The Analysis Series: Manchester City v The Premier League: The “115 Charges” case

The case:

In February 2023, after a four-year investigation triggered by Der Spiegel’s November 2018 Football Leaks publications, the Premier League formally referred Manchester City to an independent commission alleging breaches of its financial rules across 115 numbered allegations (in five categories, with the actual underlying rule-breach count widely reported as approximately 129–130).

The charges cover seasons 2009/10 to 2017/18 for the substantive offences and December 2018 to February 2023 for failure to cooperate.

A 12-week confidential hearing ran at the International Dispute Resolution Centre in London from 16 September to 6 December 2024 before a three-person commission appointed by Murray Rosen KC.

As of 30 April 2026,  more than 16 months after closing arguments,  no verdict has been published; legal commentators expect a liability judgment imminently (i.e. before the 2026 World Cup in June), with any sanctions phase, appeal and damages claims likely to extend resolution well into the 2026/27 season.

The substance:

The Premier League alleges City inflated revenues by disguising owner equity from Abu Dhabi United Group (ADUG) as third-party sponsorship payments (Etihad, Etisalat, Aabar, ADTCA), concealed manager remuneration via a parallel Al Jazira consultancy contract for Roberto Mancini, mis-stated player image-rights and salary information, breached UEFA FFP and the Premier League’s PSR, and obstructed the Premier League’s investigation.

Manchester City, represented by Lord Pannick KC and instructing solicitors Freshfields, with Paul Harris KC of Monckton Chambers (the architect of the 2020 CAS victory) as advisor, denies every charge and has secured significant collateral wins, notably the September 2024/February 2025 ruling that the Premier League’s 2021–24 Associated Party Transaction (APT) Rules were unlawful and unenforceable in their entirety, and the September 2025 APT settlement. 

The stakes and likely outcome:

Sanctions available range from reprimand and unlimited fine to points deductions, title-stripping, transfer/registration bans and expulsion. Most football-finance commentators anticipate a partial finding rather than total acquittal or expulsion, most likely a substantial points deduction (estimates as high as 40–60-point figure if all the most serious charges are upheld, scaled by reference to Everton’s 6+2 and Forest’s 4-point precedents) plus a major fine, with City almost certain to appeal.

A complete acquittal is also a real possibility because the case rests heavily on hacked Football Leaks emails of disputed authenticity/context, much of the conduct overlaps with material that CAS in 2020 found not established or time-barred under UEFA rules, and Lord Pannick has used the same dismantling strategy that defeated UEFA. The Independent Football Regulator,  established by the Football Governance Act 2025, has no jurisdiction over the present charges, but the case has become Exhibit A in the policy argument for statutory regulation.

Charges: Complete Catalogue

Premier League’s formal charge sheet (6 February 2023)

The Premier League’s statement was issued under Rule W.82.1 and referred the case to a commission under Rule W.3.4.

It listed five numbered groups of alleged rule breaches. The “115” figure derives from counting individual season-rule combinations in the original document; multiple sports lawyers note that the underlying total of distinct rule breaches is approximately 129–130, with figures up to 134 in some breakdowns.

Group 1: Failure to provide accurate financial information (Seasons 2009/10–2017/18; 54 alleged breaches)

Rule provisions invoked, season by season:

2009/10: B.13, C.71, C.72, C.75 (later C.79), C.80

2010/11: B.13, C.78, C.79, C.86, C.87

2011/12: B.13, C.78, C.79, C.86, C.87

2012/13: B.16, E.3, E.4, E.11, E.12

2013/14: B.15, E.3, E.4, E.11, E.12, E.49

2014/15: B.16, E.3, E.4, E.11, E.12, E.50

2015/16: B.16, E.3, E.4, E.11, E.12, E.50

2016/17: B.16, E.3, E.4, E.11, E.12, E.51

2017/18: B.16, E.3, E.4, E.11, E.12, E.51

Each requires the club to provide, in utmost good faith, accurate financial information that gives a true and fair view of the club’s financial position, in particular with respect to its revenue (including sponsorship revenue), its related parties and its operating costs.

Group 2: Failure to disclose full details of manager and player remuneration (14 alleged breaches)

Manager remuneration, 2009/10–2012/13: Rules Q.7, Q.8 (then P.7, P.8 from 2012/13)

Player remuneration, 2010/11–2015/16: Rules K.12, K.20 (later T.12, T.19/T.20 and T.13/T.20)

Group 3: Failure to comply with UEFA regulations including UEFA Club Licensing & Financial Fair Play Regulations, 2013/14–2017/18 (5 alleged breaches)

Rule B.14.6 (2013/14); Rule B.15.6 (2014/15–2017/18).

Group 4: Failure to comply with the Premier League’s own Profitability and Sustainability Rules, 2015/16–2017/18 (7 alleged breaches)

2015/16: Rules E.52 to E.60

2016/17 and 2017/18: Rules E.53 to E.60

Group 5: Failure to cooperate with the Premier League’s investigation, December 2018 – February 2023 (35 alleged breaches)

Each season from 2018/19 to 2022/23: B.15/B.16, B.18/B.19, W.1, W.2, W.12, W.13 (latterly W.15, W.16),  requirements to cooperate, assist and provide documents in utmost good faith

What the Premier League alleges City actually did

The conduct alleged, drawing together the formal rules and the underlying Football Leaks evidence reviewed by both UEFA’s CFCB and the Premier League:

• Disguised equity as sponsorship. Owner funds from ADUG were channeled through Abu Dhabi state-linked sponsors so they appeared as commercial revenue in City’s audited accounts. Specific allegations include:
• Etihad Airways,  only £8 million of the 2015 £67.5 million headline figure said to have been provided directly by Etihad, with the remaining £59.5 million sourced from ADUG and routed through the airline (Der Spiegel, November 2018).
• Etisalat,  payments of £30 million identified in a 2020 UEFA report as having originated from Jaber Mohamed,  described as a UAE financial broker, and re-papered as Etisalat sponsorship contributions.
• Aabar Investments and Abu Dhabi Tourist Authority (ADTCA),  similar conduits.
• Concealed manager remuneration. Roberto Mancini’s £1.45 million City salary (2009–2013) was supplemented by a £1.75 million per-year consultancy with Abu Dhabi club Al Jazira, also owned by Sheikh Mansour, requiring only four days’ service per year. Invoices issued by Mancini’s company , Italy International Services, were paid by City, then reimbursed by ADUG which forwarded the funds to Al Jazira to pay Mancini,  making it, the Premier League contends, undisclosed City remuneration.
• Concealed player payments / image-rights structures. Allegations relate to image-rights agreements (notably involving Yaya Touré’s representatives) and use of Manchester City Football Club (Image Rights) Ltd, set up in October 2012, allegedly to deliver remuneration outside the Rule K/T disclosure regime.
• Obstruction of the Premier League’s investigation, refusal to provide originals of leaked emails, disputing the scope of disclosure orders, and bringing repeated procedural challenges (see Section 4).

Connection to the UEFA/CAS case

The Football Leaks dump triggered both the UEFA investigation (March 2019 onwards) and the Premier League’s own investigation (opened 19 December 2018, announced March 2019).

On 14 February 2020, UEFA’s Club Financial Control Body (CFCB) banned City from European competition for two seasons and fined them €30 million for serious breaches between 2012 and 2016, overstating Etihad sponsorship revenue, and failing to cooperate. On 13 July 2020, the Court of Arbitration for Sport (CAS 2020/A/6785) overturned the ban and reduced the fine to €10 million. The full 93-page reasoning (28 July 2020) found:

• Etisalat-related charges (June 2012 / January 2013 payments) were time-barred under UEFA’s five-year statute of limitations;
• Etihad-related allegations were not established to the comfortable-satisfaction standard, with the panel concluding UEFA had not shown the payments constituted disguised equity;
• Leaked emails were admissible as evidence;
• City had nevertheless committed a severe breach of Article 56 of UEFA’s regulations by failing to cooperate, justifying the residual €10 million fine.

Crucially, the Premier League rule book contains no statute of limitations equivalent to UEFA’s.

The Premier League’s case therefore covers a longer period (2009–2018), is not constrained by the time-bar that negated UEFA’s prosecution, and is governed by English contract law and arbitration principles rather than Swiss-law sports arbitration.

Some of the same conduct (Etihad/Etisalat sponsorship) is therefore being re-litigated, but on different evidentiary and procedural footing.

Manchester City’s defence

Since 6 February 2023 the club’s stated position has been unchanged:

“Manchester City FC is surprised by the issuing of these alleged breaches of the Premier League Rules, particularly given the extensive engagement and vast amount of detailed materials that the EPL has been provided with. The Club welcomes the review of this matter by an independent Commission, to impartially consider the comprehensive body of irrefutable evidence that exists in support of its position. As such we look forward to this matter being put to rest once and for all.”

Pep Guardiola, on the day charges were announced, said he was “fully convinced” of City’s innocence and that the club had been “sentenced already” by the media. He has repeatedly emphasised the panel’s independent status and said City will accept the outcome. CEO Ferran Soriano and General Counsel Simon Cliff have spoken publicly only sparingly.

Legal team and strategy

• Lead counsel: Lord David Pannick KC (Blackstone Chambers): The same barrister who acted for Boris Johnson in the prorogation case (R (Miller) v The Prime Minister) and ‘Partygate’. Reputedly an Arsenal supporter.
• Specialist sports/EU competition counsel: Paul Harris KC (Monckton Chambers): Leader of City’s successful CAS appeal in 2020, has been an advisor for nearly 20 years.
• Solicitors: Freshfields Bruckhaus Deringer LLP (also instructed in the parallel APT challenge in 2024).
• Premier League counsel: Adam Lewis KC and Daniel Hunter (Blackstone Chambers); solicitors Bird & Bird, supported by Slaughter and May in the APT proceedings.

The strategy mirrors the 2020 CAS playbook, identified by European Business Magazine and the Lawyer as targeted legal deconstruction: rather than blanket denial, identify specific procedural, evidentiary and competition-law weaknesses in the Premier League’s case and dismantle them piece by piece.

Key defence arguments

• Evidence integrity. City have argued throughout that the Football Leaks emails were stolen by Rui Pinto (later given a four-year suspended sentence in Lisbon in September 2023, upheld by the Lisbon Court of Appeal in January 2025), are partial (City say 5.5 million emails were stolen but only six form the core of UEFA’s case), de-contextualised, and in some instances reflect proposals never implemented rather than executed transactions. Authenticity has not been denied, but reliance on fragments is challenged
• CAS findings as persuasive authority. While the 2020 CAS award is not formally binding on the Premier League panel, City argue many factual matters (Etihad/Etisalat) were already adjudicated and held not established.
• Audit trail. City emphasise their accounts were independently audited (originally by BDO, latterly by PwC), and that the financial statements presented a true and fair view.
• Mancini consultancy was genuine. City contends the Al Jazira contract reflected real services owed to a separately-owned Abu Dhabi entity; that quarter of the funds may have been netted against ADUG payments does not, on the club’s case, demonstrate the City-administered payment was salary in disguise.
• Competition law / regulatory unfairness. City have launched parallel competition-law challenges to the Premier League’s own rules,  most notably the Associated Party Transaction (APT) arbitration under Premier League Rule X. In the First Decision (September 2024) the tribunal found three discrete elements of the 2021–24 APT Rules unlawful (procedural unfairness, exclusion of shareholder loans from FMV assessment, and abuse of dominance under the Competition Act 1998). In the Second Decision (February 2025) it ruled those elements were not severable, rendering the APT Rules void and unenforceable in their entirety for that period (analysis: Morgan Sports Law). City has used these findings to argue that if Premier League rules of the same family are competition-law-defective, large parts of the underlying complaint may collapse. The dispute over the post-November 2024 amended rules was settled on 8 September 2025, with City accepting the validity of the new rules but securing a path for new Etihad / First Abu Dhabi Bank deals.
• Procedural challenges. In 2021 City unsuccessfully sought to keep the very existence of the Premier League’s investigation confidential; the High Court (and subsequently the Court of Appeal) ruled against them, which is how the public first learned of the investigation. The arbitration over disclosure of internal emails is the foundational procedural fight.
• Rule of comity / consistency. City note the Premier League’s own willingness to settle (Chelsea, March 2025) and to apply restrained sanctions for clear admissions (Everton, Forest, Leicester) and argue they should not be singled out for unprecedented punishment.

 Chronological account

• Aug–Sept 2008: Sheikh Mansour bin Zayed Al Nahyan, via Abu Dhabi United Group (ADUG), purchases Manchester City. First full season under ADUG ownership: 2009/10, start date of substantive charges.
• 2014: UEFA settlement with City (and PSG) under FFP, €60 million fine reduced to €40 million on compliance.
• September 2015: Rui Pinto launches Football Leaks website.
• December 2016: Der Spiegel and the European Investigative Collaborations begin publishing Football Leaks material.
• November 2018: Der Spiegel publishes the “Web of Lies” series, four days of front-page City revelations including the Etihad routing, Mancini’s Al Jazira contract and Yaya Touré image-rights agreements.
• December 2018: Premier League opens its investigation (later confirmed in court documents).
• March 2019: UEFA’s CFCB Investigatory Chamber refers City to the Adjudicatory Chamber. The Premier League also publicly confirms it is looking into the issues (the only public confirmation of its investigation for the next two years).
• 14 February 2020: UEFA CFCB bans City for two years, fines €30 million.
• June 2020: CAS hearing held by video conference (Covid-19), three days.
• 13 July 2020: CAS announces the ban is overturned, fine reduced to €10 million.
• 28 July 2020: CAS publishes 93-page written reasons.
• March 2021: Court of Appeal ruling (after a High Court judgment had been challenged) results in confirmation that the Premier League investigation is ongoing, the first time this is publicly verified. 
• 6 February 2023: Premier League issues Rule W.82.1 statement referring 115 alleged breaches to a commission under Rule W.3.4. City respond the same day.
• March 2023 onwards: Murray Rosen KC, chair of the Premier League Judicial Panel, appoints the three-person commission. Identities of panel members remain confidential.
• Through 2023–early 2024: Confidential procedural conferences. City brings collateral applications, including, in May 2023, an unsuccessful objection to Rosen’s involvement on grounds that he is an Arsenal member.
• September 2023: Rui Pinto receives a four-year suspended sentence in Lisbon for nine offences, including attempted extortion.
• January 2024: City launched a separate arbitration under Premier League Rule X challenging the APT Rules.
• June 2024: APT arbitration hearing before the tribunal at the IDRC, lawyers reported in legal circles to number more than 60.
• September 2024: First Decision on APT, partial victory for City; specific provisions found unlawful.
• 16 September 2024: Main 115-charges hearing begins at the International Dispute Resolution Centre, 70 Fleet Street, London. Lord Pannick KC photographed entering.
• 6 December 2024: 12-week hearing concludes. Panel retires to deliberate. City confirm conclusion in their 2024-25 Annual Report.
• February 2025: APT Second Decision, APT Rules 2021–24 declared void and unenforceable in entirety due to non-severability of unlawful provisions. Pep Guardiola publicly says he expects the 115-charges verdict “in one month.”
• 8 September 2025: APT settlement: City accepts amended (November 2024) APT Rules; Premier League proceeds to validate new Etihad and FAB sponsorship arrangements.
• End July 2025: Premier League CEO Richard Masters (NBC interview) refuses to give any timeline.
• February 2026: At Financial Times Business of Football Summit, Masters says: “I simply can’t comment. Having spent three years not commenting, I’m not going to start now. More broadly, any regulator wants its judicial system to be efficient and work quickly  that’s as far as I can go.” Stefan Borson tells ESPN the 15-month silence is extraordinary with few legitimate excuses.
• March–April 2026: Reports (The Athletic, Yahoo, Football Insider) of increased belief inside City of an imminent verdict; Borson and others suggest a liability ruling before the 2025/26 season ends, with sanctions hearing and any appeal to follow.
• 30 April 2026 (current status): No verdict published. Both parties confirm they have received no formal update from the panel. City sit at the top of the Premier League table at points in 2025/26, raising the spectre of a champion being found in breach simultaneously with the title being decided.

Why Is It Taking So Long?

1. Volume. Approximately 129–130 distinct rule breaches; reportedly around 500,000 evidential items reviewed by the panel; financial statements spanning nine reporting years; multiple sponsors and counterparties.
2. Complexity. Each charge requires individual proof; many require proof of intent and obstruction (analogous to fraud), not merely numerical breach. ESPN’s analogy: “the difference between speeding and speeding while remotely manipulating the police officer’s radar gun.”
3. Bullet-proof reasons required. The panel must publish written reasons capable of withstanding appeal (and any High Court challenge to procedural rulings). It is sequencing a bifurcated process: a liability award first, then a separate sanctions phase if any charges are upheld,  a model used in Everton’s PSR cases 
4. Part-time arbitrators. The panel is composed of senior practitioners with full diaries of other commercial litigation work; no equivalent of a sequestered jury exists.
5. Confidentiality. Premier League Rule W.82 makes the proceedings private, and English law protections constrain disclosure,  meaning even the panel’s identity has not been confirmed.

Comparison to other Premier League / EFL PSR cases

• Everton (FY 2022, 6/10 points): Charged 13 March 2023; five-day hearing in October 2023; 10-point sanction announced 17 November 2023; reduced to 6 on appeal February 2024; Total  circa 11 months charge to final outcome.
• Everton (FY 2023, 2 points): Charged 15 January 2024; three-day hearing 25–27 March 2024; decision 8 April 2024 Total 12 weeks.
• Nottingham Forest (4 points): Charged 15 January 2024; 7–8 March 2024 hearing; sanction 18 March 2024; appeal heard 24 April; upheld 7 May: Under 4 months.
• Leicester City (PSR, 6 points, EFL/PL jurisdictional dispute): Initial reference March 2024, jurisdictional disputes through 2024/25; Commission and Appeal decisions 2025/26. Decision finally upheld April 2026.

By comparison, City’s timeline from charge to (anticipated) liability verdict already exceeds 38 months, and from end of hearing exceeds 16 months, orders of magnitude longer than any comparable Premier League case.

Specific procedural battles delaying the case

• 2019–21 disclosure litigation, including a 2021 Court of Appeal ruling on the publicity of the investigation;
• Multiple confidentiality applications under Rule W.82 throughout 2023–24;
• The challenge (May 2023) over Murray Rosen’s appointment given his Arsenal membership;
• The parallel APT arbitration (June 2024 hearing, September 2024 First Decision, February 2025 Second Decision, September 2025 settlement) — which directly affected the comparator data the Premier League can rely upon for fair market value analysis at the substantive hearing;
• Late evidence and additional charges reportedly added during the disclosure phase.

Estimates from legal commentators

• Stefan Borson (McCarthy Denning, ex-City advisor, ESPN/Football Insider): “Few legitimate excuses”; predicts liability ruling before end of 2025/26 season, with sanctions hearing potentially extending well beyond that. Notes City have spent heavily on legal costs.
• Nick De Marco KC ( Barrister, sports law commentator): Has cautioned that any verdict will be appealed by whichever party loses, adding 6–8 months minimum.
• The Lawyer (April 2026): Lays out eight scenarios, noting the panel may have requested supplementary submissions, may be drafting against the prospect of judicial-review challenges, or may be navigating settlement-style discussions in the background. (The Lawyer)
• Paul Quinn / The Esk (April 2026): Frames the silence as likely due to the complexity of the 500,000 items of evidence and the difficulty of coordinating the three senior legal figures on the panel.”

Likely Outcome

Under Premier League Rule W.55 the commission’s tools include reprimand; unlimited fine; recommendation of expulsion; suspension; cancellation of registrations; transfer/registration ban; deduction of points (current or prior season, i.e. title-stripping); compensation orders to other clubs; and the catch-all “such other order as it thinks fit.” The Premier League has no statutory tariff – a sanctions grid was mooted by Richard Masters in February 2025 but is not yet in place).

Range of possible verdicts

1. Full acquittal: Thought to be 15–25% probability per most commentators. Hinges on Pannick’s deconstruction holding, evidence found insufficient and APT/competition law arguments biting on individual charges.
2. Acquittal on substantive charges, conviction on failure-to-cooperate (Group 5): Material probability given that this is the only finding CAS sustained in 2020. Likely sanction: significant fine.
3. Partial findings on Groups 1–4 plus Group 5: The consensus most-likely outcome. Likely sanction: a multi-point deduction, fine, possibly transfer-window restrictions.
4. Wholesale conviction with severe sanction: Points deduction in the range of 40–60 points (Maguire, Wyness), title-stripping of 2013/14, 2017/18 etc., and a record fine. Some legal commentators include expulsion as a theoretical possibility, though almost no commentator views it as likely. 
5. Settlement: Marcotti (ESPN) and The Lawyer have flagged the small possibility that the long delay reflects settlement negotiations modelled on Chelsea’s March 2025 £20 million FA fine and £10 million Premier League settlement for Abramovich-era undisclosed payments.

I have written previously (April 2026) that City’s regulatory exposure would, if the most serious systematic financial-manipulation charges are proven, “potentially elevate the case from a sporting dispute to one of corporate fraud … such a finding would necessitate a complete overhaul of the club’s board of directors and could potentially trigger legal challenges from rival clubs seeking loss-of-chance damages.”

On sanction,  I think a very significant points deduction, note that Champions League non-qualification alone would cost £55–100 million. I have also flagged the diplomatic dimension, the UK Foreign Office having reportedly discussed the case with the UAE, as a shield that may make the most extreme sanctions politically uncomfortable. Theesk.org

Factors making severe sanctions more or less likely

More likely:

• Sheer scope (nine seasons, allegedly systemic).
• Allegation of intentional concealment, not negligence.
• The cumulative effect of failure-to-cooperate (35 charges over five seasons),  already a finding sustained at CAS.
• Pressure from rival clubs (the Red cartel of Liverpool, Manchester United, Arsenal etc.) and the Premier League’s need to demonstrate enforcement credibility.
• Everton and Forest precedents normalising in-season sporting sanction for PSR breaches.

Less likely:

• The 2020 CAS findings that core sponsorship allegations were not established.
• The fact that earliest charges relate to events 16+ years old, with witness availability and document recall heavily compromised,  a powerful proportionality argument.
• The competition-law cloud over Premier League rules (post-APT findings).
• City’s institutional legal firepower and willingness to litigate every issue to the High Court.
• The diplomatic risk of destabilising UK-UAE economic relations.
• The lack of any precedent in English football for stripping Premier League titles or expelling a current top-tier club for financial breaches.

The earliest alleged conduct dates from 2009/10,  over 16 years ago. While the Premier League rule book contains no formal limitation period analogous to UEFA’s 5-year statute, panels have historically given mitigation weight to staleness of allegations. The Norton Rose Fulbright analysis and Nick De Marco have both identified this as a real proportionality vulnerability for severe sanction, though not a bar to any finding.

Comparable Football Cases

Financial regulation cases

• AC Milan v UEFA (CAS 2018/A/5808). UEFA CFCB Adjudicatory Chamber on 19 June 2018 banned Milan from one season of UEFA competition for breaching Articles 58–63 of the FFP Regulations (2014–17 break-even deficit of €121 million vs €25 million permitted). On 20 July 2018 CAS confirmed the breach but annulled the exclusion as disproportionate, citing Elliott Management’s takeover. Case remitted; Milan ultimately accepted exclusion from 2019/20 Europa League and a €12 million withholding (December 2018), with squad-size restrictions. Key parallel: CAS’s de novo proportionality review under Article R57 of the CAS Code mirrors the kind of proportionality argument Pannick will deploy against any Premier League finding.
• Paris Saint-Germain. 2014 settlement with UEFA (€60 million fine, €40 million suspended) for alleged inflation of Qatar Tourism Authority sponsorship; 2017–18 reopened investigation following Neymar/Mbappé deals; CAS 2019 ruling that UEFA’s CFCB had missed deadlines to challenge its own earlier compliance decision. Further FFP penalty in 2022 (€10 million fine, prize-money withholdings). Parallel: state-linked sponsorship inflation, multiple successful procedural challenges, no points sanction ever imposed in domestic competition.
• FC Barcelona,  Negreira case. Payments of approximately €7.3–8.4 million made between 2001–2018 to companies linked to José María Enríquez Negreira, vice-president of Spain’s Technical Committee of Referees (CTA). Spanish prosecutors charged Barcelona, ex-presidents Sandro Rosell and Josep Maria Bartomeu and Negreira with sports corruption and continuous corporate corruption (2023). May 2024: bribery charges against Negreira dismissed (not a public official under Spanish law). October 2025: Barcelona formally charged as a legal entity. UEFA opened its own investigation in 2023 (potential one-season Champions League ban under post-2007 Article 4.02 of UEFA’s Champions League regulations). Case still active April 2026. Also LaLiga licensing/PSR pressures and the 2021 “economic levers” sales of TV rights.
• Juventus  plusvalenze / capital gains scandal. January 2023: 15-point Serie A deduction for false invoicing in transfer swap deals (2018–2021). April 2023: deduction restored on appeal. May 2023: 10-point deduction reimposed by FIGC Court of Appeal. 22 directors banned including Andrea Agnelli (24 months) and Fabio Paratici (30 months, then extended to a global FIFA ban affecting his Tottenham role). Also accepted €20 million fine and one-year UEFA ban (Conference League, 2023/24) for separate FFP issues
• Rangers FC (Scotland). EBT scheme used 2001–2010 paying  approximately £47 million via Murray Group Management Remuneration Trust; HMRC prevailed in the Supreme Court on 5 July 2017 (RFC 2012 Plc v Advocate General [2017] UKSC 45). Rangers entered administration February 2012, liquidation 31 October 2012; SPL refused membership transfer; Lord Nimmo Smith Commission (2013) found rule breaches but declined to strip titles, holding no sporting advantage was gained. Tax bill ultimately settled for circa 14 pence in the £.
• Leeds United. 2007 HMRC tax case during administration; insolvency-related EFL points deduction (-15) on exit from administration in League One.
• Everton, Nottingham Forest, Leicester: covered above.

Governance and integrity cases

• Calciopoli (Italy, 2006). Wiretaps revealed Juventus general manager Luciano Moggi influencing referee appointments, 2004–06. Juventus stripped of 2004/05 and 2005/06 titles, relegated to Serie B with 9-point deduction; Fiorentina, Lazio, Milan, Reggina hit with point deductions. Moggi life-banned (later partially overturned on statute-of-limitations grounds in 2015 Supreme Court ruling). The case illustrates that English football has no domestic precedent for this scale of sanction.
• 1971 Bundesliga “Bundesliga-Skandal”. Match-fixing across the relegation battle in 1970/71. 52 players and 2 managers punished, Arminia Bielefeld’s licence revoked (relegated to Regionalliga 1972), Schalke 04 nicknamed “FC Meineid” (FC Perjury) for false oaths.
• UEFA/FIFA governance scandals (Sepp Blatter / Michel Platini bans 2015, FIFAGate 2015 indictments) demonstrate the trend of statutory and law-enforcement intervention into self-regulation but are largely outside the City frame.

Disputed-evidence / long-running cases

• AC Milan and PSG cases (above) both featured admissibility/procedural battles.
• The Juventus plusvalenze case featured wiretap evidence whose admissibility was fiercely contested. Like City’s Football Leaks defence, the Italian clubs argued the evidence was contextually misleading.

The Independent Football Regulator: 

Jurisdiction over the City charges

The Independent Football Regulator (IFR) was established by the Football Governance Act 2025 (Royal Assent 21 July 2025; in force from autumn 2025; first CEO appointed 2025; chair David Kogan OBE; observer from the FA on the board). It has no jurisdiction over the existing Manchester City charges, for three reasons:

1. The IFR is a creature of statute and only acquired enforcement powers in late 2025; the conduct alleged occurred 2009–2018 and the proceedings began under Premier League contractual rules in February 2023.
2. The Football Governance Act explicitly does not displace league regulation (Pinsent Masons commentary; Latham & Watkins client alert): the Premier League continues to administer PSR and competition-rule matters.
3. Section 56 of the Act and accompanying provisions impose duties of consultation between competition organisers (Premier League, EFL, FA) and the IFR but do not transfer jurisdiction over disciplinary matters already in train.

IFR powers relevant to the City conduct

The IFR’s tools, applied to clubs in the top five tiers (116 clubs total), would have addressed almost every category of alleged conduct in the City charge sheet had they existed in 2009–2018:

• Mandatory operating licences with threshold conditions including financial soundness and compliance with a Football Club Corporate Governance Code.
• Owners’ & Directors’ Test (strengthened, with criteria of honesty, integrity, financial soundness; modelled on the FCA’s senior managers regime. See Lewis Silkin’s March 2026 analysis of the FCA-IFR Memorandum of Understanding). Applies to incumbents on grounds for concern (s.34, FGA 2025)
• Removal / disqualification orders, with appointment of trustees (s.43) to force a sale.
• Mandatory audited financial reporting by 31 December annually; obligations on financial plans, beneficial ownership, related-party transactions and source-of-wealth.
• Investigation & enforcement powers, including criminal liability for hiding/destroying evidence (up to two years’ imprisonment).
• Sanctions: licence conditions; financial penalties up to 10% of turnover; suspension/revocation of operating licence (effectively expulsion from the league).

Could the IFR have detected/prevented the conduct in 2009–2018?

Detection: Yes, more likely than the Premier League’s own machinery. The IFR’s powers to demand beneficial-ownership disclosure, scrutinise related-party transactions at fair-market value at the point of execution (a regime more demanding than the pre-2021 RPT rules), and audit financial plans would have brought the Etihad/Etisalat/Aabar arrangements under scrutiny earlier, particularly the routing of funds via owner intermediaries. The criminal-liability provision for destroying or concealing information would have changed the cost-benefit calculation for the conduct alleged in Group 5 (failure to cooperate).

Prevention: Partial. The IFR cannot regulate sporting matters or specific commercial decisions; it would not have prevented City structuring large sponsorship deals with Abu Dhabi entities. But fair-market-value scrutiny, an enforced governance code, and source-of-wealth tests on Sheikh Mansour would likely have constrained the most egregious mechanics (back-dated contracts, cash routed via intermediaries, undisclosed manager consultancy contracts).

What the City case reveals about gaps in football’s self-regulation

• Information asymmetry: Premier League Rule B/E disclosure obligations rely on club good faith. The Football Leaks evidence emerged from outside the regulatory system.
• Glacial enforcement timelines: 4 years to charge, 4+ years to verdict. The FCA-style supervisory model embedded in the IFR (Lewis Silkin) is meant to catch issues prospectively rather than via 16-year retrospective adjudication.
• Litigation as defence strategy: City’s APT victory shows that competition-law challenges can void the rule book itself. A statutory regulator with public-law foundations is structurally less vulnerable.
• Conflict of interest: the regulator (Premier League) is owned by the regulated entities, including the defendant. Multiple Springer/International Sports Law Journal commentators (2025–26) have argued the IFR’s design responds directly to this critique.

IFR design lessons from the City case

• Front-loaded transparency of related-party transactions at fair-market value; analogous to the post-2021 APT regime, but with statutory backing.
• Whistle blower protection integrated with disclosure incentives (the FCA model).
• Forward-looking financial regulation (Squad Cost Ratio) rather than purely retrospective break-even.
• Coordinated enforcement timetables to avoid 16-year dispute life cycles.
• Information-sharing MoUs with the FCA, HMRC and Companies House (in place as of March 2026 per Lewis Silkin) to capture the kinds of cross-jurisdictional money flows alleged in the Mancini/Al Jazira arrangement.

The Act adopts a deliberate division of labour: the Premier League continues to set and enforce PSR (and from 2025/26 the new Squad Cost Ratio); the IFR sets a baseline financial-resilience licence regime. Section 23 of the Act requires the IFR to consult competition organisers before imposing financial licence conditions, and competition organisers must notify the IFR of suspected breaches and consult before sanctioning (Latham & Watkins).

Risks identified by the FSA’s clause-by-clause analysis (July 2025) and the International Sports Law Journal article (2025–26):

• Double jeopardy: A club fined up to 10% of turnover by the IFR could also receive a points deduction from the league for the same conduct, with relegation costing far more than the IFR fine. The FSA has called for a statutory sequencing rule with IFR pre-eminence.
• Regulatory overlap on financial information between the IFR licensing regime and the Premier League’s PSR/SCR rules.
• Risk that PSR becomes legally vulnerable post-City APT findings (the ISLJ argues PSR may itself be unlawful under competition law, leaving the IFR’s licensing regime as the more secure forward-looking framework).

The most defensible architecture,  and the direction commentators (Pinsent Masons, Hill Dickinson, Norton Rose Fulbright) anticipate, is for the IFR to own systemic financial resilience and ownership testing, while the Premier League retains sporting and squad-cost regulation, with binding consultation duties and IFR pre-emption rights where regulations conflict.

Caveats

1. Confidentiality. The 115-charges proceedings are private under Premier League Rule W.82. Significant material, including the precise identity of the three commission members, full pleadings, expert reports and any settlement discussions, is not in the public domain. Reporting on procedural milestones inside the hearing relies on photographic/witness evidence at the IDRC, club annual reports, and statements made in passing by Pep Guardiola and Richard Masters.
2. The 115 figure is an artefact of how bullet points were counted in the Premier League’s February 2023 statement; the underlying number of distinct rule-season-conduct combinations is reported by ESPN, The Lawyer and others as approximately 129–134. Some reports have suggested charges have been added since. None of these distinctions has been formally clarified by either party.
3. All forecasts are speculative. The 40–60-point deduction estimates from Kieran Maguire, Keith Wyness and Christian Purslow are extrapolations from the Everton/Forest precedents, not predictions backed by inside knowledge. My own view, expressed previously on this site is “frankly, it remains anyone’s guess as to the range of outcomes.” Several scenarios (full acquittal, settlement, very limited findings) remain materially possible.
4. Source quality. Several articles cited (Manchester Independent, Yardbarker, European Business Magazine, SI/Sports Illustrated explainer) compile and recycle reporting from primary outlets (BBC, Sky Sports, The Athletic, ESPN, The Times, The Guardian, Der Spiegel, Norton Rose Fulbright, Morgan Sports Law, Lawinsport, The Lawyer). Where these add new factual claims (e.g. “500,000 evidence items,” “24-hour notice before publication”), readers should treat them with caution. The 1 April 2026 CaughtOffside item about the City team-bus driver is satirical (April Fool’s). 
5. Football Leaks evidence. Authenticity of the underlying emails has not been seriously contested. What is contested is the inferential leap from individual email fragments to provable financial misconduct over nine seasons. CAS in 2020 admitted the emails but found they did not establish UEFA’s case; the Premier League’s panel may take a different view because (a) the rule book is different, (b) the time-bar does not apply, and (c) more material (including post-2018 conduct in Group 5) is in scope.
6. Geopolitical context. I and others have raised the UK-UAE diplomatic dimension; this is a contested framing.  Some argue there is no evidence that any UK government has actually intervened in the proceedings, and the Lawyer has explicitly pushed back on conspiracy theories about state interference. References to Sheikh Mansour’s alleged role in the Sudan conflict are drawn from external NGO and intelligence sources and have not been adjudicated.

Status as of 30 April 2026. As of the date of this analysis, no liability verdict has been published; no sanction has been imposed; all 115 charges remain alleged but unproven.

Manchester City remain presumed compliant pending the commission’s findings. Meanwhile football waits.