Guilty, Not Yet Punished, And Appealing: Where the Manchester City Case Goes From Here

After eight years of investigation and a 42-day hearing, the Premier League finally has its answer. On 29 September, the league confirmed that an independent Commission had found Manchester City guilty of every charge relating to breaches of its financial rules between the 2009/10 and 2017/18 seasons, and three of the four alleged breaches of its duty to cooperate with the investigation.[1] Chief executive Richard Masters called the case "the most significant in Premier League history."[2] Within three days, City had appealed, insisting "the Club is innocent of the accusations made by the Premier League."[3] Beneath the ‘115 charges’ headline sits the more interesting legal questions of why the league succeeded where UEFA failed, and what happens next.

The Findings

The Commission found that City used "sham" contracts, where sponsors paid only part of their stated fees, with the balance covered by the owner’s investment fund Abu Dhabi United Group. A similar owner-funded arrangement with Fordham, an entity that bought players' image rights, let the club understate its expenses.[4] Together, the schemes inflated revenues and reduced costs by more than £900 million (roughly A$1.7 billion), including around £830 million of the owners' own money dressed up as sponsorship.[5]

The Commission was also critical of City's conduct during the investigation, finding the club "made concerted efforts to stop and frustrate the PL investigation"[6] and rejecting one explanation as "concocted well after the event."[7] These findings of deliberate concealment and non-cooperation are classic aggravating factors, and will no doubt follow City into the sanctions hearing. City deny all wrongdoing, and the findings are subject to appeal.

Why the Premier League Won While UEFA Lost

In 2020, UEFA banned City from European competition for two seasons and fined it €30 million. The Court of Arbitration for Sport overturned the ban, finding most alleged breaches "were either not established or time barred", and cut the fine to €10 million.[8]

The difference is largely procedural. UEFA's rules impose a five-year limitation period on financial breaches while Premier League rules have none.[9] That let the league reach back to 2009, into seasons off-limits to UEFA. Both cases drew on the same internal City emails, obtained by hacker Rui Pinto and published by Der Spiegel in 2018.[10] It was timing that proved decisive in these cases producing opposite outcomes.

Where to From Here

City lodged their appeal on 1 October, arguing the decision "contains clear material errors, of law, principle and fact, and is unsafe."[11] This time, the process is on the clock. Under rules introduced this season, an appeal must be heard within 12 weeks, in a single block of no more than five days, with a decision due within 30 days of the hearing ending. City cannot introduce new evidence or call witnesses.[12] Overturning findings of fact made after a 42-day hearing on the papers alone is a tough ask, and most legal commentators expect the appeal to fail.[13]

That may not be the end. If City lose, they are expected to go to the High Court and argue the process was unfair.[14] Because Premier League disciplinary proceedings are decided by private arbitration rather than in court, the likely avenue is a "serious irregularity" challenge. This is under section 68 of the Arbitration Act 1996 (UK), a notoriously narrow ground requiring substantial injustice, not merely a wrong answer.[15] The court will not revisit whether the Commission got the facts or the law wrong. Therefore, City would need to show a serious procedural failure that caused substantial injustice, a threshold the House of Lords has reserved for "extreme cases".[16]

What Punishment Looks Like

City have not yet been punished. Sanction will be decided at a separate, private hearing before the original panel, which can run alongside the appeal.[17] The rules set no standard penalty. The Commission's powers range from fines and points deductions to registration bans and a recommendation of expulsion.[18]

The recent benchmarks look modest by comparison. In 2023/24, Everton lost eight points across two deductions and Nottingham Forest lost four for profitability and sustainability breaches.[19] City's breaches span nine seasons and involve sham contracts and deliberate concealment. The sanction is therefore likely to be considerably heavier.

Other sports offer a guide to what that could look like. In 2010, the NRL stripped the Melbourne Storm of their 2007 and 2009 premierships, removed all their competition points for the season and imposed a A$1.6 million penalty after finding the club had run a dual-contract system to breach the salary cap by at least A$1.7 million over five years.[20] A decade later, rugby union's Saracens were deducted 35 points, fined £5.3 million and ultimately relegated for repeated salary cap breaches.[21] 

Both cases involved deliberate concealment across multiple seasons, the same features the Commission found here. A substantial points deduction looks likely, and the stripping of titles can no longer be dismissed as out of the question. However, Everton's case offers a caution. Its 10-point deduction was cut to six on appeal after the original commission was found to have erred,[22] a reminder that any sanction will itself be fiercely contested.

How the Fans Are Taking It

For City supporters, like MSLA’s very own James Forrester, the verdict lands awkwardly. The trophies of the last decade are real memories, and it was ultimately the players on the pitch who delivered them. But the finances that assembled those players have now been found to be built partly on fiction. How does a fan reconcile these two realities?

The question reaches Australia too. Melbourne City has been owned by City Football Group since 2014, and its vice-chairman Simon Pearce sits on Manchester City's board.[23] There is no suggestion of any wrongdoing at Melbourne City.

Ultimately...

The Commission has answered whether City broke the rules, but not what that means. Masters says the decision "vindicates" the league's choice to pursue the case.[24] Real vindication, though, may depend on the sanction. If the punishment fits the findings, the Premier League's financial rules will mean something. If not, the lesson for any club with deep enough pockets is that breaking the rules, and fighting the charges for the best part of a decade, is simply a cost of doing business.

References

 

[1] 'Premier League Statement: Manchester City FC', Premier League (online, 29 September 2026) https://www.premierleague.com/en/news/4727779/premier-league-statement-manchester-city-fc.

[2] Ibid [1].

[3] ''Club Is Innocent': Manchester City Vow to Appeal Premier League Verdict', Khaleej Times (online, 29 September 2026) https://www.khaleejtimes.com/sports/football/manchester-city-to-appeal-premier-league-verdict.

[4] Ibid [1].

[5] Kaveh Solhekol, 'Man City Charges: UEFA Monitoring Premier League Club's Case as It Considers Potential Action', Sky Sports (online, 6 October 2026) https://www.skysports.com/football/news/13595795/man-city-charges-uefa-monitoring-premier-league-clubs-case-as-it-considers-potential-action.

[6] Ibid [1].

[7] Ibid [5].

[8] Ibid [5].

[9] Ibid [5].

[10] Kaveh Solhekol, 'Man City Premier League Charges Explained: What Are They? What Could Punishment Be? What Happens Next?', Sky Sports (online, 26 September 2026) https://www.skysports.com/football/news/13591837/man-city-premier-league-charges-explained-what-are-they-what-could-punishment-be-what-happens-next.

[11] Ibid [3].

[12] Kaveh Solhekol, 'Manchester City Charges: Latest on Sanctions Hearing and Appeal Against Guilty Verdict', Sky Sports (online, 12 October 2026) https://www.skysports.com/football/news/13598124/manchester-city-charges-latest-on-sanctions-hearing-and-appeal-against-guilty-verdict.

[13] Ibid [12].

[14] Ibid [12].

[15] Arbitration Act 1996 (UK) s 68 https://www.legislation.gov.uk/ukpga/1996/23/section/68.

[16] Lesotho Highlands Development Authority v Impregilo SpA [2005] UKHL 43.

[17] Ibid [12].

[18] Ibid [10].

[19] Ibid [10].

[20] ‘Melb Storm Stripped of Titles as NRL Vows Clean Up’, SBS News (online, 22 April 2010) https://www.sbs.com.au/news/article/melb-storm-stripped-of-titles-as-nrl-vows-clean-up/8k092gtmc.

[21] 'On This Day in 2020: Saracens Relegated from the Premiership', RugbyPass (online, 18 January 2023) https://www.rugbypass.com/news/on-this-day-in-2020-saracens-relegated-from-the-premiership/.

[22] Ross McLeish, 'Why Everton Point Deduction Has Been Reduced and What It Means for Premier League', The Scotsman (online, 26 February 2024) https://www.scotsman.com/sport/football/everton/why-everton-point-deduction-has-been-reduced-and-what-it-means-for-premier-league-4533512.

[23] Joanna Guelas, ''Doesn't Concern Us': A-Leagues on Man City Scandal', The Canberra Times (online, 30 September 2026) https://www.canberratimes.com.au/story/9360094/doesnt-concern-us-a-leagues-on-man-city-scandal/.

[24] Ibid [1].

Photo by Jonny Gios on Unsplash

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