Claimant would like to request form the FIFA Football Tribunal to decide that the
Respondent has to pay the amount of 390,694 EURO with its interest of 5% p.a. as Mitigated
Compensation for the residual value of the contract from the termination date, i.e. 6 January
2026, until the effective payment date.
The Claimant would like to request form the FIFA Football Tribunal to decide that the
Respondent has to pay the amount of 49,306 EURO with its interest of 5% p.a. as the
Additional Compensation from the termination date, i.e. 6 January 2026, until the effective
payment date.
The Claimant would like to request from the FIFA Football Tribunal to impose sporting
sanctions on the Respondent according to the Art. 17/4 of FIFA Regulations on the Status and
Transfer of Players.
The Claimant finally would like to request from the FIFA Football Tribunal to impose sanctions
on the Respondent according to the Art. 12bis of FIFA Regulations on the Status and Transfer
of Players.”
b. Reply of the Respondent
10. Despite being invited to do so, the Club did not reply to the claim.
pg. 4
REF. FPSD-22674
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
11. 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 16 January 2026 and submitted for decision
on 26 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.
12. 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.
13. 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
14. 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
15. 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. 5
REF. FPSD-22674
i. Main legal discussion and considerations
16. The Chamber then moved to the substance of the matter, and took note of the fact that
the Player alleged that he had just cause to terminate the Contract due to outstanding
salaries.
17. The Club, on the other hand, did not respond to the claim, entailing that the Chamber’s
decision must be made on the basis of the documentation on file, that is, the
argumentation and evidence filed by the Claimant in line with art. 14 par. 1 and 21, par. 1
of the Procedural Rules.
18. In this context, the Chamber acknowledged that its task was to determine whether the
Player had just cause to terminate the Contract and the consequences thereof.
19. The Chamber recalled that according to art. 14 bis 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).
20. In the case at hand, the Player alleged not having received the salaries corresponding to
the months of August, September, October and November 2025 (i.e., 4 monthly salaries) as
well as the balance of the sign-on fee of the amount of EUR 1,350 and has provided written
evidence of having put the Respondent in default on 17 December 2025, i.e. at least 15 days
before the unilateral termination of the Contract, on 6 January 2026.
21. In view of the above, the Chamber decided that the Player had just cause to terminate the
Contract in line with art. 14bis of the Regulations.
ii. Consequences
22. 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.
23. 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 4 salaries under
the Contract as well as the balance of the sign-on fee, amounting to EUR 101,350.
24. 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
101,350 (EUR 20,000 times 5 plus EUR 1,350 as the balance of the sign-on fee).
pg. 6
REF. FPSD-22674
25. 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 1,350 as from 30 July 2025 until the date of
effective payment;
5% interest over the amount of EUR 20,000 as from 1 September 2025 until the date
of effective payment;
5% interest over the amount of EUR 20,000 as from 1 October 2025 until the date of
effective payment;
5% interest over the amount of EUR 20,000 as from 1 November 2025 until the date
of effective payment;
5% interest over the amount of EUR 20,000 as from 1 December 2025 until the date
of effective payment;
5% interest over the amount of EUR 20,000 as from 1 January 2026 until the date of
effective payment.
26. 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.
27. In application of the relevant provision, the Chamber held that it first of all had to clarify as
to whether the 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.
28. 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).
29. 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 450,000 (i.e., the residual value of the Contract) serves
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REF. FPSD-22674
as the basis for the determination of the amount of compensation for breach of contract,
corresponding to the salaries from January 2026 to June 2027.
30. 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.
31. Indeed, the Player found employment with Zakho SC. In accordance with the New Contract,
the Player was entitled to the total amount of USD 56,666.66 (approx. EUR 48,971.33)
corresponding to USD 10,000 per month from February to June 2026 plus USD 6,666 pro
rata for the month of January 2026. Therefore, the Chamber concluded that the Claimant
mitigated his damages in the total amount of EUR 48,971.
32. 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.
33. In this respect, the DRC decided to award the amount of additional compensation of EUR
60,000, i.e., three times the monthly remuneration of the Player.
34. 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 450,000 to the Claimant (i.e., EUR 450,000 minus EUR 48,971.33 plus EUR 60,000
capped to the initial residual value of the Contract), which was to be considered a
reasonable and justified amount of compensation for breach of contract in the present
matter.
35. However, the Chamber observed that the Player had limited its request for compensation
to EUR 440,000. Hence, based on the principle of ne ultra petita the Chamber limited the
compensation payable to the Player to the amount of EUR 440,000.
36. 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 9 January 2026 until the date of effective
payment.
pg. 8
REF. FPSD-22674
iii. Compliance with monetary decisions
37. 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.
38. 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.
39. 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.
40. 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.
41. 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.
d. Costs
42. 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.
43. 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.
44. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
pg. 9
REF. FPSD-22674
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Endri Cekici, is partially accepted.
2.
The Respondent, Chabab Riadhi de Belouizdad, must pay to the Claimant the following
amounts:
- EUR 101,350 as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest over the amount of EUR 1,350 as from 30 July 2025 until the date of
effective payment;
- 5% interest over the amount of EUR 20,000 as from 1 September 2025 until the date
of effective payment;
- 5% interest over the amount of EUR 20,000 as from 1 October 2025 until the date of
effective payment;
- 5% interest over the amount of EUR 20,000 as from 1 November 2025 until the date
of effective payment;
- 5% interest over the amount of EUR 20,000 as from 1 December 2025 until the date
of effective payment;
- 5% interest over the amount of EUR 20,000 as from 1 January 2026 until the date of
effective payment.
- EUR 440,000 as compensation for breach of contract plus 5% interest p.a. as from 9
January 2026 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. 10
REF. FPSD-22674
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 11
REF. FPSD-22674
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. 12