Unpaid players, what to do? Everything you need to know about the salary complaint procedure before the FIFA Football Tribunal, step by step

How can a player recover his unpaid employees from a soccer club? What is the FIFA procedure in case of non-payment? What sanctions are there for failing clubs?
These are all essential questions answered by this case study, which focuses on the decision rendered in July 2024 by the FIFA Football Tribunal's Dispute Resolution Chamber in the case of Valentin Rosier v/Besiktaş JK.

In April 2024, the French defender Valentin Rosier filed a complaint with FIFA for unpaid employees by his employer club, Beşiktaş (Turkey), covering the period preceding his loan to OGC Nice. Despite the reminders, the club refused to pay.
In May 2024, represented by The law firm Fellous Avocats, Rosier filed an official complaint before the FIFA Dispute Resolution Chamber.
Result: decision in favor of the player rendered in July 2024, ordering the payment of the amounts due.

Disputes related to unpaid employees in soccer are becoming more and more frequent: loans, transfers, or simple breach of contract. In response, FIFA and FIFPRO launched the FIFA Players Fund (FIFA FFP) in 2020, a financial aid for players who are victims of these breaches.

This practical guide explains:

• How to get back your unpaid salary as a professional player.
• How does the FIFA procedure for wage disputes work.
• What remedies and sanctions are provided for by international regulations.

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I. Debt collection procedure before FIFA: conditions and steps

1. FIFA jurisdiction: international litigation

In accordance with article 22 of the Regulations on the Status and Transfer of Players (RSTJ), FIFA is competent for international disputes between clubs and players relating to work. This involves:

• Nationality different between the player and the club.
• Absence of preferential agreement for a national chamber (except for an explicit written clause in accordance with FIFA standards).

In the case of Rosier v Beşiktaş, the dispute is international: French player vs Turkish club, meeting the conditions of jurisdiction.

Possibility to derogate from the FIFA competence:
The parties may provide for a clause conferring jurisdiction on a national chamber, provided that it is:

• Written in writing.
• Inserted in the contract or collective agreement.
• Recognizing a national chamber validated by FIFA.

2. Referral procedure via the FIFA Legal Portal

The unpaid player must:

• File a complaint online on the FIFA Legal Portal.
• Provide evidence (contract, payslips, emails...).
• Act within 2 years after the breach of the contract (Art. 23.3 RSTJ).

Example: Valentin Rosier, represented by the Fellous Avocats law firm, followed this procedure. The file included:

• Chronology of events.
• Proofs of stimulus.
• Explicit refusal by the club to pay.

Article 12 bis, 2° RTSJany club that has delayed payment for more than 30 days without a prima facie contractual basis is subject to sanctions in accordance with paragraph 4 below. Article 12bis, 3° RTSJ

For a club to be considered in arrears within the meaning of this article, the creditor (player or club) must have notified the debtor club in writing of the non-payment and granted the debtor club a period of at least ten days to allow it to comply with its financial obligations.

The case is decided by:

• A single judge if the claim is < 200,000 USD.
• A panel of 3 judges or more if ≥ 200,000 USD (Art. 24 RPTF).

Decisions are issued without a hearing except in exceptional circumstances (Art. 14 RPTF).

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II. Enforcement of the decision: legal effects and sanctions

If the club is ordered to pay salaries:

• He has 45 days to execute the decision (Art. 24.2a RSTJ).
• Otherwise, FIFA imposes sports sanctions:

”The club ordered to pay the employees has 45 days to execute the decision.“, Article 24.2 a of the RTSJ

• Prohibition to register new players (transfers and loans).
• Maximum duration: 3 transfer periods (i.e. 18 months).
• International and national application via federations (UEFA, FFF, etc.).

If a player has to pay amounts (abusive resolution, compensation... ):

• Risk of suspension of 6 official matches (Art. 24.2b RSTJ).

The FIFA decision can be contested within 21 days (Art. 50 FIFA Statutes). The CAS in Lausanne is carrying out a complete review of the file.
Statistics: 80% of FIFA decisions are confirmed by the CAS (2022 data).

The Rosier v Beşiktaş case is a perfect illustration of the contractual protection offered by FIFA to professional players in the face of unpaid employees.

Thanks to a clear normative framework, a dedicated online portal (FIFA Legal Portal), and dissuasive sports sanctions, FIFA is fully playing its role as a global football regulator.

Finally, the FIFA Players Fund (FFP) reinforces this protection by providing additional financial support, especially for the most complex cases.