Can a player based abroad escape an exclusive mandate by invoking the rules of the federation of the country where he plays? In a judgment of 15 September 2026, the Paris Judicial Court rejects this argument.
An agent licensed by the FFF had entered into an exclusive two-year mandate, governed by French law, with a player who was then under contract in the Belgian top division, in 2021. Less than four months later, the player terminated it. He relied on a provision of the Belgian federation's regulations allowing a player to terminate his representation contract at any time.
The court applies Article 3 of the Rome I Regulation: the contract is governed by the chosen law. It dismisses the exception based on Belgian mandatory rules. The agent had performed no placement services in Wallonia, since the mandate was signed after the player had been recruited by his Belgian club, and he had not negotiated with any other Belgian club. The Belgian federation's regulations therefore could not govern the relationship between the parties. Indeed, the court accepts that registration in Wallonia is required of an agent who operates there or who negotiates with a Belgian club.
The mandate, stipulated as being in the common interest and exclusive, could be terminated only by agreement of the parties, for serious misconduct or in the event of force majeure. The termination letter cited no grievance, and the prior formal notice required by the contract was missing. The player is therefore liable for the consequences of the termination.
The agent claimed 10% of the player's gross earnings over the five seasons of his new contract, i.e. €600,000 calculated on an average Ligue 1 salary. The court refused to reason on average salaries and recognised only a loss of opportunity, as the agent had received no offer from the club the player eventually joined. It stayed the ruling on the amount, ordered the player to produce his employment contract and payslips, and referred the case to a pre-trial management hearing of 30 November 2026.
Source : Paris Judicial Court, 5th Chamber, 1st Section, 15 September 2026, RG No. 24/00593
