Legal and Financial Aftermath of the Manchester City Decision

gunnercooke Sport

This piece was written by Steve Kavanagh, Head of gunnercookeSport, Julian Pike, Reputation Management/Sport Partner, and Khaled Moyeed, Dispute Resolution Partner.

On 29 September 2026, the Premier League published the Disciplinary Commission’s decision against Manchester City (“City”). The Commission found City liable on 114 of 115 charges spanning nine seasons and found that evidence given by several City’s own witnesses was not just false but, in some instances, knowingly dishonest. On 1 October 2026, City lodged its appeal against the Decision. Clearly the next phase is the appeal but if City are unsuccessful, although they strongly deny all charges, then matters turn to what happens next: the sanction hearing, the regulatory fallout, and the compensation claims other clubs could potentially consider advancing.

Sanctions, Appeal Timing and Regulatory Exposure

Sanctions are being dealt with under Premier League Rule W.64, which allows a combination of penalties, ranging from a reprimand, a fine or a points deduction, through to suspension, player-registration restrictions; the Commission can even recommend expulsion from the League. They have made it clear a separate sanction hearing will be held to consider and determine sanctions. This is unlikely to take place before the appeal.

Beyond sporting penalties, the findings have wider consequences. The Commission found that City’s accounts for nine seasons (2009/10 to 2017/18) did not give a true and fair view of its financial position for financial fair play purposes.

One strand of the Commission’s findings concerns an arrangement with a company called Fordham. The Commission found this was, in substance, a front for City’s owner, Abu Dhabi United Group (ADUG). ADUG money was used to let Fordham buy, at a sizeable, artificially inflated price, City’s entitlement to benefit financially from its players’ image rights; Fordham then itself took on City’s image-rights payment obligations to those players, which were really City’s liabilities. The effect the Commission found was to let City book ADUG’s money as commercial income and keep City’s own costs off its books, rather than recording its true position.

It is separate from another scheme the Commission examined, under which it is understood that around £8.9m of the manager’s pay over four seasons (2009-13) was routed through a consultancy arrangement so that what was, in reality, a City liability, did not appear in the club’s accounts. These findings matter beyond football because they go to how City’s finances were reported. The first consequence is whether authorities such as HMRC will seek involvement: Treasury Committee Chair, Dame Meg Hillier, has written to HMRC’s permanent secretary, asking whether HMRC has received an unredacted version of the Commission’s report, requesting an overview of HMRC’s current work on football clubs, and seeking reassurance that HMRC is alive to the issues and the public interest in the case. The letter raises the question of whether City’s accounts also understated its tax position.

The Appeal

The appeal will be heard by a three-member Appeal Board, appointed under the Premier League’s Judicial Panel Rules, and chaired by a member who has held judicial office. An appeal must be filed within 14 days of the decision; City’s appeal, lodged on 1 October 2026, fell within that window. The standard directions provide for a hearing to be concluded within 12 weeks of filing, lasting no more than five days, with a reasoned decision within 30 days of its end, although these can be varied or disapplied. That fast-track timetable was only recently introduced, however, and City is reportedly expected to argue that it should not apply to a case charged in 2023 and heard in 2024, before the new rules took effect. If that argument succeeds, the appeal could run well beyond 12 weeks. Overturning findings of fact may well be difficult; City’s more realistic targets are errors of law, procedural unfairness, or irrationality.

It is considered that City’s grounds are most likely to focus on whether the Commission properly applied the ‘strong, cogent evidence’ standard required for allegations of serious dishonesty, and whether it was right to find City’s witnesses unreliable and draw conclusions against the club. Outside the Premier League process, City’s only route is a challenge in the High Court under sections 67 (jurisdiction) and 68 (serious irregularity) of the Arbitration Act 1996. Both set a high bar.

Compensation Claims from Rival Clubs

Rival clubs are understood to be considering seeking compensation through the Premier League’s own procedures rather than the courts. The likely template for these claims is the Burnley v Everton case, where an independent commission found that Everton’s overspending had cost Burnley their place in the Premier League, and ordered Everton to pay Burnley £35m after Burnley argued that Everton’s spending breaches cost Burnley a fair chance of avoiding relegation. The Premier League Rules operate as a binding contract between member clubs, and Rule W.64.5 allows the Commission to order a club in breach to pay compensation to other clubs.

The case is clearly significant when examining any compensation claims from rival clubs given the tribunal accepted statistical modelling estimating what the rule-breaking club would likely have achieved had it stayed within the rules and compared that to what actually happened. Everton is appealing to that decision, so the method itself is not yet settled. Assuming City’s Appeal is unsuccessful, its most likely defence will be less about whether a breach occurred and more about the same contested ground as Burnley: what a compliant City would have spent and achieved, and what they would have meant in terms of league placing relative to the club claiming compensation.

The clearest head of loss is lost Champions League qualification and the prize money that comes with it, although City’s fifth-place finish   in 2009/10 season did not earn Champions League qualification. City’s breaches are found to run through multiple seasons, and for simplicity we assume that in each of those seasons, where City qualified for the Champions League, only one club could have taken the Champions League place City held if City had complied with the rules; in practice, which specific rival would have taken that place, and what points swing is attributable to the breach, is itself likely to be contested, much as it was in Burnley v Everton. On that assumption, this is not a claim that several clubs missed out in the same season; at most, one rival per season has a claim to that place.

However, the degree of complication in the calculation is evident from examining the gap between City and the fifth placed side. In 2010/11, City was third with 71 points, with Tottenham in fifth nine points behind on 62. In the 2012/13 season the gap between City (in second place) and Spurs in fifth was only six points. Tottenham are understood to be one of the teams to have issued a protective claim but would the modelling support claims in respect of both seasons or only the 2012/13 season? The 2015/16 season saw City level on points with Manchester United in fifth place, but with a better goal difference. The following season, Arsenal took fifth spot, merely three points behind City in third.

By contrast, in 2011/12, City finished first with 89 points, while the fifth placed side, Newcastle, only secured 65 points. In 2017/18, City finished first with 100 points, some 30 points ahead of Chelsea in fifth. It’s not thought either Chelsea or Newcastle have issued a claim.

The direct value of moving up one league position in a given season was modest on its own, estimated at roughly £755,000 to just around £1.9 million depending on the season, but Champions League qualification carries much larger broadcasting and prize money on top, which is why the clubs affected are considering pursuing claims. Modelling such claims would be complex, although eminently possible. We have not therefore advanced such figures, but such claims would be substantial and will vary from club to club.

Claimants will rely on section 32(1)(b) of the Limitation Act 1980, which postpones the usual six-year limit to bring a claim if the defendant has deliberately concealed any fact relevant to the claimant’s right of action. City is likely to argue that the clock started when Der Spiegel published its Football Leaks articles in early November 2018. This risk is reportedly why Arsenal, Liverpool, Manchester United, and Tottenham filed protective notices in November 2024, although Liverpool never finished fifth in any of the relevant seasons.

The appeal and sanctions hearings are likely to take months, and compensation claims years. Every claim depends on the Decision surviving City’s appeal. Beyond City, the case is a test of whether football’s financial rules can be enforced against its wealthiest clubs, and the compensation mechanism now most likely to be relied on by rival clubs may prove as significant a deterrence as the sanction itself, although that somewhat depends on the sanction(s) imposed.

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