Termination by a Professional Footballer for Unpaid Wages: The 30-Day Notice, Termination Period and Compensation (PFSTT Art. 28)

For professional footballers, the club's failure to pay wages is one of the most common reasons for ending a contract. If the termination does not follow procedure, however, it may be treated as an unjustified termination and the footballer may lose rights. This article gives general information under Article 28 of the Turkish Football Federation's Instruction on the Status and Transfers of Professional Footballers (PFSTT). It does not replace an assessment of your file and predicts no result. For collecting wages, see our article on athletes' wage claims.

1. Just cause: non-payment of wages

A club's failure to pay a footballer's due wages may be just cause for termination for the footballer. In a decision of 4 June 2021, the TFF Arbitration Board also stated that a club's default on wages is just cause, but that the footballer must follow the procedure in PFSTT Art. 28 when exercising this right.

2. Procedure: notarial notice, 30 days, short termination period

As described in that decision, the main lines of PFSTT Art. 28 are:

• The footballer sends the club a notarial warning setting a payment period of 30 days.
• If the club does not pay despite this period, the footballer may terminate the contract within seven days of the end of the period.
• These periods cannot be changed to the footballer's detriment (Art. 28/3). The Board stated that, because the procedure is mandatory, contract terms granting a right of immediate termination or giving less than 30 days are contrary to PFSTT and invalid.
• If the footballer terminates without following the procedure, the termination may be classified as unjustified even though just cause exists (the Board decision).

Because instruction provisions may be updated, check the PFSTT text in force and your contract before terminating.

3. Examples from Court of Cassation practice

• Termination following a proper notice: the 13th Civil Chamber held termination based on a payment notice given under the procedure in PFSTT Art. 28 for unpaid due wages to be based on just cause (2015/20166, 2016/4162; 2014/35973, 2016/3223).
• Match-fee difference: in the same decisions, a claimed match-fee difference within termination compensation was found to be an uncertain claim, as whether the footballer would play depends on the club's technical discretion, and the compensation claim on this basis was to be rejected.
• Proof of payment: in one case before the 13th Civil Chamber (2016/23235, 2019/8073), the first-instance court accepted the wage claim because the club produced no proof of payment and the footballer was found to have played for another club after termination, and partly accepted compensation for justified termination.
• Lost wages: in some cases before the 3rd Civil Chamber, footballers sought a declaration of justified termination and compensation for guaranteed wages and match fees lost after a notice and termination (2024/905, 2025/1277; 2025/3067, 2025/5924).

4. What should a footballer check before terminating?

• Collect the contract and bank records showing wages were due and unpaid.
• Make sure the notarial notice is sent to the correct address, with the correct content and a provable date of service.
• Note the date the payment period ends and the seven-day termination period.
• Make the termination itself through a notary and document it.
• Remember that a new contract with another club after termination may affect compensation.

5. Which forum?

Disputes between footballers and clubs may be heard in TFF bodies (the Dispute Resolution Committee and the Arbitration Board) as well as in courts. See our related article on how the competent forum is determined.

6. Contact

If you would like your contract, notices and payment documents assessed, you can create an appointment or reach us via the contact page.

This article is for general information only, contains no promise of results and is not legal advice. The decisions mentioned are examples only; the instruction text and periods must be checked before terminating.