What the 25 September 2026 press reports tell us, tested against my prior analysis, and how far the case evidences governance failure at League, club and Commission level

Position as at:  Friday 25 September 2026 (evening). Based on press reporting; the judgment is unpublished

Author:  Paul Quinn, CWTE Limited 

Series:  Follows: The Esk, “Manchester City v The Premier League: the 115 charges case” (30 April 2026) and “The Unresolved 115 Charges Case” (16 September 2026)

All findings reported here remain unconfirmed by the Premier League or the commission, are subject to appeal and are not final. Manchester City denies wrongdoing. Nothing in this report asserts as established fact any finding that has not been formally published.

Summary

Ten things we learned today

• The case was not weak. A near-total finding after a 12-week hearing disposes of the narrative, advanced for three years, that the League over-reached. City’s “comprehensive body of irrefutable evidence” did not persuade the tribunal on 114 of 115 counts, on the reported numbers.

• Bifurcation is confirmed. Liability has been determined; sanction has not. My 16 September report treated bifurcation as reported understanding. It is now effectively confirmed, and it means at least one further contested phase before any appeal concludes.

• The 35 non-cooperation charges appear to have been proven. If so, this changes the delay debate. The pre-hearing delay that City would cite in mitigation was, on the commission’s apparent findings, partly the product of conduct that is itself culpable.

• The League cannot keep a secret. Clubs were told at Thursday’s shareholders’ meeting and required to sign non-disclosure agreements. The outcome was in the public domain on Friday afternoon. That is an information-governance failure of the first order, whoever the source.

• Manchester City has pre-positioned a bias challenge. Its statement conditioned its respect for due process on the League’s board and executive acting as an impartial regulator “free from partisan influence”. That is the language of a future impartiality or serious-irregularity attack, and the leak hands it material.

• The sanction framework is still a blank page. Richard Masters floated a sanctions grid in February 2025. Sky reports it is still not in place. The League is about to sanction the most serious case in its history with no published tariff.

• The ultimate sanction returns to the conflicted. A commission can only recommend expulsion to the League’s board. The most severe outcome is therefore routed back through a governance structure owned by City’s competitors, several of whom have live compensation positions.

• The compensation cascade is now live. Manchester United, Liverpool, Arsenal and Tottenham were reported in 2024 to have started protective arbitrations. My Burnley v Everton work (PLJP 2023/3) provides the loss-of-chance template these claims will follow.

• Final resolution before 2027/28 remains improbable. Sanction, appeal to a fresh three-member Appeal Board and a possible Arbitration Act challenge in the Commercial Court make any sporting penalty likely to fall on a squad, and possibly a season, unconnected with 2009 to 2018.

• The case is now the strongest single exhibit for the Independent Football Regulator’s existence. Every structural weakness we identified in April (information asymmetry, glacial enforcement, litigation as defence, regulator owned by the regulated) has now been demonstrated in a single case.

Governance failure: summary verdict by tier

What was reported on 25 September 2026

The facts below are drawn from press reporting on the afternoon and evening of 25 September 2026. None of the reported findings has been confirmed by the Premier League or the commission. The League has declined to comment, describing the process as private and confidential. The table grades each item by the quality of its sourcing, because the difference between a single anonymous source and multi-outlet corroboration matters for any board relying on it.

The reported position

The count most commonly cited is 115, taken from the League’s February 2023 release. The breakdown reported today (Inside Sport, Yahoo/All Out Soccer) is set out below. Two inconsistencies must be noted. Sky reports that the underlying count is believed to be about 130. The Guardian refers to 134 charges covering 2009-10 to 2022-23 and to 20, rather than 14, remuneration charges. The difference probably reflects how multi-rule charges are counted rather than a different case, but it cannot be resolved until the decision is published.

Elapsed-time metrics

The durations below run to Thursday 24 September 2026, when clubs were informed. The date on which the decision was delivered to the parties is not public and may be earlier.

My 16 September report, “The Unresolved 115 Charges Case”, set out conclusions on why the case had taken so long and what the delay meant for each party. My 30 April Analysis Series piece placed the case inside the IFR systemic risk framework. Both are tested below against today’s reporting. Where today’s evidence overtakes or refines a prior view, it is stated plainly.

The one correction to make

My 16 September report relied on sourcing indicating that the parties had not yet received a decision. City’s reported surprise at the timing of today’s news, and its statement that significant elements remain to be completed, are consistent with the parties having held the liability decision for some period before the clubs were told. If so, that element of our earlier report was overtaken before publication. The analytical conclusions do not depend on it, but it should be recorded.

The most consequential detail in today’s reporting is not the headline 114. It is that the non-cooperation block, 35 charges covering December 2018 to February 2023, appears to have been proven. The League spent four years getting from investigation to charge. City’s public case was that this reflected a partisan, over-extended regulator. A finding that City failed to cooperate throughout that period reallocates a material share of the pre-charge delay to the club.

This matters in three places. First, in sanction, where the non-cooperation findings will be treated as aggravating rather than as neutral procedural history. Second, in any mitigation-for-delay argument by analogy with Attorney General’s Reference No 2 of 2001, where the party responsible for delay cannot ordinarily rely on it. Third, in the governance assessment in section 3, because it shows that the League’s investigative weakness was not only one of capability but of enforceable power: it could ask, but it could not compel.

Is this a complete governance failure?

Governance failure is defined here as the failure of a system of direction, control and accountability to deliver outcomes that are timely, fair, proportionate, confidential where confidentiality is required, and credible to the people who depend on them. A system can fail on process while succeeding on substance. That distinction is the key to answering the question fairly.

A complete governance failure would require that the system produced the wrong answer, or no answer, or an answer no one could trust. On today’s reporting none of those is true of the adjudication itself. What has failed is almost everything that surrounds it: the absence of early detection, the four-year investigation, the lack of any timetable, the absence of a published tariff, the design of the disclosure process and the structural conflict at the top of the League. The test is applied below across eight dimensions and four actors.

Governance scorecard

Ratings measure severity of failure: Low means the actor performed acceptably on that dimension; Critical means the failure was fundamental. “Quality of outcome” is rated Low (good) for the League and commission because the reported result vindicates the prosecution and the tribunal’s fact-finding; it is Critical for City because the reported findings are findings against it. All ratings for City are provisional pending publication and appeal.

The Premier League: right about the case, wrong about the system

Detection: the League did not find this; a hacker did

The alleged breaches began in 2009/10. The League did not detect them through its own monitoring. They surfaced in November 2018 through Der Spiegel’s Football Leaks publications, based on material obtained by Rui Pinto. That is the defining fact of the case. A financial rulebook built on self-certification and a club’s duty of utmost good faith had no independent means of testing whether the certificates were true. For nine seasons, on the reported findings, they were not. No prudential regulator would regard a supervisory model that relies on criminal leaks for detection as functioning.

Investigation: four years, compelled secrecy, weak powers

The investigation opened in December 2018 and produced charges in February 2023. The Guardian recalls that the inquiry was so secretive that the Mail on Sunday had to go to court to establish that it existed. City challenged the League’s information requests through the courts in 2019 to 2021 and lost. The deeper point is that the League’s powers were contractual, not statutory. It could demand documents but could not compel them in the way the FCA or CMA can, and its only remedy for non-cooperation was a further charge, adjudicated years later. The 35 non-cooperation charges are the measure of that weakness.

Rule design: no tariff, no timetable, no limitation policy

Sky reports that the League has no fixed sanctions for financial breaches because clubs feared that a known price would be treated as a cost of doing business. That rationale has some force. But its consequence is now acute: the League will sanction the most serious case in its history with no published tariff, inviting a proportionality challenge on every number. Masters raised a sanctions grid in February 2025; it is not in place. Nor do the rules require the commission to deliver an award within any period, or require the Judicial Panel chair to supervise progress. The League has no limitation period. That permitted charges reaching back to 2009, where UEFA’s five-year rule defeated much of its own case at CAS in 2020, but it also committed the League to adjudicating conduct older than most of the current squad’s careers.

Information governance: the leak

Clubs were informed of the outcome at Thursday’s shareholders’ meeting and required to sign non-disclosure agreements. The result was public on Friday afternoon across The Athletic, The Times, the BBC and the Guardian. The source is unknown and nothing in this report attributes it. But the failure does not depend on identifying the source. It lies in the design decision to disclose a confidential, unpublished, pre-sanction liability finding to nineteen competitors, several of which hold live compensation positions against the respondent, protected only by a contractual NDA.

The consequences are practical, not just reputational. City now has a documented procedural grievance to deploy at sanction and on appeal. Its statement already frames the League’s board and executive as a potentially partisan regulator. A professional tribunal is unlikely to be influenced by press coverage, and the grievance is unlikely to succeed as a legal ground on its own. But it will feature in any Arbitration Act narrative, in the court of public opinion and, critically, with UAE-government counterparties and UK ministers who have their own reasons to want the matter contained.

Accountability: “we have no influence over timing” is not an answer

Masters told Sky Sports News in August 2025 that the League had no influence over the commission’s process or its timing. As a statement of the tribunal’s independence, that is correct. As a statement of governance, it is not, because the League wrote the rules that gave the tribunal no timetable. A board cannot disclaim responsibility for an outcome produced by a framework it designed and that its shareholders approved.

Structure: a regulator owned by the regulated

The League is a company owned by its twenty clubs, including the respondent and the prospective claimants. It is simultaneously the rule-maker, the prosecutor, the appointer of the adjudicators’ panel and the commercial agent maximising the value of the competition all of them share. Masters himself has framed enforcement as going to the integrity of the competition and ultimately to value. That combination is the root cause of most of the failures above, and it is precisely why the Football Governance Act 2025 created a statutory regulator.

The Chelsea contrast: the system rewards fighting

My August 2026 analysis of the two published Chelsea Sanction Agreements is instructive here. Chelsea self-reported Abramovich-era payments through third-party entities; a Sanction Agreement (a £10m fine, a suspended two-window registration ban) was ratified in November 2025, and a second, on academy breaches, in February 2026. Self-report and cooperate, and the matter closes in months at a known price. Contest everything, and the matter runs for eight years, during which the club keeps competing, winning and earning. Unless the eventual sanction on City fully prices the time value of that delay, the system’s incentives favour obstruction. That is a design failure, and it is the League’s.

The Commission and the Judicial Panel: a timeliness failure, not a quality failure

On the reported numbers the commission has done the core job well. It heard twelve weeks of evidence, made findings across nine seasons of accounts and contracts, and reached decisive conclusions, including, reportedly, a finding of bad faith that a tribunal would not make lightly against a club of this standing. If the award is as comprehensive as the delay implies, it will be difficult to attack on its merits.

Its failure is time. Twenty-one and a half months from close of hearing to decision would attract comment in the Commercial Court; in a sporting context, where every month of delay means a further month of competition under an unresolved cloud, it is damaging in its own right. The panel was part-time, there was no timetable, and no one had the job of asking what the delay was costing the competition. Our August 2026 research on whether adjudicators owe duties to the wider game found that commissions owe duties to the parties under the arbitration agreement and the Arbitration Act, notably the s.33 duty to avoid unnecessary delay, but no enforceable duty to the competition as a whole. That gap is where the systemic cost of this delay fell.

Bifurcation compounds it. The sanction phase will require further submissions, possibly a further hearing and a further reasoned decision. An appeal to a new three-member Appeal Board, appointed by the Judicial Panel chair, follows, and that board’s decision is final within the League’s system. Beyond it lies only the Commercial Court under ss.67 and 68 of the Arbitration Act 1996. Each step is individually defensible. Together they push the practical effect of any sporting sanction to 2027/28 at the earliest.

The member clubs: architects, claimants and the probable channel

The clubs are not bystanders. As shareholders they approved a rulebook with no sanction tariff and no adjudication timetable, and they did so deliberately. They divided on Associated Party Transaction rules in 2024: Goal, citing Sky, reported that Chelsea, Newcastle and Everton supported City’s position while Arsenal, Manchester United, Liverpool, West Ham, Brentford, Bournemouth, Fulham and Wolves supported the League. Four of them (United, Liverpool, Arsenal and Tottenham) were reported by The Times in 2024 to have started protective arbitrations against City to preserve compensation claims. They will sit in judgment, through the board, on any recommendation to expel.

That is a conflict of interest embedded in the League’s constitution. It is also why the disclosure of the verdict to the full shareholder body was so predictably leaky: the audience included parties with direct financial interests in the outcome becoming public, and nothing in the NDA mechanism aligned their incentives with confidentiality. Attribution is not established, and a leak could have come from anyone briefed, including advisers. But a system that routes a confidential finding through nineteen interested competitors has chosen its own risk.

Manchester City: the most serious failure, if the findings stand

The findings are unpublished and under appeal, and City denies wrongdoing. On the reported position, however, the commission has found against the club on the integrity of its financial reporting across nine seasons, on the disclosure of remuneration, on compliance with PSR and UEFA FFP, and on its cooperation with the regulator for more than four years, with a reported finding of bad faith. Those are board-level failures by definition. Financial reporting to the league regulator, remuneration disclosure and the posture adopted towards an investigation are decisions taken or sanctioned at the top of the club. The club’s senior leadership has been substantially continuous across the charge period and the investigation.

Two further features of City’s governance deserve board attention. The first is litigation as strategy. In 2014, Sky recalls, Khaldoon Al Mubarak said he would rather spend heavily on lawyers and litigate for a decade than accept a UEFA financial penalty. City’s record since, including the successful CAS appeal on time-bar grounds, the 2019 to 2021 disclosure challenges and the 2024 APT victory, shows that approach executed. It is lawful, but it is also a governance choice to treat regulation as adversarial rather than cooperative, and the reported non-cooperation findings suggest a tribunal has now priced it.

The second is today’s statement. It does not engage with the reported findings; it questions the impartiality of the League’s board and executive while describing the process as confidential. That is a strategic position for the next phase, not a governance response to a finding of this gravity. For City’s own board, the orthodox governance response to a reported bad-faith finding would be an independent review of financial reporting and regulatory engagement, whatever the appeal strategy. There is no sign of one.

Verdict

Today’s reporting bears on almost every strand of my analytical programme. The table sets out where, and what changes.

Compensation exposure: framing, not estimating

It would be false precision to estimate City’s compensation exposure before the award is published, because causation, counterfactual league positions and limitation will all turn on specific findings. What can be said is how the Burnley v Everton framework will apply. A claimant must show a breach, a causal link between that breach and a lost opportunity, and a real and substantial chance of a better outcome, discounted for probability. For City claimants, the relevant lost opportunities are titles, Champions League qualification and the associated prize, broadcast and commercial uplift across the 2009/10 to 2017/18 seasons.

Three features distinguish these claims from Burnley’s. They are multi-season and multi-claimant, so the aggregate is larger and the counterfactuals interact: if City had finished lower, several clubs’ positions would move at once. Limitation is contested: claimants will rely on s.32 of the Limitation Act 1980 (deliberate concealment), which a bad-faith finding materially supports. And the evidential burden on causation is heavier where the breach is financial inflation over years rather than a single identifiable event. Press estimates of potential exposure in the hundreds of millions of pounds are plausible in order of magnitude but should not be relied on.

What happens next

Procedural sequence

Two points of detail are unresolved in today’s reporting. First, outlets differ on who chairs the Judicial Panel and so appoints the Appeal Board: Sky names Sir Gary Hickinbottom, while several other outlets name Murray Rosen KC, who held the role earlier in the case. Sky’s reference appears more current, but it should be verified. Second, it is not clear whether an appeal on liability can be lodged now or only once sanction is determined. Sky’s report that the process is moving to the appeal stage suggests the former.

Sanction benchmarks

The League has no tariff. The table sets out the comparators a tribunal and an Appeal Board will be referred to. None is a close match for the combination of scale, duration and non-cooperation reportedly found here.

Scenario probabilities

The probabilities below are my analytical judgement, conditional on the reported liability findings substantially surviving appeal. They are offered to support planning, not as predictions of a confidential process.

The weighting towards A and B reflects three factors: the scale and duration of the reported findings, the reported bad-faith and non-cooperation findings (which remove the principal mitigating features present in the Everton and Forest cases), and the need for a deterrent that exceeds the value City derived from the period. D is kept at 10% because the proportionality argument about punishing a current squad for historic conduct is real, and the post-hearing delay is not City’s fault.

Recommendations

Questions the Premier League Board must answer now

• Under what rule or obligation was a confidential, pre-sanction, unpublished liability decision disclosed to all shareholder clubs, and who took that decision?

• What information controls were applied beyond an NDA: who was in the room, what was shown, and was any written material distributed?

• Will the League commission an independent leak inquiry under external counsel, with findings reported to shareholders?

• When will a sanctions framework be published, and will it apply to this case or only prospectively?

• What is the League’s assessment of its exposure if City advances a s.68 serious-irregularity or impartiality challenge drawing on today’s events?

• How will the League ensure that any expulsion recommendation is decided by persons without a financial interest in the outcome?

Recommendations by addressee

Possible recommendations for the Independent Football Regulator

The IFR has no jurisdiction over League disciplinary proceedings, and it should not seek to intervene in them. But this case engages its statutory remit in four ways.

• Systemic financial risk. A severe sanction on City, followed by multi-club compensation claims, is a system-level financial event. It should be modelled within the IFR’s monitoring of club financial resilience, including counterparty exposure through transfer receivables.

• Owners’ and directors’ fitness. If findings of bad faith are upheld, they will be relevant to the IFR’s owners’ and directors’ test, whose criteria include honesty and integrity. The IFR should state now how it will treat final findings of this kind, so that its approach is not devised under pressure later. (The precise statutory wording should be confirmed against the Act and IFR guidance.)

• League governance. The IFR’s assessment of the state of the game should record the absence of adjudication timetables, sanction tariffs and information controls as governance deficiencies in the League’s regulatory function.

• Future statutory review. The case supports considering whether financial-rule enforcement for licensed clubs should sit with the statutory regulator, with public-law safeguards and statutory information-gathering powers, rather than with a members’ association.

Caveats, methodology and sources

Data limitations

Methodology

Press reports of 25 September 2026 were collated and graded by sourcing quality. Prior analysis of mine (30 April and 16 September 2026) was tested, finding by finding. Governance was assessed against a defined test across eight dimensions and four actors, using a four-point severity scale. Comparators were drawn from Premier League, European league, other-sport and UEFA/CAS precedent, and from my analysis of Burnley v Everton, Chelsea, IFR systemic risk and duty-of-care workstreams.

Principal sources

• The Athletic (David Ornstein), report of 25 September 2026, as reported by Football365, Read Man City, Yahoo Sports and CNN.
• The Guardian, report of 25 September 2026, syndicated by the Irish Times and AOL.
• BBC Sport, report of 25 September 2026, as syndicated.
• Sky Sports (Kaveh Solhekol), “Man City Premier League charges explained” and “Inquiry moves to appeal stage”, 25 September 2026.
• The Times, report of 25 September 2026 on the shareholders’ meeting, via Read Man City.
• The Independent, report on the appeal process, 25 September 2026, via Read Man City and Inside Sport.
• Inside Sport, “Manchester City guilty of 115 charges: verdict and appeal”, 25 September 2026 (charge breakdown).
• Manchester City FC statement of 25 September 2026 (to The Athletic, CNN and Sky Sports).
• Richard Masters to Sky Sports News, August 2025, as reported by Reuters/Malay Mail and Flashscore.
• Norton Rose Fulbright, “Manchester City v The Premier League: What happens next in the 115 charges litigation?”.
• The Times (2024), via Goal, on protective arbitrations by Manchester United, Liverpool, Arsenal and Tottenham; Goal (citing Sky) on club alignments in the APT arbitration.
• APT arbitration award, October 2024, as reported (Reuters/Malay Mail).
• Burnley FC v Everton FC, PLJP 2023/3 (Commission: David Phillips KC, HH Alan Greenwood, Nick Igoe).
• Premier League / Chelsea FC Sanction Agreements, ratified 26 November 2025 and 25 February 2026.
• The Esk: “The Analysis Series: Manchester City v The Premier League: The 115 Charges case” (30 April 2026); “The Unresolved 115 Charges Case” (16 September 2026); IFR systemic risk series IFR/SOTG/SR/2025/01, IFR/SOTG/FIN/2025/02 and 03.

Paul Quinn  |  CWTE Limited