CAS 2025/A/11833 Qingdao Hainiu Football Club v. Milos Milovic — Award of 27 July 2026, Sole Arbitrator Prof. Dr. Martin Schimke

A club does not need to stop paying a player to give rise to just cause for termination. Removing the player from the squad registration list may be enough.

In a recent award, the Court of Arbitration for Sport ruled in favour of Montenegrin defender Miloš Milović against his former Chinese Super League club, Qingdao Hainiu FC, offering a clear and well-reasoned restatement of this principle.

The Facts

Milovic signed with Qingdao Hainiu in January 2024 for a contract running from February 2024 to December 2025, on an annual salary of roughly USD 300,000 net. Within a few months he suffered a knee injury during a Chinese Super League match, followed shortly after by a foot injury in a separate game. He underwent meniscus surgery in May 2024 and began a course of rehabilitation.

On 5 July 2024, the club’s head coach signed an internal document titled “Evaluation Form for Leaving Players,” which stated:

“Due to Milos’ slow recovery after meniscus surgery and still unable to meet the competition level of the Chinese Super League, consider to withdraw Milo’s league registration and adding new foreign players.”

On 2 August 2024, the player sent the club a default notice: unpaid remuneration, exclusion from first-team training since 25 July, and — critically — de-registration from the squad. He gave the club fifteen days to reinstate him and settle the arrears, reserving the right to terminate with just cause. Rather than deny the de-registration, the club’s reply on 17 August confirmed it in writing: after a “unanimous decision by the coaching staff,” the club had cancelled his first-team registration, because his recovery had not reached the required level before the summer transfer window closed.

The player terminated the contract on 20 August 2024. He was subsequently registered with Azerbaijani club Sumgait FC via a FIFA Players’ Status Chamber decision granting the International Transfer Certificate over Qingdao Hainiu’s objection, and signed a short, modest replacement contract there.

The FIFA Dispute Resolution Chamber found in the player’s favour, awarding him outstanding remuneration and a substantial compensation figure for breach of contract. The club appealed to CAS.

The Legal Question

The case turned on a single, recurring question in football employment disputes: does a club’s unilateral removal of a player from its league registration list amount, by itself, to just cause for the player to terminate the contract — independent of whether wages are also owed?

What CAS Confirmed: De-Registration Is Its Own Ground for Just Cause

The Sole Arbitrator’s answer drew on a long and consistent line of CAS authority. A player’s ability to train and compete is not incidental to the employment relationship — it is the relationship. De-registration, by preventing a player from being eligible to play at all, was described as amounting to the “factual termination of the employment contract” (CAS 2015/A/4122), and as a serious infringement of the player’s personality rights: the right to develop and fulfil his career through sporting activity, and to protect his professional and economic freedom, including his market value (CAS 2013/A/3091, 3092 & 3093; CAS 2013/A/3354).

The award traces this reasoning through a consistent body of jurisprudence: CAS 2014/A/3643, which frames an employer’s duty to actually occupy an employee whose future career depends on staying visible; CAS 2018/A/6029, which treats being pulled from first-team training as a materially harsher measure than merely being demoted to a reserve squad; CAS 2011/A/2428, which affirms that the bulk of a professional’s training should happen with the team, not alone; and CAS 2018/A/5771 & 5772, and CAS 2016/A/4902, all of which treat de-registration as sufficient, on its own, to justify termination with just cause.

Applied here: because Qingdao Hainiu removed Milovic from its CSL registration list, that fact alone was capable of entitling him to walk away from the contract.

Where the Club’s Defence Failed: On the Evidence, Not the Law

Qingdao Hainiu did not dispute that it had de-registered the player. Its defence was that he had agreed to it, given his slow recovery. This is a legally available defence — a genuinely mutual, documented decision to de-register a player while he completes rehabilitation is not a breach. But the club could not prove it.

• No signed record. The club produced no document showing the player’s agreement to the de-registration — only internal notes and chat screenshots that never recording his consent.
• Its own words worked against it. The club’s 17 August reply to the default notice described the de-registration as a “unanimous decision by the coaching staff” — with no reference to any agreement with the player. The player argued, and the Sole Arbitrator accepted, that this was inconsistent with the club’s later position on appeal that the decision had been mutual.
• Employee witness statements carried limited weight. Three of the club’s four witnesses were its own staff — an interpreter/assistant coach, the general manager, and the head coach — whose statements were, in the Sole Arbitrator’s words, strikingly similar in wording, raising doubts about their independence.

Applying the well-established CAS principle that a party asserting a fact bears the burden of proving it (CAS 2003/A/506; CAS 2009/A/1810 & 1811), the Sole Arbitrator found the club had not discharged that burden. The de-registration was therefore unilateral, and the player had just cause to terminate.

The Quantum Nuance: Which Door You Walk Through Changes What You Recover

This award is also a useful reminder that “just cause” is not one gate but several, and the gate used affects the damages available under Article 17 of the FIFA Regulations on the Status and Transfer of Players.

On appeal, the club produced properly translated bank vouchers showing it had, in fact, paid nearly all of the salary and bonuses the player had claimed as overdue — evidence the FIFA DRC had earlier disregarded for lack of translation. The Sole Arbitrator accepted this evidence and found that, at the point of termination, the outstanding payables did not reach the two-month threshold under Article 14bis RSTP that would independently justify termination for non-payment.

That mattered for compensation. Article 17.1(ii) RSTP allows a player who terminates for overdue payables to recover, on top of the residual value of his contract (net of mitigation), an Additional Compensation sum of three to six months’ salary. Because Milovic’s just cause rested on de-registration rather than on overdue payables, that Additional Compensation under RSTP was not available. The Sole Arbitrator accordingly reduced the compensation from the USD 409,088 net awarded by the FIFA DRC to USD 382,765.17 net — the residual value of the contract, mitigated by his earnings at Sumgait FC, without the Article 17 uplift.

The player still won decisively. But a claim built on both grounds — de-registration and a genuine, well-evidenced overdue-payables default — would have preserved access to the larger compensation envelope.

Practical Takeaways

For clubs

• Never remove a player from the league registration list for sporting or business reasons — injury, underperformance, freeing up a foreign-player slot — without the player’s informed, dated, written consent. Verbal understandings and internal coaching decisions are not a substitute.
• Internal paperwork doesn’t stay internal. If it ends up in front of a tribunal, notes like a coach’s evaluation form can end up proving the other side’s case for them. Here, they did more damage to the club than anything player submitted.
• Think before you put an explantion in writing. A letter written to justify a decision in the heat of the moment,  “the coaching staff unanimously decided…” can come back to haunt you if you later need to argue something different.
• Employee witness statements rarely carry the weight of a contemporaneous signed document — particularly where several statements read as if drafted from the same template.

For players and agents

• De-registration is one of the most reliable just-cause triggers available under CAS jurisprudence — it does not require a prior default notice, though sending one, as Milovic did, strengthens the record and gives the club a documented chance to cure.
• Where possible, build a claim on more than one ground. Pairing de-registration with a genuine, provable overdue-payables default preserves access to the Article 17(1)(ii) Additional Compensation that a de-registration-only claim will not recover.
• Keep your own contemporaneous record — training schedules, chat messages, medical correspondence — from the moment a club begins signalling a change in your status.

Closing Thought

CAS 2025/A/11833 does not create a new legal rule. Instead, it clearly confirms that removing a player from the registration list can be serious enough, by itself, to justify the player terminating their contract.

For clubs across Asia managing injuries, squad changes and foreign-player limits—and for the players affected—the practical message is simple: if a player agrees to being de-registered, record that agreement clearly in writing. Otherwise, a tribunal may assume the player never agreed.

This commentary is provided for general information and does not constitute legal advice. For advice on a specific matter involving player contracts, registration disputes, or FIFA/CAS proceedings, contact Gameplan Legal.