After the reported verdict – an opinion paper
| Item | Detail |
|---|---|
| Author | Paul Quinn, CWTE Limited |
| Date | 26 September 2026 |
| Status | Opinion. Written on the basis of the verdict as reported on 25 September 2026; the commission’s reasons are unpublished, sanction is undetermined and an appeal is expected. |
| Related work | Systemic risk report series (IFR/SOTG/SR/2025/01; IFR/SOTG/FIN/2025/02–03); Burnley v Everton systemic risk and inter-club litigation papers (2026) |
|
Summary
The reported verdict is a judgment about a club. The seventeen years between the first season in scope and a first-instance finding are a judgment about a system. English football needs to answer both, and it must resist the temptation to let the second answer dilute the first.
My position, set out in full below, rests on six propositions:
- Accountability is not negotiable. If the findings survive appeal, sanction must be proportionate to the seriousness and duration of the conduct and to the non-cooperation found. No governance undertaking, commercial consideration or settlement should be allowed to trade against it.
- This was also an institutional failure. A regime in which alleged breaches spanning 2009/10 to 2017/18 were exposed by a newspaper rather than by supervision, and took a further eight years to reach a first-instance decision, did not work. That is a statement about the rules and the rule-maker, not an excuse for anyone who breached them.
- Leadership is now tested at three levels. The club, the League and the Regulator each face a distinct test, and each can pass or fail it independently of the others.
- Prevention requires detection, speed and compulsion. The agenda is not new rules for their own sake; it is earlier detection, enforceable cooperation, time-bound adjudication and assurance that reaches the transactions where concealment happens.
- The Independent Football Regulator is prospective, not retrospective. It cannot and should not re-try this case. Its value lies in ensuring the conditions that allowed it cannot recur, and in treating adverse findings seriously within its fitness and supervision regimes.
- Reputation is recovered by transparency, not by communications. Full publication of the reasons, a principled and published approach to sanction and consequential redress, and an honest institutional account of the delay will do more than any statement.
What is known, and what is not
| Matter | Position at 26 September 2026 | Status |
|---|---|---|
| The finding | Guilty on 114 of 115 charges, per The Athletic (David Ornstein), subsequently reported by Reuters and others | Reported; not officially published |
| The one charge not upheld | Not identified in reporting | Unknown |
| Sanction | Not yet determined; process described as ongoing | Pending |
| Appeal | Expected. Either party may appeal within 14 days; a fresh three-person appeal board is appointed by the chair of the Judicial Panel | Expected |
| Club position | Process “ongoing” and confidential; position unchanged from February 2023 statement | On record |
| Premier League position | Declined to comment | On record |
| Conduct period | Nine seasons, 2009/10 to 2017/18 (non-cooperation charges run December 2018 to February 2023) | Per February 2023 charge |
| Hearing | September to December 2024 | Established |
Sources: The Athletic via Yahoo Sports, beIN SPORTS, ESPN, Bleacher Report, CNN (all 25–26 September 2026); Premier League charge announcement, 6 February 2023.
The charges, as framed by the Premier League in February 2023, fell into five groups. They are worth restating because they describe the anatomy of the problem any reform must address.
| Charge group | Number | Period |
|---|---|---|
| Failure to provide accurate financial information giving a true and fair view | 54 | 2009/10 – 2017/18 |
| Failure to provide full details of manager and player remuneration | 14 | 2009/10 – 2017/18 |
| Breach of UEFA Financial Fair Play requirements (as incorporated in League rules) | 5 | 2013/14 – 2017/18 |
| Breach of Premier League Profitability and Sustainability Rules | 7 | 2015/16 – 2017/18 |
| Failure to cooperate with the Premier League investigation | 35 | Dec 2018 – Feb 2023 |
| Total | 115 |
Source: Premier League statement of 6 February 2023. Allocation of the 114 reported findings across these groups is not yet known.
First principle: Accountability is not negotiable
There will be a temptation, in some quarters, to move quickly from verdict to “lessons learned”. That instinct is understandable in an industry that prizes continuity of product and commercial value. It is also dangerous. A reform agenda announced before sanction is settled can be read, and will be read, as a substitute for it.
Three points need to be stated plainly.
First, the club’s right of appeal is legitimate and should be respected without reservation. Due process cuts both ways. But the appeal is the forum for challenge. It is not a licence to continue characterising the League as partisan, and the club’s statement of 25 September, which again framed its cooperation as premised on the League behaving as an “independent, impartial and fair minded regulator”, does nothing to lower the temperature. Boards should expect the club to contest the findings robustly in the appeal and to stop contesting the legitimacy of the process in public.
Second, the scale of the findings, if upheld, matters. Everton and Nottingham Forest received points deductions in 2023/24 for Profitability and Sustainability breaches, cases that turned on the scale of accounting losses, not on nine seasons of alleged inaccurate reporting and years of non-cooperation. The credibility of the entire rulebook now depends on sanction being visibly proportionate across that spectrum. A sanction that appears lighter per breach, per season or per pound for the most serious case the League has ever brought would do more reputational damage than the original conduct.
Third, nothing in the forward agenda should cap, defer or compromise the rights of other clubs to pursue remedies available under the rules. I return to redress later, and I want to be clear at the outset: my concern is with the orderliness of redress, not its quantum.
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How this happened: A system failure as well as a club failure
To acknowledge institutional failure is not to share blame. Whoever breaches a rule is responsible for the breach. But a regulator, and in 2009 to 2018 the Premier League was the regulator, is responsible for whether its rules detect, deter and determine. On each of those three measures, the record is poor.
Detection came from outside the system
The investigation followed the publication of leaked documents by Der Spiegel in November 2018, not supervisory discovery. Nine seasons of alleged inaccurate financial reporting passed through the League’s ordinary monitoring, and through clean statutory audits, without triggering action. Whatever the explanation, the sophistication of the arrangements, the limits of audit scope, or the absence of any power to look behind related-party and remuneration structures, a supervisory regime that depends on journalism to detect misconduct is not a supervisory regime.
The process took too long at every stage
| Stage | Dates | Elapsed |
|---|---|---|
| Conduct period in scope | 2009/10 – 2017/18 | 9 seasons |
| Leak to investigation to charge | Nov 2018 – Feb 2023 | c. 4 years 3 months |
| Charge to hearing | Feb 2023 – Sep 2024 | c. 19 months |
| Hearing | Sep – Dec 2024 | c. 3 months |
| Close of hearing to reported decision | Dec 2024 – Sep 2026 | c. 21 months |
| First season in scope to first-instance decision | 2009 – 2026 | c. 17 years |
| Appeal and sanction | From Oct 2026 | Unknown |
Elapsed periods are approximate and calculated from publicly reported dates. The commission, not the parties, controls the timetable once a matter is referred.
Every one of these intervals has an explanation. The case was unprecedented in scale; the club contested it fully, as it was entitled to; the commission rightly took care. But explanations are not justifications. During that period three Premier League titles in the conduct window were already in the record books, further titles were won while the charges were pending, players were bought and sold, clubs were relegated, and broadcast contracts were negotiated, all under a cloud that the League itself could not lift. Justice this delayed imposes costs on every participant, including the accused.
Cooperation could not be compelled
Thirty-five of the charges related to non-cooperation. That this category exists at all, at that scale, tells us the League lacked the tools to obtain what it needed on a timetable it controlled. A private members’ association can require documents under its rules; it cannot compel them with the force that a statutory regulator can. The practical consequence is that an investigated party retains considerable control over the pace of an investigation into itself.
Time was on the side of concealment
The club’s 2020 appeal to the Court of Arbitration for Sport against its UEFA exclusion succeeded because the panel found most of the alleged breaches either not established or time-barred under UEFA’s five-year limitation rule; the exclusion was lifted and the fine reduced from €30m to €10m, for non-cooperation. The lesson from that episode was available six years ago: limitation periods that run from the date of conduct rather than the date of discovery reward concealment. Any regulatory regime that intends to be credible must close that gap.
The rule-maker was also the prosecutor and the commercial partner
The Premier League is owned by its twenty member clubs. It writes the rules with their approval, investigates them, prosecutes them, and simultaneously sells their collective rights. I do not suggest that this structure produced a biased outcome; the adjudication was independent, and the reported result speaks for itself. The point is different: the structure made it possible for the accused to argue bias, publicly and persistently, for years. A system that cannot be seen to be independent cannot command acceptance of its outcomes, whichever way they fall.
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Future leadership: Three tests
Leadership in this context is not about personalities. It is about whether the three institutions with the power to shape what happens next discharge their distinct responsibilities. Each test is independent: one institution failing does not excuse another.
The club
Manchester City’s board faces a test of institutional character that will outlast any appeal. The club has built one of the most admired sporting operations in world football, and its supporters, staff and players who had no part in decisions taken between 2009 and 2018 deserve an ownership that treats the finding with seriousness rather than grievance.
What that looks like in practice is straightforward to describe and difficult to do: contest the findings in the appeal and nowhere else; cooperate fully and promptly with every remaining stage; and, if the findings are upheld, give an account to supporters and to the game of what went wrong, who was responsible, and what has changed. Clubs are custodians of community assets. Custodians explain themselves.
Where the reasons, once published, attach findings to identifiable individuals, those findings must have consequences in the proper forum. That is not a matter for commentators. It is precisely what the Regulator’s owners, directors and senior executives regime exists to consider.
The Premier League
The League’s leadership has pursued this case against its most successful and most powerful member through years of litigation, including the separate challenge to the Associated Party Transaction rules that was resolved in September 2025 with the club accepting the existing rules as valid and binding. That persistence deserves recognition. It should not, however, be confused with vindication of the League’s regulatory model.
The League’s test is whether it is prepared to give an honest institutional account of why its own system took so long, and whether it will accept that some of its disciplinary machinery needs to change structurally rather than cosmetically. In my view the board should commission, now, an independent review of its enforcement function, investigative capacity, case management, time standards and the separation of regulatory from commercial governance, with terms of reference and findings published in full. A league that asks its members to accept adverse outcomes must show it can accept an adverse review.
The Independent Football Regulator
The Regulator has been operational only since its powers took effect on 1 November 2025, with licensing of all 116 clubs in the top five tiers to begin from 2027/28. This case therefore lands at a formative moment. The Regulator’s test is to be neither silent nor opportunistic: it should not comment on a live disciplinary process it does not own, and it should not use the moment to seek powers it does not need. It should, however, make clear how findings of this kind will be treated within its own regime, and it should use its forthcoming State of the Game work to put the enforcement question on the record. I turn to that next.
The role of the Independent Football Regulator
In my earlier systemic risk papers, I argued that football’s governance problems are best understood through the lens of prudential regulation: the question is not whether a rule was broken, but whether the system was able to see risk building, act on it early, and resolve it before it became systemic. This case is the governance equivalent of a bank failure that the supervisor learned about from the press. The Regulator’s role follows from that framing.
What the Regulator is not
The Regulator is not an appeal body for Premier League disciplinary proceedings, and it should not become one. Under the Football Governance Act 2025, competition rules, including the League’s own financial rules, remain the responsibility of the competition organiser. Re-litigating this case in another forum would add delay, invite forum shopping, and undermine the independence of the commission process that the club itself insisted upon. The Regulator’s legitimacy will depend on the discipline with which it respects that boundary.
What the Regulator should do (IMO)
- Treat adverse findings as material to fitness. The owners, directors and senior executives test should expressly provide that findings of a competition organiser’s disciplinary commission, particularly findings of inaccurate reporting and non-cooperation, are relevant to the assessment of fitness and propriety, with appropriate weight given to appeal status. This applies to individuals, wherever they sit, not only to the club that employed them.
- Establish a formal information gateway with the League. A published memorandum of understanding should govern the exchange of information on investigations, with confidentiality protections, so that the Regulator’s supervision is informed by League enforcement and vice versa.
- Put enforcement capacity into the State of the Game report. The draft report due this year should include an assessment of the timeliness and effectiveness of league-level enforcement across the pyramid, using time-to-resolution as a headline indicator. What is measured is managed.
- Build related-party and remuneration assurance into licensing. Financial plan and corporate governance licence conditions should require specific assurance over associated-party revenue and over all forms of consideration to managers and players, including arrangements with third parties and image-rights vehicles.
- Open a protected whistleblowing channel. Detection in this case depended on a leak. The Regulator should, if it has not already, seek designation as a prescribed person under the Public Interest Disclosure Act 1998, giving club employees and advisers a protected route to disclose concerns.
- Place an auditor reporting duty on the table for the five-year review. In financial services, auditors of regulated firms may and in some circumstances must report matters of material significance to the PRA and FCA. An equivalent channel between club auditors and the Regulator would address the gap between clean audits and inaccurate financial information.
| The Regulator’s credibility in this matter will be built by what it does to make recurrence impossible, not by what it says about a case it does not own. Every recommendation above is prospective and within, or adjacent to, its existing statutory framework. |
Ensuring it never happens again: A prevention agenda
The following measures are addressed to the Premier League and its clubs as rule-makers, with the Regulator’s role noted where relevant. They are designed as a coherent package: detection without speed achieves little; speed without compulsion is unenforceable; and none of it commands confidence without structural independence.
| # | Measure | Failure addressed | Owner |
|---|---|---|---|
| 1 | Transfer investigation and prosecution to a structurally independent integrity unit, with its own budget, board and published reporting, separate from the League’s commercial executive | Structural conflict | Premier League |
| 2 | Binding time standards: charge within 12 months of opening an investigation save exceptional cause; hearing within 9 months of charge; reasoned decision within 6 months of close of hearing, with published reasons for any extension | Delay | Premier League / Judicial Panel |
| 3 | Non-cooperation to be determined as a preliminary issue on an expedited timetable, carrying presumptive sporting sanction | Weak compulsion | Premier League |
| 4 | Limitation to run from discovery, not conduct, where concealment or inaccurate reporting is found | Conduct-based limitation | Premier League (and UEFA) |
| 5 | Mandatory disclosure of all consideration to managers and players, including third-party and image-rights arrangements, with director certification | Detection | Premier League / IFR licensing |
| 6 | Published sanctions guidance with starting points by category, aggravating factors for concealment and non-cooperation, and a clear policy on the treatment of honours and records in future cases | Proportionality and predictability | Premier League |
| 7 | A structured redress framework for claims by affected clubs, administered independently, preserving full entitlement and avoiding serial inter-club litigation | Systemic litigation risk | Premier League |
| 8 | Protected whistleblowing channel and prescribed-person status | Detection | IFR |
Time standards in measure 2 are proposed benchmarks, not derived from any existing rule. They are intended to be demanding but achievable for all but exceptional cases.
On redress
Measure 7 needs a word of explanation, because it could be misread. The Burnley v Everton proceedings established that clubs may recover substantial losses caused by a rival’s breach; that commission assessed Burnley’s loss at £26.0m before interest against a claim of £51.7m, and Everton’s appeal proceeds as of right. If the Manchester City findings are upheld, the potential universe of claimants, clubs relegated, clubs denied European qualification, clubs that finished below City across nine seasons and beyond, is of a different order.
In my earlier work this year, I have argued that uncoordinated inter-club litigation at that scale is itself a systemic risk: years of parallel claims, inconsistent findings, and balance-sheet uncertainty across the league. The answer is not to limit what claimants can recover. It is to ensure they recover it through a single, independent, efficient process rather than a decade of satellite litigation. A redress framework that operated as a cap would be wrong. One that operated as a clearing mechanism would protect claimants and the game alike.
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Recovering the game’s reputation
Football’s reputation is not a brand asset to be managed. It is the accumulated confidence of supporters that what happens on the pitch is decided on the pitch, and of investors, broadcasters and public authorities that the competition is governed with integrity. That confidence has been depleted by this case in two ways: by the conduct alleged and reportedly found, and by the years in which no one could say whether it had occurred.
Recovery depends on four things.
- Publish the reasons in full, promptly. Subject only to necessary redaction, the commission’s decision should be published as soon as the rules allow, as has been the practice in previous Premier League commission cases. A finding of this significance cannot be understood through leaks and summaries.
- Settle the principles before the particulars. The League should state now how it will approach the treatment of titles, records and prize money for future cases, so that the eventual outcome in this one is seen to follow a principle rather than to set one under pressure.
- Give an honest account of the delay. An independent review of the enforcement function, published in full, is the only credible way to answer the question every supporter is asking: why did this take so long?
- Demonstrate change, not promise it. Supporters, many of whom have spent years hearing assurances, will judge the game by its next case, not by its statements about this one. The first time a charge is brought, heard and decided within twelve months will do more for the game’s reputation than any reform announcement.
One further observation. The supporters of Manchester City are not the defendants in this case. Many of them have followed their club through its lowest years, long before 2008. The reputational recovery of the game must include them, and the tone of institutional and public commentary, including from rival clubs, should reflect that the conduct in question was the responsibility of decision-makers, not of those who fill the stands.
Conclusion
English football has, for the first time, a reported finding that its most successful club of the modern era systematically breached the rules on which its competition depends. If that finding survives appeal, the sanction must match it. That is the necessary condition for the game’s recovery. It is not the sufficient one.
The sufficient condition is that the game builds a system in which misconduct of this kind is detected by supervisors rather than by journalists, determined in months rather than years, and sanctioned according to principles published in advance. The Premier League can build much of that system itself, and should begin now. The Independent Football Regulator can ensure it endures, by treating findings seriously within its fitness regime, by insisting on assurance where concealment happens, and by measuring enforcement as rigorously as it measures solvency.
The measure of leadership over the next twelve months will not be what anyone says about Manchester City. It will be whether, when the next case comes, the system works.
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Methodology, caveats and limitations
- This paper is opinion, grounded in public reporting and in the author’s prior published and board-level work. It does not purport to be legal advice.
- The verdict is as reported by The Athletic on 25 September 2026 and subsequently by other outlets citing that report. The Premier League has not confirmed it and the commission’s reasons have not been published. Should the published reasons differ materially from reporting, the analysis in Sections 2 to 4 would need to be revisited; the prevention agenda in Sections 6 and 7 would not.
- The breakdown of charges is taken from the Premier League’s February 2023 announcement. How the 114 reported findings are distributed across those groups, and which charge was not upheld, is not known.
- Elapsed periods are approximate and calculated from publicly reported dates. Attributing delay to any particular party is not possible on public information, and none is attributed here.
- Characterisation of the Independent Football Regulator’s powers reflects the Football Governance Act 2025 and published IFR material as at this date. Several IFR rules and guidance documents remain in consultation or implementation, and the regime is expected to evolve.
- Proposed time standards and other recommendations are the author’s own and are offered for board discussion.
Sources
- The Athletic (David Ornstein), report of 25 September 2026, as carried by Yahoo Sports: “Manchester City found guilty on virtually all of 115 Premier League charges as club prepares to appeal”.
- beIN SPORTS, “Manchester City Receives Verdict on 115 Premier League Charges”, 25 September 2026.
- ESPN, Manchester City statement and sanction range reporting, 25 September 2026.
- Bleacher Report and CNN, reporting of 25–26 September 2026, including the club’s statement.
- Yahoo Sports, “Can Man City appeal against verdict on Premier League’s charges?”, 25 September 2026 (appeal mechanics).
- Premier League statement announcing charges and referral to an independent commission, 6 February 2023.
- Court of Arbitration for Sport award, Manchester City FC v UEFA (CAS 2020/A/6785), July 2020.
- Football Governance Act 2025; Norton Rose Fulbright, “The Independent Football Regulator and the State of the Game Report”, May 2026; Lewis Silkin, “The Independent Football Regulator – an overview”, 21 May 2026.
- Paul Quinn / CWTE Limited, Systemic risk report series (IFR/SOTG/SR/2025/01; IFR/SOTG/FIN/2025/02; IFR/SOTG/FIN/2025/03), including the Manchester City 115-charges systemic risk analysis.
- Paul Quinn / CWTE Limited, Burnley v Everton (PLJP 2023/3) systemic risk and inter-club litigation papers, 2026.