The Analysis Series: Premier League v Manchester City, Potential civil claimants & hypothetical criminal exposure arising from the Independent Commission Core Decision

30th September 2026

Paul Quinn ; CWTE Limited

Author	Paul Quinn, The Esk / CWTE Limited
Date	30 September 2026
Classification	Analytical commentary . Not legal advice.
Status of findings	First-instance Section W findings, subject to appeal (deadline 2 October 2026)

 

STRICT CAVEAT: PRESUMPTION OF INNOCENCE The findings described in this paper are first-instance findings of a Premier League Section W Independent Commission, made on the civil balance of probabilities under a private disciplinary regime. They are subject to appeal and Manchester City denies all wrongdoing. “Guilty” is the Premier League’s disciplinary terminology and does not denote criminal guilt. The criminal-law analysis is strictly hypothetical. It makes no allegation that any individual, director, executive, owner or counterparty has committed any criminal offence, and identifies no individual whose identity the Commission redacted. No individual has been charged, arrested or, to public knowledge, investigated.

 

Summary

SUMMARY: HEADLINE CONCLUSION The claims most likely to succeed against Manchester City are compensation claims brought by rival Premier League clubs under the League’s own Section W compensation machinery. These are strongest for the UEFA break-even and PSR seasons of 2013/14 to 2017/18, and the Burnley v Everton award of £35.0m is now the working template. Almost every other category of claimant (players, agents, sponsors, broadcasters, bettors, fans, European clubs) faces obstacles on causation, standing or forum that in most cases make a claim unviable. Criminal exposure for any individual is entirely hypothetical, and no referral or investigation is publicly known.

 

On 29 September 2026 the Premier League stated that an independent Commission had found Manchester City guilty of all charges relating to serious breaches of the League’s financial rules over nine seasons, and the majority of charges relating to its failure to co-operate. The outcome leaked on 25 September via The Athletic (“114 of 115”). The Core Decision itself does not state a count; it records all charges proven “bar Charge 4(B)”. No sanction has yet been imposed.

The Commission found that City arranged “sham” commercial deals with a number of sponsors as part of a disguised funding scheme: sponsors paid only a portion of the fees and ADUG funded the rest, inflating revenues and reducing costs by more than £900 million. Of £949.94m of recorded Abu Dhabi sponsorship income, £830.69m (87.4%) is found to have been ADUG money.

Liability is not the obstacle; causation and forum are. For rival clubs, the Core Decision supplies a first-instance finding of intentional breach, which is exactly what Burnley had against Everton. The contest will be over the counterfactual (what a compliant City would have spent and achieved), causation, limitation and quantum.

Strongest claimant class. Premier League member clubs claiming Champions League qualification and merit-payment losses in the UEFA break-even seasons (2013/14–2017/18) and the PSR seasons (2015/16–2017/18). Title-race claims are emotionally powerful but financially narrower than assumed: the direct merit differential for one place was between £755,062 and £1,931,268 in the relevant seasons.

Headline quantum. The merit-payment-only ceiling is about £163.4m before interest (every club below City moving up one place in every season 2011/12–2017/18), or roughly £187m including the two earlier seasons on assumed rates. Champions League and consequential losses sit on top and are club-specific. Reported figures of “over £200m” for individual clubs are unsourced and at the extreme upper end.

Criminal exposure. As at 30 September 2026 there is no public referral to, or statement from, the SFO, police, HMRC, the FRC, the Insolvency Service, the Independent Football Regulator or UEFA. Criminal proceedings are a remote contingency, not a base case.

Recommendation. Boards of potentially affected clubs should now (i) confirm their limitation position, including whether a protective notice was lodged; (ii) commission season-by-season counterfactual modelling on the Burnley v Everton methodology; and (iii) keep claims inside the Premier League’s arbitral machinery unless they need to join third parties such as ADUG or the sponsors.

Methodology and sourcing

Primary sources

• Premier League statement of 29 September 2026 and notes to editors.
• Redacted Core Decision (40 pp., 160 paragraphs), as analysed paragraph by paragraph in the CWTE/Esk analysis of 29 September 2026.
• Burnley v Everton Compensation Summary of Decision (PLJP 2023/3, Rule W.51.5, 2 June 2026).
• CAS 2020/A/6785 award, as reported; UEFA distribution releases; Premier League central-payment figures as reported by Sporting Intelligence from official Premier League tables.

Limitations

CAVEAT: DATA LIMITATIONS The 37 Appendices are unpublished. Sponsor, individual and arrangement identities are redacted, as is everything after ¶160. Rule references such as W.51 follow the numbering used in the Burnley v Everton award; the 2026/27 Handbook has not been verified. League positions are taken from standard published final tables and should be re-verified before any pleading. Percentages, the c.£921m aggregate and the PSR window multiples are my calculations, not Commission findings. Only Arsenal, Liverpool, Manchester United and Tottenham are named in reporting as having reserved compensation rights. The “8–10 clubs” figure could not be verified. Merit-payment-per-place figures for 2009/10 and 2010/11 were not located; about £0.75m per place is assumed.

 

Where media or commentators predict outcomes (sanctions, claim values, class actions), those are labelled as predictions.

Verified status of the proceedings

Chronology

Date	Event
Nov 2018	Der Spiegel “Football Leaks” publications. Premier League opens investigation in December 2018.
14 Feb 2020	UEFA CFCB Adjudicatory Chamber bans City from UEFA competitions for two seasons and fines it €30m for overstating sponsorship revenue between 2012 and 2016.
13 Jul 2020	CAS (2020/A/6785) lifts the ban: most alleged breaches either not established or time-barred; fine reduced to €10m for non-cooperation. Etisalat-related charges time-barred under UEFA’s five-year limitation.
6 Feb 2023	Premier League refers City to an Independent Commission under Section W.
16 Sep – 6 Dec 2024	42-day hearing: 34 days of evidence, 27 factual witnesses, c.7,000 pages of transcript. Bird & Bird for the Premier League; Clifford Chance for City, advocacy led by Lord Pannick KC.
14 Nov 2024	Arsenal, Liverpool, Manchester United and Tottenham reportedly lodge notices reserving compensation rights (The Times).
8 Sep 2025	City and the Premier League settle the second APT arbitration; City accepts the current APT Rules are “valid and binding”.
2 Jun 2026	Burnley v Everton compensation decision: £35.0m including interest.
25 Sep 2026	The Athletic reports the verdict (“114 of 115”).
29 Sep 2026	Premier League publishes the redacted Core Decision, stating the Commission has ruled (and an Appeal Board confirmed) that it is a “final award”.
2 Oct 2026	Deadline for City to lodge an appeal.

 

Charges proven and not proven

Charge	Subject	Seasons	Outcome
1(A)	Abu Dhabi sponsorship agreements; accounts not true and fair	2009/10–2017/18	Proven (sham; knowing or reckless)
1(B) limb 1	Remuneration arrangement (App. 16), £8.866m; Q/P rules, indicating a manager	4 seasons	Proven (sham)
1(B) limb 2	Remuneration and image-rights arrangement (App. 17), £7.4m; K/T rules, indicating a player	6 seasons	Proven (sham)
1(B) limb 3	Consultancy arrangement (App. 18), £0.5m	1 season	Proven (sham)
1(C)	Fordham image-rights arrangement (“little more than a front for ADUG”)	Redacted	Proven
1(D)	Non-disclosure of related-party transactions	9 seasons	Proven
2	UEFA break-even (via PL Rule B.14.6)	2013/14–2017/18 (inferred)	Proven: failed by a very substantial amount every season
3	PL Profitability and Sustainability Rules	2015/16–2017/18	Proven: failed by a very substantial amount every season
4(A), 4(C), 4(D)	Non-cooperation, 2018–2023	—	Proven
4(B)	Non-cooperation	—	Not proven

 

Additional findings relevant to downstream claims:

• Evidence from certain Club witnesses was found false in a number of key respects, and some witnesses were found to have knowingly given untrue evidence and so been dishonest (¶29).
• The Club’s “CPC Explanation” was found to have been “concocted well after the event” (¶77).
• Regulators, and even the Club’s auditors, were unaware of the Scheme (¶68, fn 7).
• The Premier League reserved, but never pleaded, a further allegation of inaccurate, dishonest and/or misleading statements; the Commission therefore made no finding on it (¶158–159).
• ¶70 finds no direct evidence that a redacted individual knew of or authorised the Scheme.

NOTE: MANCINI / AL JAZIRA Press reporting has long linked the manager remuneration arrangement to Roberto Mancini and a consultancy with Al Jazira. The Decision redacts identities, and this paper does not treat press identification as established.

 

Sanction, appeal and forum

• Sanction: not yet decided. It will be addressed separately at a further private hearing before the Commission. Powers are open-ended: fines, points deductions, suspension, expulsion and other sporting sanctions. There is no tariff.
• Appeal: City has confirmed it will appeal to a three-member Appeal Board appointed by the Chair of the Judicial Panel, Sir Gary Hickinbottom, and chaired by a former judicial office-holder. The Board may allow the appeal, dismiss it, or make any other order it thinks fit.
• No CAS route is available to City.
• Possible court route: Sky Sports reports City could go to the High Court arguing the process was not fair and impartial. The “final award” terminology suggests Section W proceedings are arbitral for Arbitration Act 1996 purposes, so realistic routes are s.67 (jurisdiction) or s.68 (serious irregularity) challenges, both with high thresholds.
• City’s position (29 September 2026): the club says it is innocent, that a comprehensive body of irrefutable evidence supports its positions, and that it will be relentless and, where necessary, proactive in all appropriate regulatory and legal forums. Khaldoon Al Mubarak told supporters that “nothing has changed”.

Related litigation

• First APT arbitration (October 2024): parts of the APT regime found unlawful, including the exclusion of shareholder loans; the Premier League’s fair-market-value decisions on City’s 2023 Etihad Aviation Group and First Abu Dhabi Bank deals set aside as procedurally unfair. The tribunal nonetheless endorsed the APT concept. A subsequent award declared the rules void as a whole.
• Second APT arbitration: filed February 2025 (Freshfields), settled 8 September 2025.
• Significance: the APT litigation is closed, but City’s competition-law arguments there (including abuse of dominance by the Premier League) show the kind of “proactive” counter-litigation it may deploy against sanction or compensation claims.

The legal architecture for claims

The Premier League compensation route (Section W / Rule W.51)

• The mechanism: Burnley’s claim was brought under Rule W.51.5 before a Premier League Independent Disciplinary Commission (PLJP 2023/3) chaired by David Phillips KC, with HH Alan Greenwood and Nick Igoe ACA. This is the natural forum for member-club claims against City: confidential, specialist and binding under the members’ contract.
• Early notice: in the Everton PSR case the Commission gave Leeds, Nottingham Forest, Southampton, Leicester and Burnley 28 days to say whether they intended to claim. A similar direction in the City sanction decision would be a strong procedural signal and should be watched for.
• Members’ contract: the Premier League Rules operate as a multilateral contract between the League and its members. A breach of the financial rules is therefore, in principle, a breach owed to the other members; this was the conceptual basis of Sheffield United v West Ham.
• Section X arbitration: club-to-club disputes go to arbitration, effectively excluding the courts. Non-members (ADUG, sponsors, European clubs, players) are not bound, so claims against them must go to court.

Lessons from Burnley v Everton (2 June 2026)

• Counterfactual: must be “practical and realistic”. Everton’s minimum-change scenarios were rejected; the only realistic counterfactual was earlier generation of £19.5m in player-sale profit.
• Timing of breach: a PSR breach relates to the playing season, not the financial year-end, closing off a timing defence City might otherwise run.
• Causation modelling: Burnley’s experts, Professor Rob Wilson and Will Daniels, regressed points on player-related expenditure for 2012/13–2023/24, estimating the £19.5m overspend at 3.85–7.13 points, and ran 100,000 season simulations. Causation was accepted on the balance of probabilities even on the conservative scenario.
• Quantum: Burnley claimed £51.7m (Richard Boulton KC); Everton’s expert said Burnley had in fact gained £6.8m or £18.1m. The Commission awarded £26.0m before interest (£24.6m operating profit, £1.4m player trading), plus £9.1m interest to 31 July 2025, totalling £35.0m, with interest continuing at 11.81% a year.

KEY FINDING: READ-ACROSS TO MANCHESTER CITY Causation models of this kind are admissible and persuasive. Interest at that rate over a 10–15-year horizon can rival or exceed the principal loss. The yardstick is lost profit including player trading, not headline revenue. This substantially shrinks gross revenue claims.

 

Sheffield United v West Ham (Tevez)

West Ham was fined £5.5m in 2007 for third-party ownership breaches over Carlos Tevez and Javier Mascherano but not deducted points; Sheffield United was relegated on the final day of 2006/07. An arbitral tribunal found for Sheffield United on 23 September 2008, and the clubs settled on 16 March 2009. Sheffield United initially valued its claim at £45m; the settlement was reported at around £20m, paid over five years.

• Arbitral panels will accept that a rule breach conferring sporting advantage caused a specific league outcome.
• Settlements tend to land well below headline claims: about 44% of the reported £45m (higher if the claim was nearer £30m, as some sources suggest).

Other causes of action

Cause of action	Principal use	Key hurdle
Breach of members’ contract / W.51	Member clubs	Counterfactual, causation, limitation
Unlawful means conspiracy	Reaching ADUG and sponsors (non-members); court forum	Intention to injure the claimant. Rivals’ loss is arguably the other side of the same coin as City’s gain, but this is contested.
Deceit	Parties to whom representations were made (PL, UEFA, auditors)	Rival clubs were not the representees and did not rely on the statements
Unjust enrichment	Recovery of merit or central payments	“At the claimant’s expense” requirement; more naturally a League-level redistribution question
Competition law (Ch I/II CA 1998; Arts 101/102 TFEU) in the CAT	Collective or opt-out claims	The conduct is rule-evasion, not an anti-competitive agreement or abuse. Novel and weak.

 

Limitation: the critical gateway

• Basic periods: six years for contract and tort (Limitation Act 1980, ss.2 and 5). For 2009/10–2017/18 conduct, every claim is time-barred unless the period is postponed.
• Postponement for concealment: s.32(1)(b) postpones the period where a fact relevant to the right of action has been deliberately concealed, running from actual or reasonably discoverable knowledge. Under s.32(2), deliberate breach in circumstances where it is unlikely to be discovered for some time counts as deliberate concealment.
• Effect of the findings: findings of concealment from auditors and regulators (¶68 fn 7, ¶71, ¶78) are close to ideal s.32 material, subject to the Supreme Court’s strict reading in Canada Square Operations Ltd v Potter [2023] UKSC 41.
• Trigger date: clubs were reportedly advised time could run from November 2018 (Der Spiegel), explaining the November 2024 protective notices. Clubs that did not act by then face a serious limitation defence. The counter-argument is that the true extent of the scheme (the Tagged Sums, Fordham) was not reasonably discoverable until the Core Decision.

KEY FINDING: MOST IMPORTANT VARIABLE Limitation is the single most important variable in separating viable claimants from non-viable ones.

 

Claimant-by-claimant analysis

English clubs (Premier League members)

Verified preserved claimants: Arsenal (reportedly first), Liverpool, Manchester United and Tottenham Hotspur, whose notices were reportedly lodged in November 2024. The Athletic reports further clubs planning action and discussion of a coordinated or “class” approach. No verifiable public report supports the “8–10 clubs” figure; treat it as unconfirmed.

The causation distinction boards must understand. The breaches fall into two economically different phases.

KEY FINDING: PHASE 1 (2009/10–2012/13): MISREPORTING WITHOUT A BINDING DOMESTIC CAP The Premier League had no loss limit until PSR, first assessed in 2015/16. UEFA break-even monitoring began with periods from 2011/12. Accurate reporting would not necessarily have reduced City’s spending, because ADUG could lawfully inject equity. The realistic counterfactual is a City that spends much the same but reports honestly. That weakens sporting-advantage causation for the 2011/12 title, lost by Manchester United on goal difference, despite the narrow margin. The better argument here is indirect: accurate figures would have exposed City to earlier and harsher UEFA sanctions from 2013/14.

 

KEY FINDING: PHASE 2 (2013/14–2017/18): THE UEFA AND PSR SEASONS The counterfactual mirrors Everton: a compliant City would have had to cut spending very substantially. The Tagged Sums alone in each PSR window were 3.2–3.7 times the entire £105m permitted three-year loss. On the scale of the Burnley v Everton model, an overspend of this size plausibly moves City by tens of points per season (CWTE extrapolation, not a finding; returns on spending are not linear at the elite end). City could therefore have dropped out of the title race and, in some seasons, out of the top four.

 

Season map (City’s final position and most directly affected rival):

Season	City	Most exposed rival claim (illustrative)	Tractability
2009/10	5th	Minimal; City outside the top four	Very low
2010/11	3rd	Tottenham (5th) as CL-place claimant; Phase 1 causation	Low
2011/12	1st (GD)	Manchester United (title); Phase 1 causation	Low–moderate
2012/13	2nd	Tottenham (5th, one point off 4th) as CL-place claimant	Low–moderate
2013/14	1st	Liverpool (2nd, two points); Everton (5th) as CL-place claimant	Moderate
2014/15	2nd	Tottenham (5th); Liverpool (6th)	Moderate
2015/16	4th (GD over Man Utd)	Manchester United (missed CL on goal difference)	Moderate–high
2016/17	3rd	Arsenal (5th, one point off 4th)	Moderate–high
2017/18	1st	Manchester United (title, 19 points behind); Chelsea (5th) as CL-place claimant	Moderate (CL), low (title)

 

Positions are from standard final tables and should be verified before pleading.

• Relegated clubs (2009/10–2017/18): very weak. City was never near the relegation places, and the “inflated market” theory lacks the club-specific causal chain Burnley v Everton requires.
• 2018/19 onwards: Liverpool finished one point behind City in 2018/19 and 2021/22, but these seasons are outside the charged period. Any claim would have to argue a legacy squad advantage built with disguised funding: novel and very hard to prove.
• Chelsea: a potential CL-place claimant for 2017/18, but its own record may temper its appetite. In March 2026 the Premier League fined Chelsea a record £10.75m with a suspended transfer ban over £47,524,925.74 of undisclosed payments (2011–2018) by third parties linked to Roman Abramovich, self-reported by the current owners. Chelsea also paid UEFA €10m in July 2023 for incomplete financial reporting covering 2012–19.
• Former members: clubs no longer in the Premier League, such as Stoke, may face standing arguments under Section W. Burnley suggests status at the time of loss matters more than at the time of claim, but the point is untested for historic members.

The Premier League

The League’s main route is costs recovery and financial sanction within Section W, not damages. A contractual claim for reputational or commercial damage is theoretically available but improbable, given that broadcast revenues grew throughout the period and a fine is the more efficient instrument. Redistribution of merit payments paid to City faces the same which-clubs, which-seasons problem as the compensation claims, and the Rules do not obviously provide for it.

The EFL

City won the League Cup in 2014, 2016 and 2018, but the EFL has not charged City and prize differentials for losing finalists are small. Parachute and solidarity effects flow from the bottom of the table, which City did not affect. The EFL’s exposure is mainly operational (where an expelled or relegated City would play), not as claimant. Prospect: very low.

The FA, FIFA and UEFA

• FA: City beat Stoke in the 2011 FA Cup final; Tony Pulis has said his team was “cheated”. Stoke still gained Europa League entry as runners-up, the final falls in Phase 1, the FA has not charged City, and prize differentials are modest. Community Shield claims are negligible.
• FIFA: City’s Club World Cup participation fell outside the charged period. No realistic claim.
• UEFA as damages claimant: UEFA distributes by formula and suffered no obvious loss of its own; other clubs lost distributions.
• UEFA as regulator: faces the CAS 2020 award and its time-bar reasoning; its own five-year limitation, which has expired for conduct to 2017/18; the 2014 Settlement Agreement (under which the CFCB disagreement was never resolved, Core Decision fn 11); and ne bis in idem principles. No UEFA statement had been found as at 30 September 2026. Prospect: very low for damages; low for disciplinary action on historic conduct.

UEFA Champions League distribution benchmarks:

Season	Group fee	Win / draw	R16	QF	SF	Final (RU / W)
2013/14–2014/15	€8.6m	€1m / €0.5m	€3.5m	€3.9m	€4.9m	€6.5m / €10.5m
2015/16	€12m	€1.5m / €0.5m	€5.5m	€6m	€7m	€10.5m / €15m
2016/17–2017/18	€12.7m	€1.5m / €0.5m	€6m	€6.5m	€7.5m	€11m / €15.5m

 

Market-pool (TV) payments are additional and club-specific.

European clubs

Clubs eliminated by City in knockout ties, and group rivals who finished behind City, should be identified from official records. England held four Champions League places throughout, so association-level displacement is negligible. These clubs are not bound by the members’ contract and would need to sue in the English courts, most likely for unlawful means conspiracy, facing Rome II applicable-law complexity and s.32 arguments. Showing that a single tie was decided by disguised funding is far harder than showing a season-long points effect. Prospect: very low.

Players

• Rival players: those who lost title or CL bonuses (Manchester United’s 2011/12 squad being the obvious example) have no contract with City. Pure economic loss in tort requires unlawful means conspiracy with intention to injure them specifically. Prospect: very low. Medals and recognition are sporting-governance matters, not damages.
• Former City personnel: more likely to face exposure than to claim. The App. 16 and App. 17 arrangements (£8.866m and £7.4m) were found to be shams whose terms should have been in the contract. Recipients could face HMRC enquiries (see 5.10), and would be claimants only if promised sums went unpaid.

Agents, intermediaries, and rival managers and coaching staff

Agents who lost commissions and rival managers dismissed after missing targets have no contract with City and no viable causal chain; their losses flow from their own clubs’ decisions. Prospect: nil to very low. Intermediaries connected to the sham arrangements (Fordham and the consultancy counterparties) are potential defendants or witnesses, not claimants.

Commercial partners and sponsors

• City’s Abu Dhabi sponsors: redacted in the Decision; earlier press and CAS reporting identified them as including Etihad, Etisalat and Aabar. They paid only the Base Sum (£119.25m of £949.94m), suffered no loss, and are more exposed than aggrieved. Owner-linked partners are, in effect, paying themselves.
• City’s independent sponsors and kit partners: may hold morality or reputational termination rights. Termination or renegotiation is more likely than damages and depends on unseen contract terms.
• Rival clubs’ sponsors: paid less when their club underperformed; they benefited rather than lost. No claim.
• Broadcasters: received the product contracted for from the Premier League. Prospect: nil.

Shareholders, investors and lenders

• Silver Lake: bought just over 10% of City Football Group for US$500m in November 2019 (valuing CFG at US$4.8bn), after the Der Spiegel revelations and during the UEFA investigation. Any warranty or misrepresentation claim would face disclosure, knowledge and contractual limitation provisions.
• CMC / CITIC consortium: agreed on 1 December 2015 to invest US$400m for just over 13% of CFG (valuing it at US$3bn); later reporting of about 12% may reflect dilution. Having invested earlier, it is in principle better placed on knowledge.
• Likely remedy: both minority investors have strong commercial reasons not to sue their majority partner; exit pricing is the realistic lever, not litigation.
• Lenders: City’s lenders may face covenant questions if sanctions bite. Lenders to rival clubs have no standing.

HMRC

HMRC’s interest would focus on whether the off-contract remuneration (App. 16–18) was in substance employment income subject to PAYE and NICs, and on the characterisation of the Fordham image-rights payments (£49.414m of expenses understated). Kieran Maguire observes that there is no corporation tax to recover because football clubs lose money. HMRC’s extended assessment limit for deliberate conduct is 20 years (TMA 1970, s.36(1A)), so periods from 2009/10 remain reachable in principle. A civil tax enquiry is more plausible than any other public-body action in this paper. No statement or referral is known.

Bettors, betting operators and fans

Bookmakers settle on official results and bettors have no cause of action. Commentary suggesting every Sky Sports subscriber has a claim is rhetorical: a CAT opt-out collective action requires a competition-law infringement, and fans paid for, and received, the matches. Prospect: nil to very low.

Summary risk and prospect matrix

Claimant	Cause of action	Forum	Limitation	Causation	Indicative quantum (pre-interest)	Prospect
Man Utd (2015/16 CL; 2017/18)	Members’ contract / W.51	PL Commission	Preserved (Nov 2024)	Moderate	Tens of £m	Moderate–high
Arsenal (2016/17 CL)	Members’ contract / W.51	PL Commission	Preserved	Moderate	Tens of £m	Moderate–high
Liverpool (2013/14 title; 2014/15)	Members’ contract / W.51	PL Commission	Preserved	Moderate–high	£m to low tens of £m	Moderate
Tottenham (2010/11, 2012/13, 2014/15 CL)	Members’ contract / W.51	PL Commission	Preserved	High (Phase 1)	Tens of £m if successful	Low–moderate
Chelsea (2017/18 CL)	Members’ contract / W.51	PL Commission	Not known preserved; s.32 needed	Moderate	Tens of £m	Low–moderate
Everton (2013/14 CL)	Members’ contract / W.51	PL Commission	Not known preserved	Moderate–high	Tens of £m	Low
Other PL clubs (one-place merit uplift)	Members’ contract / W.51	PL Commission	Mostly unpreserved	Moderate	£0.76m–£1.93m per place per season	Low
Relegated clubs 2009–18	Contract / conspiracy	PL / court	Unpreserved	Very high	Speculative	Very low
Premier League	Costs; sanction; contract	Section W	N/A	N/A	Costs plus fine	High (costs)
EFL / League Cup finalists	Contract / tort	Court / EFL	Unpreserved	High	Small	Very low
Stoke (2011 FA Cup)	Tort	Court	Unpreserved; Phase 1	Very high	Small	Very low
UEFA	Disciplinary; damages	UEFA / CAS	Time-barred	N/A	N/A	Very low
European clubs	Unlawful means conspiracy	English court	s.32 needed	Very high	Per-round UEFA sums	Very low
Rival players / managers / agents	Tort	Court	s.32 needed	Very high	Bonus sums	Very low / nil
City’s AD sponsors	—	—	—	—	—	Nil (exposure)
Independent sponsors	Contract (morality clauses)	Court / arbitration	Contract-specific	Low	Termination value	Low
Silver Lake / CMC	Warranty / misrepresentation	Contractual forum	Caps likely	Moderate	Unknown	Low
Broadcasters, bettors, fans	Contract / competition law	CAT / court	Various	Extreme	—	Nil to very low
HMRC	Tax assessment (civil)	Tax tribunal	20-year deliberate limit	Low–moderate	Unknown	Moderate (enquiry)

 

Quantum: Transparent assumptions

Premier League merit payments (per place)

Season	Merit per place	Source
2011/12	£755,062	Sporting Intelligence (official PL table)
2012/13	£755,881	Sporting Intelligence
2013/14	£1,236,083	Sporting Intelligence
2014/15	£1,244,898	Sporting Intelligence
2015/16	£1,242,405	Sporting Intelligence
2016/17	£1,941,609	Sporting Intelligence
2017/18	£1,931,268	Sporting Intelligence / PL release

 

2009/10 and 2010/11 figures not located; about £0.75m per place assumed by extrapolation.

Scenario A: the “City-absent” merit ceiling

Every club below City moves up one place in every season.

Season	Clubs below City	Uplift
2011/12	19	£14.35m
2012/13	18	£13.61m
2013/14	19	£23.49m
2014/15	18	£22.41m
2015/16	16	£19.88m
2016/17	17	£33.01m
2017/18	19	£36.69m
Total 2011/12–2017/18		£163.4m
Add 2009/10 (15 clubs) and 2010/11 (17 clubs) at assumed £0.75m		≈ £24m
Indicative nine-season ceiling		≈ £187m

 

CAVEAT: READING THE CEILING This is a ceiling on merit money only, spread across all clubs. It overstates any realistic award, because a compliant City would probably still have finished high in many seasons, but understates individual clubs’ positions because it excludes Champions League revenue and consequential losses. Current-cycle estimates of about £3m per place do not apply to the charged seasons.

 

Scenario B: Champions League qualification (the real value driver)

• UEFA fixed amounts: for a club displaced in 2016/17 or 2017/18, a €12.7m participation fee plus €1.5m per group win, with knockout rounds adding €6m (R16), €6.5m (QF) and so on.
• Market pool: club-specific TV money comes on top.
• Net approach: Burnley v Everton requires lost operating profit (after squad costs and bonuses) plus player-trading effects, net of any Europa League revenue actually earned.
• Indicative range: a realistic net single-season CL-loss claim of £20m–£50m before interest, depending on progression and market pool (CWTE estimate, not a sourced figure).

Scenario C: title claims

The direct merit value of first place over second was £755,062 (2011/12), £1,236,083 (2013/14) and £1,931,268 (2017/18). Title-contingent sponsor bonuses are real but contract-specific, and partly offset by the title bonuses the claimant would itself have paid its players. Title claims are therefore mainly reputational: financially, single-digit to low-double-digit millions per season unless boosted by proven commercial clauses.

Interest and the “£200m” reports

• Interest: at the 11.81% rate applied in Burnley v Everton (set by that Commission, not a rule), interest on a 2015/16 loss could approach or exceed the principal by 2027.
• The “£200m” reports: The Independent reported claims potentially worth over £200m to some claimant clubs, attributed only to unnamed sources. That is achievable only for a club combining several CL seasons, heavy consequential losses and long-running interest. Treat it as an upper-bound scenario, not a central estimate.
• Settlement read-across: Sheffield United’s settlement at about 44% of its reported claim is a useful benchmark for settlement discounts.

Hypothetical criminal exposure of directors and executives

 

STRICT CAVEAT: STRICTLY HYPOTHETICAL This section is an abstract legal mapping exercise. It does not allege that any person committed any offence. The Commission’s findings are civil findings on the balance of probabilities, made in a private process, subject to appeal, and redacted as to identities. Criminal liability requires proof to the criminal standard (the tribunal of fact must be sure), admissible evidence, individual culpability, and dishonesty as tested by Ivey v Genting [2017] UKSC 67 and R v Barton and Booth [2020] EWCA Crim 575. ¶70 of the Core Decision records no direct evidence that one redacted senior individual knew of or authorised the Scheme.

 

Offence mapping

Offence	Elements (summary)	Hypothetical fit to civil findings	Key obstacles
Conspiracy to defraud (common law)	Dishonest agreement to prejudice another’s rights or deceive a person performing a public or regulatory duty	Closest conceptual fit to a multi-party scheme to deceive regulators and auditors	Proof of each individual’s agreement and dishonesty; cross-border parties; CJA 1993 Part 1 jurisdiction
Fraud by false representation (Fraud Act 2006 s.2; from 15 Jan 2007)	Dishonest false representation intending gain or loss in money or property	Representations to UEFA and the PL in accounts and break-even submissions	Identifying representor and representation; gain or loss in property
False accounting (Theft Act 1968 s.17)	Dishonestly falsifying or using misleading accounts with a view to gain or loss	Nine sets of accounts found not true and fair (¶101)	Dishonesty and “view to gain” per individual
False statements by officers (Theft Act 1968 s.19)	Officer publishing misleading account with intent to deceive members or creditors	Weak: deceived parties were regulators; members (ADUG) arguably knew	Identity of the deceived class
Misleading statements to auditors (CA 2006 s.501)	Knowingly or recklessly conveying misleading information to auditors	Auditors unaware of the Scheme (fn 7)	Individual attribution; evidential age
Accounting-records offences (CA 2006 ss.386–387)	Officers in default of duty to keep adequate records	Sham documentation (¶78)	Statutory defence of honest and excusable conduct
Fraudulent trading (CA 2006 s.993)	Business carried on for any fraudulent purpose	A stretch: the business was genuine football	Proportionality; prosecutorial appetite
Perjury (Perjury Act 1911 s.1)	Wilfully false statement on oath in a judicial proceeding	¶29 finds certain witnesses dishonest; engaged only if sworn before arbitrators with power under AA 1996 s.38(5)	Whether oaths administered; corroboration (s.13); identity redacted
Perverting the course of justice	Acts tending to pervert public justice	Non-cooperation with a private disciplinary process very unlikely to qualify	Not “public justice”
Cheating the revenue / tax evasion	Dishonest conduct prejudicing HMRC	Only if off-contract remuneration dishonestly evaded PAYE/NIC	No evidence in the public domain
Failure to prevent facilitation of tax evasion (CFA 2017; from 30 Sep 2017)	Corporate offence	At most the 2017/18 residue	Non-retrospective; needs underlying evasion
Bribery Act 2010 / Money laundering (POCA 2002 ss.327–329)	Improper-performance inducements / dealing in criminal property	No finding suggests bribery; money laundering purely derivative	No factual basis / wholly contingent
ECCTA 2023 (identification reform s.196; failure to prevent fraud from 1 Sep 2025)	Corporate attribution via senior managers; corporate failure-to-prevent offence	Not retrospective; irrelevant to 2009–2018 conduct	Commencement dates

 

Investigative bodies

• Potential investigators: the SFO (CJA 1987, s.2 compulsory powers); police economic-crime units; HMRC Fraud Investigation Service; the Insolvency Service (company investigations and director disqualification). The FRC has audit-enforcement, not criminal, jurisdiction. The FCA’s role is marginal because CFG is unlisted.
• Current position: as at 30 September 2026 no referral, investigation or statement from any of these bodies has been publicly reported. The SFO and HMRC seldom confirm investigations, so absence of reporting does not prove inactivity.

Structural barriers

• Time: no limitation period for indictable offences in England and Wales, but the conduct is 8–17 years old and witnesses and documents are stale.
• Evidence: much of the Core Decision rests on Football Leaks material obtained by hacking. English courts can admit improperly obtained evidence, subject to the PACE s.78 fairness test. Section W confidentiality would not bind a prosecutor using compulsory powers.
• Jurisdiction and immunity: key actors and entities are Abu Dhabi-based. A UK–UAE extradition treaty exists, but extradition of UAE nationals is doubtful in practice, and immunity questions could arise at ownership level for serving senior state officials.
• Cautionary precedent: the failed Rangers-administration prosecutions. The Lord Advocate told the Scottish Parliament on 9 February 2021 that liability had been admitted to Mr Clark and Mr Whitehouse, each paid £10.5m in damages plus over £3m in aggregate expenses. Prosecutors will be wary of football-finance cases built on regulatory findings.

Non-criminal individual consequences (more realistic)

• Director disqualification under CDDA 1986 s.8 (public-interest application after investigation, available for solvent companies) is more realistic than prosecution, though uncertain. Section 6 requires insolvency and does not apply.
• Owners’ and Directors’ Tests: findings of dishonesty and concealment are directly relevant to the Premier League’s test and to the IFR’s owner and officer fitness tests under the Football Governance Act 2025. Individuals identified in the unredacted Appendices as having “knowledge and approval” (¶87, ¶98) face the most practical exposure.
• Political reaction: the Culture Secretary, Lisa Nandy, called the report “incredibly stark” and noted a club can be expelled from the Premier League if such allegations are upheld.

Overall criminal assessment

KEY FINDING: ASSESSMENT The realistic likelihood of any criminal charge against any City director or executive is low. Conspiracy to defraud, false accounting and s.501 are the only offences with a coherent conceptual fit; perjury is a narrow, fact-dependent outlier. Regulatory fitness consequences and HMRC civil enquiries are materially more likely than prosecution.

 

Appeal and timeline considerations

2 October 2026: City’s appeal deadline. An appeal is effectively certain.

Sanction hearing: timing unconfirmed. Sky reports the Premier League wants the process concluded this season. It is unclear whether sanction will await the liability appeal.

Appeal Board: wide powers; its decision ends the Section W process, with no CAS route. Liability is hard to overturn because the Core Decision relies on documents and credibility findings and deliberately avoids the contested question of Abu Dhabi governance (¶75). City’s likely strongest grounds are procedural (the c.21-month delay, redaction, handling of “missing” evidence), bearing more on sanction than liability.

Court challenge: Arbitration Act ss.67/68 challenges are possible but slow and rarely successful.

Compensation claims: reportedly can only proceed after the case and appeals conclude. On the Burnley timetable (Everton sanctioned November 2023, award June 2026), final awards against City are unlikely before 2028 (CWTE estimate).

Counter-litigation risk: City’s commitment to be “proactive” in all appropriate forums signals possible competition-law or public-law challenges to the sanction or compensation regime itself, modelled on its APT litigation.

Key uncertainties and caveats

CAVEAT: KEY UNCERTAINTIES Appeal outcome: any reversal or variation removes or reshapes the foundation for every claim. Unpublished Appendices: in particular the findings that reduce the extent or degree of the breaches (fn 13), restated PSR and break-even figures by season, and the identities behind ¶70, ¶87 and ¶98. Limitation: whether s.32 carries unpreserved clubs past a November 2018 knowledge date. Counterfactual modelling: what a compliant City would realistically have spent, given ADUG could lawfully inject equity at any time. Public-body action: no referral to the SFO, HMRC, FRC, Insolvency Service, IFR or UEFA is known.

 

STRICT CAVEAT: PRESUMPTION OF INNOCENCE AND LEGAL STATUS All findings referred to are first-instance findings on the civil standard, subject to appeal. Manchester City denies all wrongdoing. The presumption of innocence applies to every individual. No allegation of criminal conduct is made against any person. Figures marked as CWTE calculations or estimates are analytical, not findings of any tribunal. This paper is analytical commentary for board discussion and is not legal advice.

 

Conclusions

The compensation risk is real and concentrated. City’s main civil exposure is to four, possibly more, Premier League clubs through Section W. It is strongest for CL-place losses in 2013/14–2017/18, where Manchester United 2015/16 and Arsenal 2016/17 stand out, and is amplified by interest.

The title claims are weaker than the headlines suggest. This is especially true of 2011/12, where the Phase 1 counterfactual undermines sporting-advantage causation despite the goal-difference margin.

Most “wider” claimant categories are not viable. Players, agents, managers, broadcasters, bettors, fans, European clubs, UEFA and the FA/FIFA. Boards should not commit resources to these theories except as leverage.

Limitation discipline decides everything. Clubs without preserved rights should take urgent advice on s.32 and consider protective steps immediately.

Method matters. Claimant boards should instruct causation experts on the Wilson/Daniels model and quantum experts on the net operating-profit and player-trading basis adopted in Burnley v Everton. Gross-revenue claims will be discounted.

• Criminal exposure is a low-probability tail risk. Its practical significance lies in the regulatory fitness of named individuals under the Premier League and IFR tests, not in prosecution.

Fairness to City. City succeeded at CAS in 2020, won partial APT victories, denies all wrongdoing and is exercising its right of appeal. Every conclusion in this paper depends on the Core Decision surviving that appeal.

Sources

• Premier League, “Premier League Statement: Manchester City FC”, 29 September 2026  premierleague.com
• The Esk / CWTE, “Premier League v Manchester City: Analysis of the Independent Commission’s Core Decision (Redacted)”, 29 September 2026  theesk.org
• Premier League Judicial Panel, Burnley v Everton Compensation Summary of Decision (PLJP 2023/3), 2 June 2026
• Sky Sports, “Man City Premier League charges: Appeal process, punishment hearing and what happens now”, September 2026
• Sky Sports, “Man City charges verdict  key findings: the Fordham Arrangement”, September 2026
• CBS Sports, “What’s next for Manchester City? Appeal process and penalties”, September 2026
• The National, “Independent Commission finds against Manchester City”, 29 September 2026
• The Independent (via inkl), “Man City verdict could see four Premier League clubs land compensation worth more than £200m”, September 2026
• Malay Mail / The Times, Arsenal, Liverpool, Man United and Spurs lodge compensation notices, 14 November 2024
• Farrer & Co; The Lawyer  Manchester City / Premier League APT settlement, September 2025
• Sports Illustrated; CBS Sports  CAS 2020/A/6785 ruling reporting, July 2020
• UEFA  Champions League revenue distribution releases, 2013/14, 2016/17, 2017/18
• Sporting Intelligence (Substack)  “Where the money went” Premier League payment tables, 2011/12 to 2017/18
• AOL / The Independent Tony Pulis on the 2011 FA Cup final, September 2026
• European Business Magazine  “Man City Guilty on 114 Charges: The £694m Business at Risk”, September 2026
• GiveMeSport  Kieran Maguire on the likelihood of HMRC investigation, September 2026
• Wikipedia Manchester City F.C. Premier League financial breaches case (used for chronology cross-checking only)