Labour Disputes
Texto da decisão
REF. FPSD-22684
Decision of the
Dispute Resolution Chamber
passed on 17 February 2026
regarding an employment-related dispute concerning the player Eduardo
Gomes Hyppolito Junior
BY:
Calum BEATTIE, Scotland
CLAIMANT:
Eduardo Gomes Hyppolito Junior, Brazil
Represented by Filipe Orsolini Pinto de Souza
RESPONDENT:
Angkor Tiger FC, Cambodia
pg. 2
REF. FPSD-22684
I. Facts of the case
1.
On 9 July 2025, the Brazilian player Eduardo Gomes Hyppolito Junior (hereinafter: the Player
or the Claimant) and the Cambodian club Angkor Tiger FC (hereinafter: the Club or the
Respondent) entered into an employment contract (hereinafter: the Contract) valid from 21
July 2025 until the last match of the 2025/2026 season (expected end of May 2026).
2.
Pursuant to clause 4 of the Contract, the Player was entitled to a monthly salary of USD
2,600 net, payable on the 15th and 31st of each month (i.e., 50% each).
3.
Clause 8 of the Contract established, inter alia, the following:
“[…] 4. [The Club] has a right to terminate this Contract without mutual consent and claim
for damages against [the Player] if [the Player] breach this Contract.
[…]
14. [The Club] will pay $2500 for airplane ticket fee by cash to [the Player] on 30th July
2025 on salary day.
[…]
19. During the contract period, if [the Player] wish to terminate this Contract, [the Player]
shall pay to [the Club] the money as penalty in the amount equivalent to all money [the
Player] has received under this Contract. Alternatively, the contract shall be terminated
if both parties agree to the cancellation under the mutual agreement.
4.
The Player submitted an unsigned copy of the Contract. However, a fully executed version
of the document was duly uploaded by the Club to the FIFA Transfer Matching System
(TMS).
5.
According to the Player, in early December 2025 the Club informed him, via written
messages, that it intended to terminate the Contract, invoking the Player’s physical
condition (in particular, his weight) as the reason for termination.
6.
On 6 December 2025, the Club issued a document titled “Proof of last contract end date”,
stating that the Contract was terminated by mutual agreement on 10 December 2025. The
Player never signed this document and disputed its content and the date indicated therein.
7.
On 12 December 2025, following the termination, the Club paid the Player a total amount
of USD 10,839, which the Player broke down as follows:
•
•
USD 520 corresponding to salary for 1–6 December 2025;
An amount equivalent to three monthly salaries (USD 7,800); and
pg. 3
REF. FPSD-22684
•
USD 2,519 as contribution towards flight tickets.
8.
On 14 December 2025, the Player issued flight tickets for him and his family from Siem
Reap (Cambodia) to Sao Paulo (Brazil), with a stopover in Dubai (UAE). Each ticket, issued
by the Player, cost USD 1,232.80, totalling USD 3,698.40 for three people.
9.
On 7 January 2026, the Player signed a new employment contract with the Brazilian club
União Esporte Clube de Rondonopolis (MT), which was valid from the date of signature until
7 April 2026. Accordingly, the Player would be entitled to a monthly remuneration of BRL
2,500 – equivalent to USD 463,38 at the time of signing.
II. Proceedings before FIFA
10. On 16 January 2026, the Player filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Position of the Player
11. The Player alleged that the Club unilaterally terminated the Contract without just cause on
6 December 2025, in violation of the FIFA Regulations on the Status and Transfer of Players
(hereinafter: the Regulations). He argued that his physical condition could not constitute just
cause for termination, particularly since the Club had signed the Contract without
conducting medical examinations beforehand.
12. The Player further maintained that the termination was wrongly characterized by the Club
as a mutual agreement, despite the fact that he had never consented to such termination
nor signed the relevant document.
13. The Player submitted that, as a consequence of the termination without just cause, he was
entitled to compensation corresponding to the residual value of the Contract, as well as
full reimbursement of his flight expenses. He therefore requested that the Club be ordered
to pay outstanding remuneration, compensation for breach of contract, interest, and that
sporting sanctions be imposed.
14. The Player’s calculations were as follows:
Due Salary / Flight
Tickets (net)
USD 2,600.00
USD 2,600.00
USD 2,600.00
USD 2,600.00
USD 2,600.00
USD 2,600.00
Corresponding Month Amounts
Effective
Paid (net)
December 2025
USD 520,00 (6 days)
January 2026
USD 2,600.00
February 2026
USD 2,600.00
March 2026
USD 2,600.00
April 2026
USD 0
May 2026
USD 0
Outstanding
Amounts (net)
USD 2,080.00
USD 0
USD 0
USD 0
USD 2,600.00
USD 2,600.00
pg. 4
REF. FPSD-22684
USD 3,698.40
Flight Tickets (USD USD 2,519
3,698.40)
TOTAL DUE AMOUNT
USD 1,179.40
USD 8,459.40
15. The Player requested the following relief:
“In view of all above, the Claimant requests:
a. the FIFA general secretariat to issue a proposal according to the Article 20 of the FIFA
Procedural, given that the case does not raise complex factual or legal issues;
b. the DRC to send this claim to the Respondent Angkor Tiger Football Club Co Ltd
(Cambodia) with a time limit for a statement or a reply, pursuant article 21.1 the FIFA
Procedural;
c. the DRC to retrieve the signed Contract from the TMS, in accordance with Article 13.4
of the FIFA Procedural;
d. the DRC to accept this claim and declare that the Contract was terminated without just
cause by the Respondent on 6 December 2025, according to the article 18.4 of the FIFA
RSTP;
e. the DRC to accept this claim and order the Respondent Angkor Tiger Football Club Co
Ltd (Cambodia) to pay the Claimant the total net amount of USD 8,459.40 (eight
thousand, four hundred and fifty‑nine American dollars and forty cents), plus interests
of 5% p.a. as from the termination date on 6 December 2025;
f. the DRC to accept this claim and sanction the Respondent Angkor Tiger Football Club
Co Ltd (Cambodia) in accordance with article 17.4 of FIFA RSTP.
g. the DRC to accept this claim and include the consequences of the failure to pay the
relevant amounts in due time, pursuant article 24 of the FIFA RSTP.”
b. Position of the Club
16. Despite having been invited to do so, the Club failed to present its response to the Player’s
claim.
pg. 5
REF. FPSD-22684
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
17. 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 16 January 2026 and submitted for
decision on 17 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.
18. 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 Brazilian player and a Cambodian club.
19. 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
the Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Burden of proof
20. 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 TMS.
c. Merits of the dispute
21. 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 his considerations he
would refer only to the facts, arguments and documentary evidence, which he considered
pertinent for assessing the matter at hand.
pg. 6
REF. FPSD-22684
i. Main legal discussion and considerations
22. 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 his former club.
23. As the Club failed to reply to the claim, the Single Judge noted that it remained undisputed
that the contractual relationship between the parties came to an end in December 2025,
prior to the agreed expiry date of the Contract.
24. In particular, the Single Judge also noted that the document titled “Proof of last contract end
date” referred to a termination by mutual agreement; however, the Player denied having
agreed to such termination and the Club failed to provide any evidence to the contrary.
25. In view of the foregoing, and in the absence of any response from the Club, the Single Judge
concluded that the Contract was unilaterally terminated by the Club on 6 December 2025.
26. Furthermore, according to the Player, the Club invoked the Player’s physical condition as
the reason for the termination of the Contract. However, the Single Judge accepted the
Player’s position according to which a player’s physical condition does not constitute just
cause for the unilateral termination of an employment contract, in particular where the
Club did not conduct medical examinations prior to signing the Contract.
27. In this context, the Single Judge acknowledged that his task was to determine the
consequences of the contract termination.
28. First, given that the Contract was terminated on 6 December 2025, and the Club paid the
Player’s salary up until that date, the Single Judge concluded that there was no outstanding
remuneration at the time of the termination.
29. Second, the Player confirmed that he received USD 2,519 as contribution towards flight
expenses. However, the Player alleged (and proved) that his and his family’s cost more than
that.
30. Notwithstanding the above, the Single Judge took note that the Contract exclusively
provided for a USD 2,500 flight allowance, which was complied with by the Club. Similarly,
the Single Judge also noted that there was no contractual entitlement to any
reimbursement of family expenses, let alone an acknowledgement of debt by an identified
Club representative – reason why the Single Judge decided to dismiss this part of the claim.
31. Third, and 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
pg. 7
REF. FPSD-22684
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.
32. 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.
33. 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).
34. 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 Player under the terms of the Contract
from the date of its unilateral termination until its end date. Consequently, the Single Judge
concluded that the residual value of the Contract ultimately amounted to USD 7,280 (i.e.,
USD 15,080 corresponding to the prorated salary of December 2025 and the salaries from
January to May 2026 minus USD 7,800 that were admittedly paid by the Club).
35. In continuation, the Single Judge verified as to whether the Player had signed an
employment contract with another club during the relevant period of time, by means of
which he would have been enabled to further mitigate 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.
36. Indeed, the Player found employment with the Brazilian club União Esporte Clube de
Rondonopolis (MT). In accordance with the pertinent employment contract, the Player was
entitled to approximately USD 463.38 per month. Therefore, the Single Judge concluded
that the Player mitigated his damages in the total amount of USD 1,763.83, that is, USD
373.69 as the prorated salary for January 2026 plus USD 1,390.14 as the salaries from
February to April 2026 (i.e., USD 463.38 three times).
37. 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 Club
pg. 8
REF. FPSD-22684
terminated the Contract and for reasons not linked to overdue payables; thus no additional
compensation applied.
38. 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
USD 5,516.17 net (i.e., USD 7,280 minus USD 1,763.83) to the Player, which was to be
considered a reasonable and justified amount of compensation for breach of contract in
the present matter.
39. 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 6 December 2025 until the date of effective
payment.
ii. Compliance with monetary decisions
40. 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.
41. 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.
42. 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 Respondent in
accordance with art. 24 par. 2, 4, and 7 of the Regulations.
43. 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.
44. 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.
pg. 9
REF. FPSD-22684
d. Costs
45. 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.
46. 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.
47. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 10
REF. FPSD-22684
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Eduardo Gomes Hyppolito Junior, is partially accepted.
2.
The Respondent, Angkor Tiger FC, must pay to the Claimant the following amount(s):
- USD 5,516.17 net as compensation for breach of contract plus 5% interest p.a. as from
6 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
pg. 11
REF. FPSD-22684
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