Manchester City’s conviction marks an unprecedented moment for English football, but the immediate consequences remain uncertain. With sanctions still to be determined, and an appeal confirmed, the decision may also expose the club to wider legal and commercial claims.
The decision
After one of the most closely watched disciplinary proceedings in British sport history, Manchester City F.C. have been found guilty of all charges relating to serious breaches of the Premier League’s financial rules brought by the Premier League.
The charges relate to alleged breaches across a 9-year period, from 2009 to 2018, and broadly concern the accuracy of financial information provided by Manchester City, compliance with the Premier League’s Profitability and Sustainability Rules (PSR), and the club’s cooperation with the Premier League’s investigation, which opened in December 2018.
In its recently released, heavily redacted, decision, the independent Disciplinary Commission found that Manchester City had used “sham” commercial arrangements through which the club had allegedly overstated its revenue by more than £900 million. The Commission also concluded that Manchester City had “clearly intended to circumvent the PL Rules” and had made “concerted efforts to stop and frustrate” the Premier League’s investigation.
Manchester City have strongly denied the charges and maintain that they possess evidence demonstrating that the deals were genuine. The club has confirmed that it will appeal, alleging that the Commission’s findings involved material errors “of law, principle and fact”.
What could the sanctions be?
The scale and nature of the breaches are unprecedented, making the likely sanctions difficult to predict. The closest recent comparator is Everton F.C., who in 2023 received a 10-point deduction for exceeding the PSR limit by £20 million over a 3-year period; that deduction was reduced to 6 points on appeal. Although the cases differ materially, Everton provides the clearest recent indication of how a points deduction may be approached. Manchester City’s case is therefore a defining moment for the Premier League, both because of the seriousness of the findings and because the eventual sanction is likely to influence the treatment of future breaches.
No punishment has yet been determined, and a separate hearing will be scheduled. The Commission may impose one or more of the following sanctions:
- Financial penalties – a substantial fine payable to the Premier League.
- Transfer bans – restrictions on being able to register new players for a specified period.
- Points deduction – an immediate or delayed points deduction, which if substantial could lead to their relegation.
- Removal from the Premier League – the most severe outcome, which raises questions on how this would be fairly implemented and whether lower divisions would accept Manchester City in their division.
While the Commission’s powers are not limited to the above, it is expected that, if action is taken, it would resemble one of the above scenarios. The impact of any sanction would not be strictly confined to Manchester City, with a substantial points deduction or their removal from the League, for example, likely having far-reaching consequences for the entire football league, affecting clubs competing for the Premier League title, European qualification, Premier League survival, and promotion from the Championship.
The Premier League is also facing external pressure from parties with significant interests in the outcome. Reports have suggested that officials from the United Arab Emirates, the home country of Manchester City owner Sheikh Mansour, threatened to withdraw billions of pounds of investment from the UK depending on the findings. Executives at other clubs have reportedly described City’s expulsion as “commercial suicide” for the Premier League.
The English Football League has reportedly indicated that it would support the Premier League’s decision. Depending on the sanction imposed and the approach taken by the relevant competitions, Manchester City could therefore face consequences extending beyond the Premier League.
Will there be any spillover?
The consequences for Manchester City may extend well beyond immediate sanctions. The final outcome could instead pave the way for follow-on litigation by current and former Premier League clubs, players, and managers seeking compensation for losses allegedly caused by Manchester City’s breaches of the rules. Only time will tell how far such claims would develop.
Any action would, however, face significant evidential hurdles and require considerably more than establishing that Manchester City breached the rules. A claim would need to establish a causal connection between those breaches and the loss suffered (for instance, a club’s loss of revenue in failing to qualify for the Champions League), which would likely be broadly based on the argument that the claimant would have been more successful but for Manchester City’s breaches of the Premier League’s financial rules.
Although it remains uncertain whether other clubs would pursue complex and costly claims, the prospect is not merely theoretical. A handful of clubs have already formally reserved their rights to seek compensation from Manchester City if the charges are upheld following any appeal.
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