CAS Case Digest · Verified against the full award text

CAS 2024/A/10480 — Amar Kovcic v. NK Trnje Zagreb

"Kovcic" · CAS dismissed a Bosnian player's compensation claim after finding he failed to prove a written employment contract with Croatian club NK Trnje Zagreb.

What happened in Kovcic

Amar Kovcic, a Bosnian footballer, joined NK Trnje Zagreb in summer 2023 and played six matches between August 26 and October 7, 2023. On October 12, 2023, the Club signed a release document. Kovcic filed a claim before the FIFA DRC alleging unilateral termination without just cause, seeking €271 in unpaid wages for October 2023 and €6,029 in compensation, plus 5% annual interest and sporting sanctions. The DRC rejected his claim on February 8, 2024. Kovcic appealed to CAS, arguing the DRC failed to assess circumstantial evidence of a contractual relationship, including alleged monthly salary payments of €700 and his participation in six matches. The Club denied any written contract existed and argued Kovcic had voluntarily requested his own release. The Sole Arbitrator found that witness testimony was contradictory and inconclusive, the only documented payment was made by a third party after Kovcic had already left the Club, and Kovcic failed to prove his remuneration exceeded his expenses. Since both cumulative requirements of Article 2 RSTP — a written contract and remuneration exceeding expenses — were unmet, Kovcic could not be classified as a professional player, and Article 17 RSTP compensation was unavailable. The appeal was dismissed and the DRC decision confirmed. The case reinforces that the written contract requirement for professional status under FIFA RSTP is mandatory and cannot be replaced by circumstantial evidence or national law.

Procedural history of CAS 2024/A/10480

On November 22, 2023, Kovcic filed a claim before the FIFA Football Tribunal's Dispute Resolution Chamber (DRC) against NK Trnje Zagreb for unilateral termination without just cause, requesting €271 in unpaid wages, €6,029 in compensation (alternatively €4,200), 5% annual interest, and sporting sanctions. On February 8, 2024, the DRC rejected the claim in its entirety without costs, finding insufficient evidence of a written employment contract. On March 14, 2024, Kovcic filed a statement of appeal at CAS under Article R47 of the Code, requesting a sole arbitrator and English-language proceedings. Legal aid was granted on April 9, 2024, from the Football Legal Aid Fund. The sole arbitrator was appointed on May 14, 2024. A hearing was held by videoconference on October 29, 2024, and continued on December 21, 2024, to accommodate testimony from the Club's president. CAS issued its award on March 31, 2025, dismissing the appeal and confirming the DRC decision.

Key holdings in CAS 2024/A/10480

• A football player can only be classified as a professional under Article 2 RSTP if two cumulative requirements are met: a written employment contract with a club and remuneration exceeding the player's football-related expenses.
• The written contract requirement for professional player status under FIFA RSTP is mandatory and cannot be substituted by national legislation or circumstantial evidence.
• Contradictory and inconsistent witness testimony is insufficient to establish the existence of a written employment contract when no documentary evidence of such contract is produced.
• A bank transfer made by a third party (not the club) after the player had already left the club does not constitute proof of a salary under the employment contract.
• Article 17 RSTP compensation for unilateral termination without just cause is available only to professional players and cannot be claimed where professional status has not been established.

How the CAS panel reasoned

The Sole Arbitrator structured the analysis around the two cumulative requirements of Article 2 RSTP. On the first requirement — a written contract — the Arbitrator noted that the Respondent denied the contract's existence and refused to produce it, leaving only indirect evidence. Witness testimony was found to be contradictory and inconclusive, with neither side's witnesses deemed more credible than the other's. The only documentary payment evidence — a bank transfer — was made by Ana Kljajic (apparently the Club vice-president's daughter), not the Club itself, and was dated November 3, 2023, after Kovcic had already left. This was held insufficient to prove a salary. On the second requirement — remuneration exceeding expenses — the Arbitrator noted that Kovcic's submissions did not even address his expenses, which he was in a position to prove. The Arbitrator also rejected the argument that playing matches and receiving some payment necessarily implies professional status, noting that amateur players may also play and receive limited payments. The Arbitrator cited CAS 2015/A/4148 & 4149 & 4150 for the proposition that professional status is defined exclusively by FIFA RSTP without reference to national regulations. Since neither requirement was proven, Article 17 RSTP was inapplicable, and all relief was denied.

Why Kovcic matters in CAS jurisprudence

This award reinforces the strict and mandatory nature of the written contract requirement under Article 2 FIFA RSTP for establishing professional player status. The panel confirmed, consistent with prior CAS jurisprudence, that national law cannot substitute for this requirement and that circumstantial evidence — including match participation and informal payments — is insufficient to prove professional status. The case also illustrates the evidentiary burden on players who allege a contract exists but cannot produce it, particularly where the only payment evidence involves a third-party transfer made after the employment period ended.

Cases cited in this award

CAS 2015/A/4148 & 4149 & 4150

Frequently asked questions about Kovcic

What did CAS decide in the Kovcic v NK Trnje Zagreb case?

CAS dismissed Kovcic's appeal and confirmed the FIFA DRC's decision rejecting his claim. The Sole Arbitrator found that Kovcic failed to prove the existence of a written employment contract with NK Trnje Zagreb, which is a mandatory requirement under Article 2 RSTP to be classified as a professional player. Without professional status, Article 17 RSTP compensation for unilateral termination without just cause was unavailable.

Can a player prove professional status without a written contract by showing he was paid and played matches?

No, according to this award. The Sole Arbitrator held that both cumulative requirements of Article 2 RSTP must be met: a written employment contract and remuneration exceeding expenses. Playing six matches and allegedly receiving €700 per month in cash were insufficient to establish professional status, particularly where the only documented payment was a bank transfer made by a third party after the player had already left the club.

Does national law allowing verbal contracts satisfy the FIFA RSTP written contract requirement?

No. The Sole Arbitrator, citing CAS 2015/A/4148 & 4149 & 4150, confirmed that professional player status is defined exclusively by FIFA RSTP without reference to national regulations, and that national federations are obliged to literally transpose Article 2 RSTP. Even if Croatian or Bosnian law permitted verbal employment contracts, this would not satisfy FIFA's mandatory written contract requirement.

What was the compensation Kovcic sought and why was it rejected in the Kovcic case?

Kovcic sought €271 in unpaid wages for October 2023, €6,029 in compensation for breach of contract (alternatively €4,200), 5% annual interest from October 13, 2023, and sporting sanctions against NK Trnje Zagreb. All claims were rejected because Kovcic could not establish he was a professional player under Article 2 RSTP, and Article 17 RSTP — which provides compensation for unilateral termination without just cause — applies only to professional players.

Topics: Art. 17 RSTP & contract termination at CAS

Source: official award. This digest was generated by LexXi from the full award text and machine-verified against it — every figure, article and citation above appears in the source. It is an editorial summary, not legal advice. See how ElevenLex verification works.