Your Turkish Volleyball Club Has Not Paid You. Here Is What International Law Allows You to Do.

Turkey hosts one of the most competitive volleyball leagues in the world. Every season, dozens of foreign players sign contracts with Turkish clubs — only to find themselves, months later, chasing overdue payments across a language barrier, in an unfamiliar legal system, unsure of where to turn.

There is, however, a powerful international mechanism available to you: the FIVB / CEV Financial Dispute Procedure. It is specifically designed for cross-border salary disputes between volleyball players and clubs. It operates in English, does not require Turkish court proceedings, and carries a genuinely effective enforcement tool — the transfer ban.

Unpaid Salaries in Turkish Volleyball: The Reality

Turkey's Sultans League and the TVF first division attract significant international talent each season. Many clubs operate on large budgets — but those budgets often depend on municipal funding, sponsorship cycles, or revenue streams that can prove volatile. When cash flow problems arise, foreign players' salaries are frequently the first casualty.

The typical pattern looks something like this: regular payments in the first months, then growing delays, then partial transfers accompanied by assurances — and eventually silence. Foreign players face several compounding difficulties in this situation:

  • Salary paid in a mix of cash, bank transfers, and different currencies, creating disputed payment records
  • Contract documents drafted in Turkish, which are unreadable to the player and inadmissible in international proceedings as-is
  • Club management changes mid-season, with new management discounting prior obligations
  • Unfamiliarity with Turkish courts, which operate in Turkish and follow proceedings that can span years

⚠️ Do Not Wait Too Long to Act

The strength of your claim depends heavily on the quality of evidence you can produce. Contracts, bank statements, payment receipts, email and WhatsApp correspondence with the club — all of these should be preserved carefully from the earliest stages of a dispute.

What Is the FIVB / CEV Financial Dispute Procedure?

The FIVB (Fédération Internationale de Volleyball) Financial Dispute Procedure is established under Article 18.1 of the FIVB Sports Regulations. It provides a binding resolution mechanism for financial disputes of international dimension between volleyball players, clubs, coaches, and licensed agents.

Since Turkey is a member of the CEV (Confédération Européenne de Volleyball), disputes involving Turkish clubs and foreign players fall under the jurisdiction of the CEV Legal Chamber, which exercises regional authority on behalf of the FIVB. The procedure is entirely written, operates in English or French, and typically does not require physical hearings.

ℹ️ Key Legal Principles Applied

Ex aequo et bono — Decisions are made on the basis of fairness and justice, without reference to any specific national law. The contract terms are central.

Pacta sunt servanda — Parties must honour the contracts they have signed. A club cannot simply elect not to pay.

Actori incumbit probatio — The burden of proof lies with the party making the claim or raising a defence. A club disputing a payment obligation must prove it.

Who Can File a Complaint? Key Requirements

To be eligible to file under Article 18.1, the following conditions must be met:

🏐 Eligible Parties Players, clubs, coaches, and FIVB-licensed agents may all bring complaints. The dispute must be international in nature — i.e., the parties must belong to different national federations.
📅 Season Threshold The dispute must have arisen during the 2012/13 season or later. For agent-related disputes, the relevant threshold is the 2014/15 season.
💶 Filing Fee CEV cases require a handling fee of EUR 400. FIVB direct filings require CHF 500. If the decision is in your favour, this fee is borne by the losing party.

Step-by-Step: Filing a Claim Against a Turkish Club

The procedure is entirely written and avoids the cost and delay of courtroom proceedings. Here is how it unfolds from complaint to decision:

1
Prepare Your File: Gather your contract, all payment records, bank statements, and all correspondence with the club. Everything must be submitted in English or French — or accompanied by a certified translation. The FIVB publishes an official complaint template.
2
Submit the Complaint and Pay the Fee: File your completed complaint with the CEV Legal Chamber, together with the EUR 400 handling fee.
3
Club Is Notified: The CEV informs the club of the complaint and invites a written response within a set deadline — typically around two weeks.
4
Exchange of Submissions: Both sides may file additional written submissions in response to each other's arguments. There are no oral hearings. The process is entirely document-based.
5
CEV Issues Its Decision: The CEV Legal Chamber reviews the full file and issues a binding written decision. A copy is sent to the Turkish Volleyball Federation and, if relevant, to the FIVB.
6
Right of Appeal: Either party may request review by the FIVB Tribunal within 14 days of notification of the decision.

⚠️ Critical Rule: Turkish-Language Documents Are Inadmissible

The CEV and FIVB work exclusively in English and French. Documents submitted in Turkish — including contracts, bank receipts, and club circulars — cannot be assessed by the CEV and will be disregarded entirely. This has proven to be a decisive factor: clubs relying on Turkish-only evidence have found themselves unable to substantiate their defences.

The Transfer Ban: The Real Enforcement Lever

The most powerful consequence of a CEV/FIVB decision is the transfer ban. If a club fails to comply with the decision within the set deadline — typically one month from notification — the CEV may refuse to approve the club's transfer requests for players from any other CEV member federation.

In practical terms, this means:

  • The club cannot sign any new foreign players from European federations — for any season until it complies.
  • Its competitive standing in European-level competition is directly at risk.
  • Its reputation among players, agents, and other clubs is permanently affected.
  • The CEV may additionally request that the FIVB extend the sanction to a worldwide transfer ban.

✅ In Practice: The Transfer Ban Brings Clubs to the Table

Once a decision is issued and the compliance deadline approaches, many clubs initiate contact to propose payment or a structured settlement. Any such offer must be carefully evaluated for its legal soundness before acceptance.

Enforcing the Decision in Turkey

A CEV/FIVB decision is a binding ruling within the international sports governance framework. It is transmitted directly to the Turkish Volleyball Federation (TVF), which — as a member federation subject to FIVB and CEV statutes — is institutionally obliged to recognise and act upon it.

Two Parallel Paths for Recovery

If a club refuses to comply even after a CEV decision, two channels can be pursued in parallel:

1 — Federation Channel

The CEV decision can be formally referred to the Turkish Volleyball Federation, requesting that administrative sanctions and transfer bans be imposed domestically. The TVF is bound by FIVB and CEV directives.

2 — Turkish Courts

Salary claims arising from international employment contracts can also be pursued independently before Turkish civil or labour courts. The existing CEV decision carries significant evidentiary weight in such proceedings.

Which channel to prioritise, and whether to use them simultaneously or sequentially, depends on the specific facts of the case: the club's financial position, the amounts at stake, and the urgency of recovery. This is precisely the kind of strategic analysis that experienced legal counsel can provide.

Why Legal Representation Matters

The FIVB/CEV procedure may be more accessible than national court litigation — but it is not a simple process. The quality of your submission directly affects the outcome. Key areas where legal support makes a difference:

  • Document language and translation: All evidence must be in English or French. Preparing an accurate and complete translated file is essential — and consequential if done poorly.
  • Managing the burden of proof: Demonstrating precisely which payments were made, which were not, and what the net outstanding balance is requires careful forensic analysis of often chaotic payment records.
  • Anticipating and countering club defences: Contract invalidity claims, inflated payment figures, bonus and flight ticket offsets — these are standard club tactics that must be addressed head-on.
  • Coordinating parallel legal strategies: Combining the federation route with Turkish court proceedings where appropriate, and timing each step correctly.
  • Evaluating settlement offers: Offers made by the club during or after proceedings must be assessed for legal enforceability before any acceptance.

✅ Take Action to Recover What You Are Owed

If your Turkish volleyball club has failed to pay your contractual salary, you have options — and they are more effective than most players realise. For a legal assessment of your situation and guidance on the FIVB/CEV procedure and Turkish enforcement options, contact Maya Law Firm →

Frequently Asked Questions

▶ Do I need to go to a Turkish court to recover my salary?

Not necessarily. The FIVB/CEV procedure operates independently of Turkish national courts. You can obtain a binding international decision without initiating Turkish court proceedings. If the club still refuses to pay after the CEV decision, Turkish courts may be needed as an additional enforcement route — but the federation sanction mechanism is often sufficient pressure on its own.

▶ The club is claiming the contract was never valid. Can they use this to avoid paying?

This defence is common — and often fails. The burden of proof lies with the club to substantiate the invalidity claim. If the club made partial payments under the same contract, that conduct directly contradicts its invalidity argument. CEV decision-makers have consistently noted such internal contradictions and ruled against clubs raising them.

▶ How long does the FIVB/CEV process take from complaint to decision?

The timeline varies depending on how quickly both parties complete their submissions and the complexity of the file. In general, expect a range of several months to approximately one year. A well-prepared, complete initial submission tends to reduce delays significantly.

▶ What if the club ignores the CEV decision entirely?

If the club fails to comply within the set deadline, the CEV may block all of the club's transfer requests from other CEV-member federations — effectively preventing it from recruiting any foreign players. The CEV may also request the FIVB to extend this sanction globally. These are consequences that most professional clubs cannot afford to ignore.

The information provided in this article is for general informational purposes only and does not constitute legal advice or establish an attorney-client relationship. Each case must be assessed on its own specific facts and circumstances. Please consult a qualified attorney before taking any legal action.

Illustrative CEV Decision

FIVB Financial Dispute Procedure — CC353/2024 | 30 July 2025

Reference: FIVB Financial Dispute Procedure — CC353/...
Decision of 30 July 2025
In the matter of ....... versus ......BELEDİYESİ SPOR KULÜBÜ

1. Summary of the dispute

a) On 01 September 2023, the Russian player I... S.... ("Player" and Claimant) and the Turkish club ..... BELEDİYESİ SPOR KULÜBÜ (9728 + NF-TUR) ("Club" and Respondent) signed an agreement ("Contract") under which the Player agreed to play for the Club's team for the 2023–2024 season. In return, the Club agreed to pay the Player a total compensation of EUR 100,000 net. The term of the Contract ran from 1 September 2023 until 31st of May 2024.

b) The Player alleges that she did not receive the salaries she was entitled according to the Contract. c) The present dispute revolves around the question whether the Player received the salaries she was entitled according to the Contract.

2. Proceedings

a) On 12 August 2024 and 14 August 2024, the Claimant filed a Complaint with the CEV and paid the requested handling fee of EUR 400. b) On 21 August 2024, the CEV informed the Respondent of the Complaint and invited reply by 04 September 2024. c) On 4 September 2024, the Respondent filed its reply. d) On 11 September 2024, the CEV forwarded the reply to the Claimant, inviting a response by 18 September 2024. e) On 16 September 2024, the Claimant filed a second submission. f) On 20 September 2024, the CEV forwarded it to the Respondent, inviting reply by 27 September 2024. g) On 24 September 2024, the Respondent filed a second and final submission. h) On 10 July 2025, the CEV requested a translation of the Contract in English or French, which was provided by the Claimant on 11 July 2025.

4.1 Competence

This case involves a Russian Player who filed a complaint with the CEV against a Turkish Club, requesting payment of outstanding salaries. Given that this is a financial dispute of international dimension between a player and a club coming from different National Federations which are members of the CEV, the criteria set out in Article 18.1.b. of the FIVB Sports Regulations are met and the CEV is competent to issue a decision in this matter.

4.2 In fact — Key findings

The Club claimed two reasons to withhold the Player's outstanding salaries: (1) that the Contract is invalid for lack of joint signatures, and (2) that payments made totalled EUR 65,183. The CEV noted that the Club's exhibits were entirely in Turkish. As the working languages of the CEV and FIVB are English and French only, these Turkish-language documents could not be assessed for their probative value. As a result, the Club's exhibits were disregarded entirely.

The CEV further noted that the Club contradicted itself: on one hand claiming the Contract was invalid, while on the other hand having made payments under it. If the Contract were invalid, no payment obligation would have existed.

4.3 In law

In accordance with Article 18.1.e of the FIVB Sports Regulations, the decision was taken on a balance of probabilities by applying general principles of justice and fairness without reference to any particular national or international law (ex aequo et bono). The CEV underlined the importance of the principle of pacta sunt servanda. The Club failed to discharge its burden of proof (actori incumbit probatio) with respect to its claims. Hence, the Club had no right to unilaterally withhold the Player's salaries. The Club must pay the Player EUR 60,000 net as outstanding salaries.

5. Decision

• .............  BELEDİYESİ SPOR KULÜBÜ shall pay EUR 60,000 net to Iaroslava SIMONENKO as outstanding salaries.
• .............BELEDİYESİ SPOR KULÜBÜ shall pay EUR 400 to ............. as reimbursement of the handling fee.
• .............BELEDİYESİ SPOR KULÜBÜ shall comply with this decision within one month from notification.
• Beyond this delay, the CEV may not approve transfers of players from CEV National Federations to .............BELEDİYESİ SPOR KULÜBÜ unless adequate proof of full compliance is provided. Additional sanctions may be imposed.
• A copy of this decision is sent to the FIVB and the Turkish Volleyball Federation for their information.
• The CEV may, at a later stage, request the FIVB to extend a possible sanction worldwide.
• Within 14 days from notification, the affected parties may request review by the FIVB Tribunal.

Dragan  — CEV Legal Chamber, 30 July 2025

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