The Court of Arbitration for Sport (CAS) is holding a hearing today, Tuesday, on the appeal filed by Al-Zamalek against Polish player Konrad Michalak, regarding the unilateral termination of his contract and the award of compensation by the FIFA Dispute Resolution Chamber.
Over the past few weeks, Al-Zamalek has managed to settle all cases with rulings issued up to March 2026 in order to obtain a license to participate in the 2026-2027 CAF Champions League season.
However, among the cases referred to the Court of Arbitration for Sport (CAS) to suspend their execution is the one concerning Michalak, for which a ruling was issued last February.
Summary of the Dispute Resolution Chamber's Ruling
FIFA determined that Michalak had just cause to terminate his contract with Al-Zamalek on February 9, 2025, as the club was in arrears of $193,000, equivalent to approximately three months of his average salary, despite a written notice and a 15-day grace period.
FIFA ordered Al-Zamalek to pay:
Arrears: $293,000
Additional compensation for contract termination: $210,000
Total: $503,000 net
In addition to 5% annual interest based on the due date of each amount.
Details of Michalak's Contract
Al-Zamalek and Michalak signed an employment contract on September 11, 2024, while the player was on loan from Saudi club Al-Okhdood. The contract was valid until July 31, 2025, with a total value of $770,000 net, distributed as follows:
$77,000 until September 30, 2024
$93,000 until October 31, 2024
$100,000 until December 31, 2024
$100,000 until February 28, 2025
$100,000 until April 30, 2025
$100,000 until June 30, 2025
$100,000 until July 15, 2025
$100,000 until July 31, 2025
The contract also obligated Al-Zamalek to provide: suitable and furnished accommodation within a compound, a car with a driver for the duration of the contract, round-trip business class air tickets to Warsaw, and to cover taxes and fees, ensuring the player received the agreed amounts net.
Michalak's Claims
Michalak filed his case with FIFA on February 20, 2025, demanding a total of $619,964 from Al-Zamalek; this includes $308,000 in arrears, comprising $93,000 due in October 2024, $100,000 in December, and $115,000 calculated for the period he worked until the contract was terminated.
The player also claimed $308,000 in compensation for the contract termination due to financial arrears, or $385,000 if he was not re-registered with Al-Okhdood, in addition to $3,964 for accommodation, car, and driver, 5% annual interest, the imposition of sporting sanctions on Al-Zamalek, and an order to prove tax payment and bear the costs of the case.
Al-Zamalek's Defense
Al-Zamalek admitted to not paying $193,000 to Michalak but asserted that the contract installments were not monthly and that this amount did not equate to two months' salary according to the club's calculations. The club also objected to including the February installment in the arrears, as it was due on February 28, while the player terminated his contract on the 9th of the same month.
The club denied excluding Michalak or isolating him from the team, explaining that his training with a small group was for technical reasons and did not last more than four days. It also confirmed that it provided the player with suitable accommodation and a car with a driver, but the player chose to live independently without a written agreement obligating Al-Zamalek to reimburse his expenses.
Al-Zamalek argued that the player's return to Al-Okhdood for $100,000 per month fully compensated it for the losses resulting from the termination. Therefore, it requested that his entitlements be limited to $193,000 and rejected the additional compensation, or requested it be reduced to no more than $256,664.
Why Did FIFA Consider the Termination Justified?
The Dispute Resolution Chamber relied on Article 14bis of the Regulations on the Status and Transfer of Players, which grants a player just cause for termination if the club is in arrears of at least two months' salary, after a written notice and a grace period of at least 15 days without payment.
The Chamber calculated Michalak's average salary by dividing the total contract value of $770,000 by 11 months, resulting in an average monthly salary of $70,000. Consequently, it determined that the $193,000 in arrears equated to approximately 2.76 months, exceeding the threshold required for termination.
It was established that Michalak notified Al-Zamalek on January 22, 2025, and granted a 15-day grace period, but the club did not pay the arrears or respond to the notice, nor did it deny the non-payment. Therefore, the Chamber considered the player's termination of his contract on February 9 to be for just cause.
After establishing the justification for the termination due to arrears, the Chamber saw no need to examine Michalak's claims regarding his exclusion from the team, training alone, or attempts to force him to leave. Consequently, the decision neither confirmed nor denied these claims, but deemed their resolution unnecessary.
Additional Compensation and Ruling on the Player's Requests
Although Michalak's return to Al-Okhdood compensated him for the loss of the remaining value of his Al-Zamalek contract, the Dispute Resolution Chamber awarded him additional compensation because the contract termination resulted from financial arrears.
FIFA calculated the additional compensation under Article 17 as equivalent to three months of the player's average salary of $70,000, resulting in $210,000 net, in addition to 5% annual interest from February 9, 2025, until payment.
Thus, the total amount awarded was $503,000 net, comprising $293,000 in arrears and $210,000 in additional compensation, with 5% annual interest calculated on each amount based on its due date.
The decision did not impose an immediate registration ban but granted Al-Zamalek 45 days from the date of notification to pay. In case of non-payment, Michalak has the right to request that the club be banned from registering players locally and internationally until payment is made, for a maximum of three registration periods, with the ban lifted immediately upon payment of the arrears.
FIFA rejected the player's request for compensation equivalent to four or five months, expenses for accommodation and car, the difference between the requested and awarded arrears, the direct imposition of sporting sanctions on Al-Zamalek, as well as the costs of the proceedings and the request for a tax certificate.
