Paul Quinn

CWTE Limited  |  theesk.org

29 September 2026

Primary source: “In the Matter of Premier League Section W Proceedings,  The Football Association Premier League Limited and Manchester City Football Club Limited , Decision” (redacted core decision, 40 pp., 160 paragraphs). Paragraph references in this report (¶) are to that document. The 37 Appendices referred to in the Decision have not been published.

Premier League Manchester-City Independent-Commission-Redacted-Core-Decision document

All of the findings of the Independent Commission are subject to appeal

Summary

The Commission has found every charge proven against Manchester City Football Club Limited (“the Club”) save one sub-charge, Charge 4(B) (¶7, ¶157). The Decision is not a finding of technical or accounting non-compliance. 

It is a finding of intentional, concealed and sustained misconduct across nine consecutive financial years (2009/10 to 2017/18), in which the Club “clearly intended to circumvent the PL Rules” (¶114, ¶121, ¶128, ¶134, ¶140, ¶146), followed by “concerted efforts to stop and frustrate the PL investigation” (¶157).

The core mechanism, which the Commission names the Disguised Funding Scheme , was the routing of owner equity from Abu Dhabi United Group (ADUG) through Abu Dhabi-based sponsors so that it appeared in the Club’s accounts as commercial revenue. 

Of £949.94m recorded as Abu Dhabi sponsorship income over the nine seasons, the Commission found that only £119.25m (12.6%) was paid by the sponsors. The remaining £830.69m (87.4%) was ADUG money (¶72).

Three further categories of device operated alongside it: the Fordham Arrangement (an image-rights vehicle the Commission describes as “little more than a front for ADUG”, ¶85), and three remuneration arrangements under which ADUG met Club liabilities off the Club’s books (¶92–97). 

Taking the figures stated in the Core Decision together, the misstatement of the Club’s profit and loss identified by the Commission is approximately £921m: income overstated by about £855m and costs understated by about £66m (Section 5).

The Decision is the most serious adverse regulatory finding ever made against an English club, and it concerns the most successful one of its era. Three consequences follow from its reasoning, and none depends on the outcome of sanction:

• The league’s financial controls were defeated for nine seasons by a determined, well-resourced owner group using related-party channels.
• External audit did not detect it.
• UEFA’s 2014 settlement and the 2020 CAS process did not reach the substance.

Those are systemic lessons for the Independent Football Regulator (IFR), and they stand whatever happens to the sanction.

The document and the proceedings

What has been published

The document is the Commission’s “Core Decision”. It sets out findings and serves as a roadmap to 37 Appendices, which contain the detailed reasoning, witness assessments, quantification and legal analysis (¶4). The Core Decision and the Appendices “are to be read as a whole” (¶4). Only the Core Decision is available, and it is heavily redacted. The Commissioners’ names, counsel’s names, the identities of AD Sponsors, individuals and arrangements, and most of ¶50, ¶57, ¶69, ¶73(b) and ¶90 are blacked out. So is the entire content following ¶160.

 Instructing solicitors are visible: Bird & Bird LLP for the Premier League and Clifford Chance LLP for the Club.

Scale of the proceedings

Table 1. Procedural scale. Source: Core Decision.

The Commission acknowledges that the time taken to produce the Decision (the hearing closed in December 2024) was “much longer than we would have wished” and “regrettable” (¶18). That gap of more than 21 months is a governance issue in its own right, and it is addressed later in this article.

The Club’s procedural attacks failed

The Club criticised the Premier League’s investigation, its decision to charge, and its conduct of the prosecution. All of these criticisms were rejected as “not justified” (¶36). The Club’s challenges to the league’s competence to bring the Charges as a whole, and Charge 2 in particular, failed. None of its other defences succeeded against any Charge (¶108). Footnote 13 records one qualification: some matters raised by the Club “operate to reduce the extent/degree” of the breaches in certain respects. The detail of that is in the unpublished Appendices, and it matters for sanction.

Findings, Charge by Charge

Table 2. Charge outcomes. Seasons for Charges 2 and 3 are inferred from ¶81 (UEFA submissions 2013/14–2017/18; PSR assessments 2015/16–2017/18); the Core Decision does not list them against each charge. The Charge 4 period reflects the PL investigation opened after November 2018.

The Disguised Funding Scheme

Origins and motive

ADUG, which the Commission describes as a private Abu Dhabi investment company ultimately owned by HHSM, acquired 90% of the Club in September 2008 and the remaining 10% the following year (¶49). It then injected over £190m of equity in its first season and a further £295m in 2009/10 (¶53). This was about £485m in two seasons. By Q3/Q4 2009 the Club had missed its commercial revenue budget and was forecasting very large losses (¶64). It had two stated concerns (¶65):

• Short term: avoiding the record single-season PL loss, then Chelsea’s £140m (2006), which the Club was “adamant it should not break”.
• Longer term: the prospect of UEFA FFP rules under which owner equity would not count as “relevant income” but sponsorship revenue would (fn 5, fn 6).

More owner funding could not solve either problem (¶66). The Commission found that in early 2010 the Club “devised a plan to disguise shareholder funding … as ‘commercial partner revenue’” (¶67).

Mechanics

1. The Club entered into AD Sponsorship Agreements with Recorded Sponsorship Fees “at well above FMV” (¶67(a)).
2. The sponsor was liable for, and paid, only a fraction: the Base Sum (¶63(b)(i), ¶67(b)(i)).
3. ADUG paid the balance: the Tagged Sum (¶67(b)(ii)).
4. The Club booked the full Recorded Fee as commercial revenue and concealed that the Tagged Sum was equity (¶67(c)).
5. Documents were generated to reassure sponsors that their liability would not exceed the Base Fee, and to conceal the Scheme from regulators and auditors “should the need arise” (¶78).

The pyramid sponsorship strategy (¶55) was a genuine commercial plan. The Premier League accepted that two AD sponsorship arrangements, whose identities are redacted, were negotiated at arm’s length and at FMV (¶58, ¶60). Every other AD Sponsorship Agreement was entered into as part of the Scheme (¶71).

Quantification

Figure 1. Recorded AD Sponsorship Fees by true payer, 2009/10–2017/18 (£m). Source: Core Decision ¶72 fn 8; percentages calculated by me.

Table 3. Season-by-season decomposition. The first four columns reproduce the Commission’s table (¶72 fn 8). The last two are Esk calculations. Totals reconcile exactly to ¶72 (£949.94m = £119.25m + £830.69m).

The CPC Explanation

The Club’s case was that the sponsors were always liable for the full fees, and that any shortfall was covered by Abu Dhabi government financial assistance channelled through the “CPC”, in amounts matching the alleged Tagged Sums (¶76). 

The Commission rejected this as untrue and “concocted well after the event” (¶77). It found that the supporting documents were not records of genuine government commitments. They were generated by or on the instruction of a redacted party to reassure sponsors and conceal the Scheme (¶78). Footnote 9 records that the Club did not offer this explanation to third parties who challenged it over the years “until very late in the day”.

Importantly, the Commission declined to decide the Premier League’s case on Abu Dhabi’s two-tier governance system (¶73–75). It did not need to know how or why the Club secured the sponsors’ participation, only that it did. This deliberately narrow finding makes the Decision harder to attack on appeal. It rests on documents and the conduct of the parties, not on contested expert evidence about the structure of the Emirate’s state.

The May 2013 episode

The Commission gives one example of the Scheme in action (¶88–89). An unbudgeted liability of about £20m opened a hole in the 2012/13 accounts. On 25 May 2013, less than a week before year end, the Club identified a £9.9m shortfall against UEFA FFP. “In a matter of days, without AD Sponsors even being approached”, modified sponsorship agreements were generated. They increased fees, added bonuses “for events that had already taken place” and funded a US tour. The shortfall was “plugged”. 

A similar pattern appears at the end of 2009/10, where agreements backdated sponsorship obligations to earlier in the season (¶79, fn 10).

The other devices and the aggregate misstatement

Project Longbow and the Fordham Arrangement

Project Longbow, launched in Q3 2012, was a multi-strand revenue and cost programme driven by UEFA break-even requirements and anticipated domestic FFP rules. The Commission accepted that most strands were legitimate (¶83–84). One was not. Under the Fordham Arrangement, ADUG funded Fordham to buy the Club’s entitlement to players’ image-rights income at a “sizeable, artificially-inflated price”, and then funded Fordham to meet the Club’s image-rights liabilities to players (¶85). This had a double effect. Equity was presented as operating income, and operating costs were removed from the accounts (¶86). The Commission found it was operated with the knowledge and approval of named individuals, whose identities are redacted (¶87).

The remuneration arrangements

Three arrangements (Appendices 16–18) moved Club remuneration liabilities to ADUG through consultancy agreements or unrecorded payments. The amounts were £8.866m, £7.4m and £0.5m (¶93, ¶95, ¶97). All were found to be shams (¶116, ¶123, ¶130). Each was known to and approved by individuals at the Club (¶98). The individuals and counterparties are redacted. This report does not attempt to identify them from press reporting. The rule references (Q/P rules for the first limb; K/T rules and “his contract” for the second) indicate that the first concerns a manager and the second a player, but the Decision itself goes no further.

Aggregate misstatement identified in the Core Decision

Table 4. My aggregation of figures stated in the Core Decision. The Commission itself does not present a single total. ¶101(b) states the App. 16 understatement as “over” £8.866m, so the total is a floor. Footnote 12 notes that £1.5m (2014/15) and £5.625m (2017/18) of the Fordham fee should later have been recorded as unpaid.

Consequences for regulatory compliance

UEFA break-even (Charge 2)

The Club’s break-even submissions for 2013/14 to 2017/18 relied on the full Recorded Sponsorship Fees (¶81(b)). The Scheme let it appear first to be progressing towards compliance, and later to be compliant (¶81(b)). UEFA challenged the 2012 and 2013 reporting periods in 2013/14. 

The CFCB Investigatory Chamber disagreed with the Club’s claim of compliance, but the issue “was never resolved”, and the May 2014 Settlement Agreement followed (fn 11, ¶102). On restatement, the Club failed break-even “by a very substantial amount” in every Charge 2 season, measured against the requirement as varied by that settlement (¶149(b)).

Premier League PSR (Charge 3)

PSR permitted aggregate adjusted losses of no more than £105m over a rolling three-year period (¶43). The Tagged Sums alone for the three PSR windows at issue were:

Table 5. My calculation from ¶72 fn 8. Indicative only: the Club’s reported adjusted earnings before tax (AEBT), permitted deductions, and the Fordham and remuneration adjustments by year are not in the Core Decision.

Removing the Tagged Sums alone takes out between 3.2 and 3.7 times the entire permitted three-year loss in each window. For the Club to remain compliant after restatement, it would have needed reported adjusted profits of approximately £234m–£280m per window before restatement. That is consistent with the Commission’s finding that the failure was “very substantial” (¶153(b)). The Commission also found that the Club would still fail if sponsorship were restated to FMV instead of by removing the Tagged Sums (¶154).

Statutory accounts and audit

The Commission found that the Club’s financial statements for every season from 2009/10 to 2017/18 did not give a true and fair view (¶101). Those were the Club’s audited statutory accounts, submitted to the league under the Accounts Submission Requirement (¶38, ¶81(a)). The auditors were unaware of the Scheme (fn 7, Appendix 22). The related-party failure (Charge 1(D)) means the accounts were not prepared in accordance with applicable principles, even apart from the true-and-fair finding (¶145).

Credibility, concealment and non-cooperation

The Commission’s findings on the witnesses are the most serious in the document for the individuals involved and for the Club’s standing:

• Most factual witnesses were doing their best to give honest evidence. However, evidence from “a number of important factual witnesses called to give evidence on behalf of the Club was false in a number of key respects”, and certain of them “had given evidence at the hearing that they knew to be untrue and so had been dishonest” (¶29).
• The Club asked the Commission to rely on letters and documents from individuals who did not appear. The Commission’s approach and the weight it gave to them are in Appendix 7 (¶31–32). Both parties sought inferences from “missing witnesses” and “missing documents”, and the Commission records that the evidential picture was incomplete (¶24–25).
• The Scheme was “tweaked” over time mainly to keep it concealed and to reduce the risk of “difficult questions” from regulators and auditors (¶71).

On Charge 4, the Club “made concerted efforts to stop and frustrate the PL investigation” (¶157). The Premier League had reserved a further, more serious allegation: that the Club made “inaccurate, dishonest and/or misleading statements” in response to its questions. That allegation was never added to the pleadings, so the Commission made no finding on it (¶158–159).

Sanction, appeal and downstream litigation

Status

The Core Decision decides liability only. It contains no sanction. 

Media reporting as at 29 September 2026 is consistent with that: no sanction has been imposed, the Club has signalled its intent to appeal, and the chairman has told supporters that the Club’s “confidence and intent in proving the club’s innocence is just as strong as when this began”.

 Under the PL Rules, a Commission’s sanctions powers are open-ended. They include fines, points deductions, suspension, expulsion and “such other penalty as [it] shall think fit”. There is no fixed tariff.

Sanction drivers visible in the core decision

Table 6. Sanction factors. My assessment; the Commission has not stated its approach to sanction in the published text.

Assessment. The Everton and Nottingham Forest PSR cases involved single-window overspends without findings of dishonesty. They produced points deductions. On any principled read-across, a nine-season intentional scheme, compounded by concealment and obstruction, sits far above those cases. The realistic range is a heavy points deduction applied prospectively, together with a substantial financial penalty. Relegation or expulsion is at the far end of the Commission’s powers. 

The difficulty is not whether the conduct is serious enough.

 It is proportionality and the practical impact on third parties, including players, other clubs and broadcast contracts. Retrospective stripping of titles is legally and practically harder, and it is not addressed in the Core Decision.

Appeal

Reporting indicates a 14-day window for appeal to a three-member Appeal Board. There is further talk of a High Court challenge on procedural fairness grounds. Two features of the Decision narrow the Club’s appeal options:

• It rests on primary documents and findings about witness credibility, which appellate bodies are slow to disturb.
• It deliberately avoided deciding the contested questions about Abu Dhabi governance (¶75).

The Club’s strongest arguments are likely to be procedural: delay, redaction and the handling of “missing” evidence. Those arguments go more naturally to sanction than to liability.

Damages claims by other clubs

Clubs that finished below Manchester City, lost prize money or European places, or were themselves sanctioned under PSR during the relevant seasons now have a first-instance finding of intentional breach to rely on. The Burnley v Everton compensation claim under the PL Rules is the working precedent for PSR-based claims between clubs. The City findings are of a different order of magnitude, covering nine seasons and titles won. Causation and quantum will be heavily contested. But liability is no longer the obstacle.

Systemic implications for the IFR and the League

1. Related-party channels. The Scheme worked because owner-connected parties could present equity as revenue. The Associated Party Transaction (APT) regime, the Football Governance Act owner and financial tests, and IFR monitoring must be able to test who ultimately funds a sponsor’s payment, not just whether the headline price is at FMV. On the Commission’s alternative case, an FMV test alone would still have caught the breach (¶150, ¶154), but only after years of litigation.
2. External audit is not a sufficient control. The auditors were deceived for nine years (fn 7). The IFR should consider its own information-gathering powers. These include direct confirmation of funding sources from counterparties and sponsor-side attestations, and they should not rely on audit opinions for related-party substance.
3. Settlements without findings create a record of silence. UEFA’s 2014 settlement left compliance “never resolved” (fn 11). The Scheme continued for four further seasons. Regulators should be wary of settlements that suspend enquiry into the substance of related-party funding.
4. Obstruction must carry its own cost. Charge 4 has been proven. The league’s case management, and any IFR equivalent, should make delay and non-disclosure more costly than the underlying exposure. Otherwise a well-funded club has an incentive to litigate the process rather than the facts.
5. Time is itself a harm. More than three and a half years from charge to liability decision, and 21 months from the end of the hearing to decision (¶18), leaves competitions, clubs and commercial partners exposed to prolonged uncertainty. A regulatory framework that cannot reach a liability decision within the same economic cycle as the breach will struggle to deter.

Caveats and data limitations

• Core Decision only. The 37 Appendices, which hold the detailed reasoning, witness assessments, FMV analysis and restated break-even and PSR figures, are not published. All conclusions here are limited to what the Core Decision states.
• Redactions. Individuals, sponsors, counterparties, arrangement names, the seasons for several limbs, and everything after ¶160 are redacted. This report does not identify redacted parties from press reporting, and deliberately does not do so for ¶70.
•  The ADUG share percentages, multiples, compound growth rate, aggregate misstatement (Table 4) and PSR window sums (Table 5) are derived by me from figures stated in the Decision. Table 5 ignores permitted PSR deductions, the Club’s reported AEBT and the Fordham and remuneration adjustments by year. It is illustrative, not a restated PSR computation.
• Charge count. The “114 of 115” figure comes from press reporting. The Decision does not state a count.
• First-instance status. These are findings of a Section W Commission and are subject to appeal. Sanction, appeal and procedural information in Section 8 comes from contemporaneous media reporting, not from the Decision.
• Not legal advice. This is analytical commentary for board discussion.

Sources

Primary: Premier League Section W Proceedings, The Football Association Premier League Limited v Manchester City Football Club Limited, Decision (redacted Core Decision), 40 pp.

• Premier League, statement on referral of Manchester City to a Commission (6 February 2023) – premierleague.com/en/news/3045970

• Al Jazeera, “Man City’s Premier League charges: What’s the latest and what comes next?” (29 September 2026)

• Al Jazeera / Reuters, “Man City found guilty on almost all 115 Premier League charges: Report” (25 September 2026)

• Sky Sports, “Man City Premier League charges: What does the appeals process look like and what happens now?” (September 2026)

• CBS Sports, “What’s next for Manchester City? Appeal process and penalties” (September 2026)

• beIN Sports, “Manchester City Receives Verdict on 115 Premier League Charges” (25 September 2026)

• The Esk, “The Analysis Series: Manchester City v The Premier League: The ‘115 Charges’ case” (30 April 2026)