CAS Case Digest · Verified against the full award text

CAS 2025/A/11833 — Qingdao Hainiu Football Club v. Milos Milovic

"Qingdao Hainiu v. Milovic" · CAS partially upheld club's appeal, reducing compensation to USD 382,765.17 after finding player's unilateral de-registration constituted just cause for termination.

What happened in Qingdao Hainiu v. Milovic

Montenegrin professional footballer Milos Milovic signed a two-year contract with Chinese Super League club Qingdao Hainiu FC in January 2024. After sustaining a knee injury in May 2024 and undergoing surgery, the Club unilaterally de-registered him from the CSL squad in July 2024. The Player sent a default notice on 2 August 2024 demanding re-registration and payment of outstanding amounts, then terminated the contract on 20 August 2024 after the Club failed to re-register him. The Player filed a claim before the FIFA DRC, which awarded USD 56,544 net as outstanding remuneration and USD 409,088 net as compensation. The Club appealed to CAS. The Sole Arbitrator confirmed that unilateral de-registration constituted just cause for termination under established CAS jurisprudence on personality rights. However, exercising de novo review, the panel accepted newly translated payment evidence showing the Club had paid most salaries and bonuses before termination, reducing outstanding remuneration to USD 17,594.83 (pro-rated August salary only) and compensation to USD 382,765.17 (residual contract value of USD 418,765.17 minus USD 36,000 earned at Sumgait FC, with no additional compensation as termination was not due to overdue payables). The case matters because it confirms de-registration alone suffices for just cause while demonstrating CAS's de novo power to revise quantum based on newly translated evidence.

Procedural history of CAS 2025/A/11833

On 27 August 2024, Milos Milovic filed a claim before the FIFA Dispute Resolution Chamber seeking outstanding remuneration and compensation for breach of contract following his termination of the employment contract on 20 August 2024. The Club filed a counterclaim under Article 17 RSTP for USD 418,765.17, but it was deemed withdrawn after the Club failed to provide a bank account registration form within the deadline. On 26 August 2025, the FIFA DRC partially accepted the Player's claim, ordering Qingdao Hainiu FC to pay USD 56,544 net as outstanding remuneration and USD 409,088 net as compensation for breach of contract, both with 5% interest p.a. from 20 August 2024. The grounds were notified on 26 September 2025. On 11 October 2025, the Club filed a Statement of Appeal with CAS. The Respondent filed his Answer on 15 January 2026. Both parties waived a hearing and the Sole Arbitrator decided on written submissions alone.

Key holdings in CAS 2025/A/11833

• Unilateral de-registration of a player by a club constitutes a breach of contract of sufficient severity to give the player just cause to terminate the employment contract, even without a prior default notice.
• A club bears the burden of proving that a player consented to his de-registration; absent documentary evidence of such agreement, the de-registration is treated as unilateral.
• Witness statements by club employees that are near-identical in wording and structure lack sufficient independence and their probative value is limited.
• Under Article 17 RSTP, additional compensation (three to six monthly salaries) is only available where termination is due to overdue payables; where just cause rests on de-registration alone, only mitigated compensation applies.
• CAS's de novo review under Article R57 of the CAS Code permits the panel to accept newly translated evidence not properly considered at first instance and to revise the quantum of outstanding remuneration and compensation accordingly.

How the CAS panel reasoned

The Sole Arbitrator first assessed whether the Club's de-registration was unilateral or mutually agreed. Applying the burden-of-proof standard from CAS 2003/A/506, the panel found the Club's evidence insufficient: chat screenshots contained no express agreement; the Club's own 17 August 2024 reply to the default notice described the de-registration as a 'unanimous decision by the coaching staff' with no mention of player consent; and the four witness statements were undermined by near-identical wording and internal inconsistencies (the dinner date of 4 July 2024 in three statements versus a conference call on 2 July 2024 in the agent's statement). Relying on CAS 2013/A/3091-3093, CAS 2014/A/3643, CAS 2018/A/5771 & 5772 and related jurisprudence on personality rights, the panel confirmed that unilateral de-registration alone suffices for just cause. On quantum, the panel exercised de novo review and accepted newly translated bank vouchers as credible proof that the Club had paid the July 2024 salary and draw-match bonuses before termination. The FIFA DRC's award of a full August salary was corrected to the pro-rated amount actually claimed by the Player (USD 17,594.83). On compensation, the panel deducted the USD 36,000 earned at Sumgait FC from the residual contract value of USD 418,765.17, yielding USD 382,765.17. Additional compensation under Article 17 par. 1 lit. ii) was denied because the termination was grounded in de-registration, not overdue payables.

Why Qingdao Hainiu v. Milovic matters in CAS jurisprudence

This award reinforces the settled CAS principle that unilateral de-registration of a player is, by itself, a sufficiently serious breach of personality rights to justify immediate termination with just cause, without any prior default notice. It also illustrates CAS's de novo review power to correct first-instance quantum errors when newly translated evidence is produced on appeal, and clarifies that additional compensation under Article 17 par. 1 lit. ii) RSTP is unavailable where just cause rests on de-registration rather than overdue payables.

Cases cited in this award

CAS 2003/A/506 CAS 2006/A/1062 CAS 2006/A/1100 CAS 2006/A/1180 CAS 2007/A/1210 CAS 2011/A/2428 CAS 2013/A/3091, 3092 & 3093 CAS 2013/A/3354 CAS 2014/A/3525 CAS 2014/A/3643 CAS 2015/A/4122 CAS 2016/A/4902 CAS 2018/A/5771 & 5772 CAS 2018/A/6029 CAS 2020/A/7239, 7261 CAS 2009/A/1810 & 1811 CAS 2009/A/1975

Frequently asked questions about Qingdao Hainiu v. Milovic

Does unilateral de-registration by a club give a player just cause to terminate in Chinese football cases?

Yes. In Qingdao Hainiu v. Milovic (CAS 2025/A/11833), the Sole Arbitrator confirmed that unilateral de-registration of a player from the CSL squad constitutes a breach of contract of sufficient severity to justify termination with just cause, relying on a line of CAS authority including CAS 2018/A/5771 & 5772. The club's failure to produce any written record of the player's consent was fatal to its defence.

How did CAS calculate compensation in Qingdao Hainiu v. Milovic?

The panel applied Article 17 RSTP and calculated the residual contract value at USD 418,765.17 (covering 21 August 2024 to 31 December 2025), then deducted USD 36,000 earned by the player at Sumgait FC, yielding USD 382,765.17 net. No additional compensation (three to six monthly salaries) was granted because the termination was based on de-registration, not overdue payables, so Article 17 par. 1 lit. ii) additional compensation did not apply.

Can a club use newly translated payment evidence for the first time at CAS to reduce outstanding remuneration?

Yes. In this case the FIFA DRC had rejected the club's payment evidence as untranslated, but on appeal the Club submitted fully translated bank vouchers. The Sole Arbitrator accepted them under CAS's de novo review power (Article R57 CAS Code), finding them credible in the absence of contradicting bank statements from the player, and reduced outstanding remuneration from USD 56,544 to USD 17,594.83.

What weight do witness statements from club employees carry in CAS proceedings?

In Qingdao Hainiu v. Milovic, the Sole Arbitrator gave limited weight to three near-identical witness statements from club employees (interpreter/assistant coach, General Manager, and Head Coach), noting they lacked independence and contained internal inconsistencies — including a discrepancy between a dinner on 4 July 2024 (per the three employees) and a conference call on 2 July 2024 (per the Chinese agent's statement). This is consistent with established CAS and FIFA jurisprudence that employee statements in support of their employer's position have reduced probative value.

Topics: Art. 17 RSTP & contract termination at CAS

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