Professional football contracts are founded on the principle of contractual stability.

Article 13 of FIFA’s Regulations on the Status and Transfer of Players, commonly known as the RSTP, provides that a contract between a professional footballer and a club may generally be terminated only when it expires or by mutual agreement.

However, the RSTP recognises circumstances in which a player or club may be entitled to end the relationship early. The central question is often whether there is just cause for termination.

The consequences of getting that assessment wrong can be serious. Players considering terminating a contract should therefore obtain advice before taking any irreversible step.

What Is Just Cause?

Article 14 of the RSTP provides that either party may terminate a contract without compensation or sporting sanctions where just cause exists.

Under the definition introduced by FIFA’s interim regulatory framework, just cause will generally exist where a party can no longer reasonably and in good faith be expected to continue the contractual relationship. Article 14 also addresses abusive conduct intended to force the other party to terminate or change the terms of the contract.

The new definition took effect on 1 January 2025. FIFA described the amendment as providing greater clarity and predictability while codifying the Football Tribunal’s longstanding case law.

The definition does not, however, create an automatic right to terminate whenever a dispute arises. The assessment remains highly dependent on the facts of the individual case.

A Serious Breach Will Usually Be Required

Not every disagreement between a footballer and a club amounts to just cause.

Research reviewing the FIFA framework, FIFA Dispute Resolution Chamber decisions and Court of Arbitration for Sport awards identifies two recurring considerations:

• whether there has been a sufficiently serious breach of the contractual relationship; and

• whether the party seeking to terminate has taken the necessary procedural steps before doing so.

The established approach treats unilateral termination as a measure of last resort. The breach must generally be sufficiently serious that the player cannot reasonably be expected to continue the contractual relationship.

Potential issues may include:

• serious or persistent non-payment;

• substantial breaches of the playing contract;

• abusive conduct intended to force a player to leave or accept different contractual terms;

• serious failures affecting the contractual relationship; or

• conduct resulting in a fundamental breakdown of trust.

Whether any particular conduct reaches the required threshold will depend on the circumstances, the contractual terms and the available evidence.

Outstanding Salaries

Article 14bis contains a specific framework for termination due to outstanding salaries.

A player will be deemed to have just cause where a club unlawfully fails to pay at least two monthly salaries on their due dates, provided that the player has first placed the club in default in writing and allowed it at least 15 days to comply fully with its financial obligations.

Where remuneration is not payable monthly, the relevant threshold is the pro rata value corresponding to two months. The RSTP also recognises that a validly negotiated domestic collective bargaining agreement may contain different provisions that take precedence.

Players should not assume that unpaid wages automatically permit immediate termination. The written default notice and the opportunity to remedy the default are express elements of Article 14bis.

Is Prior Notice Required in Other Cases?

Outside Article 14bis, the RSTP does not impose the same express notice procedure for every form of alleged breach.

However, the approach identified in FIFA commentary and CAS jurisprudence is that prior notice will generally be important. The defaulting party should ordinarily be informed of the alleged breach and given a reasonable opportunity to remedy it before termination is considered.

There may be exceptional circumstances in which the breach is so serious that a further warning would serve no useful purpose, but that should not be assumed.

The practical position is that correspondence sent before termination may later become central evidence. Players should therefore obtain advice before issuing a default notice, refusing to perform obligations or terminating the contract.

Termination Must Usually Be a Last Resort

The principle of contractual stability means that termination is generally treated as a final remedy.

If a less severe and effective response remains available, immediate termination may be difficult to justify. The proportionality of the player’s response, the seriousness of the breach and whether the club was given an opportunity to put matters right may all become relevant.

The August 2026 research examining the amended framework concludes that the new wording largely codifies the established case-by-case approach rather than replacing it. It also identifies continuing uncertainty over matters such as abusive conduct, financial default and the role of prior notice.

What Is Sporting Just Cause?

Sporting just cause under Article 15 is distinct from ordinary just cause under Article 14.

An established professional who has appeared in fewer than 10% of the club’s official matches during the season may potentially terminate on the ground of sporting just cause. The player’s individual circumstances must be assessed, the question is determined case by case, compensation may remain payable, and termination must occur within 15 days following the club’s final official match of the season.

Limited playing time therefore does not automatically create a right to terminate. The regulatory requirements and the player’s particular circumstances must be assessed carefully.

Can a Contract Be Terminated During the Competition Period?

Article 16 states that a contract cannot be unilaterally terminated during a competition period.

The timing of any proposed termination is therefore important, alongside the underlying merits and procedural requirements.

What Happens If a Player Terminates Without Just Cause?

Article 17 addresses the consequences of termination without just cause.

The party suffering loss may be entitled to compensation. Under the interim framework, compensation is assessed by reference to the damage suffered and the “positive interest” principle, taking account of the individual circumstances and giving due consideration to the relevant national law.

A player who breaches a contract during the protected period may also face a restriction on playing in official matches. The RSTP specifies a four month restriction, increasing to six months in aggravating circumstances.

A new club is no longer automatically liable merely because the player joined it following a breach. Under the amended Article 17, liability and sporting sanctions involving the new club require proof that the club induced the player to breach the contract. FIFA identified this change as part of its response to the October 2024 judgment in the Diarra case.

These potential consequences explain why a player should not terminate first and investigate the justification afterwards.

What About an International Transfer?

FIFA’s interim framework also changed the International Transfer Certificate procedure.

A contractual dispute should no longer prevent the issue of an ITC. FIFA’s Circular No. 1917 states that the former association must deliver the ITC within 72 hours of the request. If it does not respond within that period, the new association may register the player. The issue of the ITC does not determine or dispose of the underlying contractual dispute.

A player may therefore be able to continue their career with a new club while liability for the earlier termination remains to be decided.

Evidence Can Determine the Outcome

Just cause disputes are evidence driven.

Relevant material may include:

• the playing contract and any side agreements;

• payment records and payslips;

• written default notices;

• correspondence with the club;

• disciplinary documents;

• medical evidence;

• evidence of any alleged abusive conduct; and

• communications concerning attempts to resolve the dispute.

The chronology is often critical. Players should preserve documents and obtain advice before sending correspondence that could later be characterised as a warning, refusal to perform or termination notice.

How a Lawyer Can Assist

A lawyer experienced in football disputes can assist by:

• reviewing the playing contract and applicable regulatory framework;

• assessing whether the alleged breach could amount to just cause;

• advising on notice and timing requirements;

• preparing formal correspondence;

• preserving and analysing evidence;

• exploring a negotiated exit or settlement;

• advising on compensation and sporting risks; and

• representing the player in proceedings before the relevant tribunal.

The objective is not necessarily to terminate the contract. It is to understand the player’s position, identify the available options and avoid an irreversible step being taken without a proper assessment of the consequences.

Conclusion

Just cause provides an important safeguard for footballers, but the threshold is deliberately demanding.

Contractual stability remains the starting point. A player will generally need to establish a sufficiently serious breach, demonstrate that continuing the relationship is no longer reasonably sustainable and, where appropriate, show that the club was given an opportunity to remedy the position.

Outstanding salary claims under Article 14bis carry specific written notice and timing requirements. Sporting just cause under Article 15 is a separate and tightly defined route. Termination without just cause can expose the player to compensation claims and, in some cases, sporting sanctions.

Any player considering unilateral termination should therefore seek specialist advice before issuing a termination notice or taking steps inconsistent with the contract.

Need Advice?

If you are considering terminating your contract with a club, advice should be obtained before any notice is given.

Barrington Atkins advises footballers and agents on contract termination, just cause disputes, unpaid salary claims and football arbitration.

Sources and further reading

• FIFA, Regulations on the Status and Transfer of Players, January 2025 edition.

• FIFA Circular No. 1917, Interim regulatory framework: amendments to the FIFA Regulations on the Status and Transfer of Players and the Procedural Rules Governing the Football Tribunal, 23 December 2024.

• W Ben Salah, N AlOmran, N Alhendi and Z Nouri, Redefining just cause for contract termination in FIFA’s RSTP, Frontiers in Sports and Active Living, 10 August 2026.