Opinion: Manchester City and the “115 charges” A proposal for restitution, a lower spending cap and personal accountability

Paul Quinn  CWTE Limited 

3 October 2026

IMPORTANT NOTICE Analytical commentary for public discussion, not legal advice. All findings referred to are first-instance findings of the Independent Commission, published in redacted form and subject to appeal. Manchester City denies all wrongdoing. Figures marked as estimates are my modelling and are explained in the text. No individual is identified in this paper as responsible for any breach.

 

Summary

This paper recommends that the Commission not rely on expulsion or several seasons of points deductions as the main sanction against Manchester City. It proposes three things instead. 

First, a compensation and disgorgement fund of approximately £300m. 

Second, a bespoke 50% Squad Cost Ratio (SCR) cap for five seasons, which removes about £883m of the spending power City would otherwise be allowed. That is roughly the same as the £921m of misstatement the Commission identified.

Third, fresh fitness-and-propriety proceedings against the individuals the unpublished Appendices identify as having known of and approved the schemes.

The package is offered as a single settlement.

Agreement to it by all parties is conditional on a mutual undertaking that no party will seek damages from any other party in respect of the matters covered by the Commission’s decision.

KEY POINTS The facts. On 29 September 2026 the Premier League published a redacted Core Decision. It found every charge proven except Charge 4(B), across 2009/10–2017/18. Of £949.94m booked as Abu Dhabi sponsorship, £830.69m was owner (ADUG) money, and the total profit-and-loss misstatement is about £921.4m. No sanction has yet been imposed, and City lodged an appeal on 1 October 2026. The money. On a transparent counterfactual, the derived benefit to City from 2013/14 to 2017/18 is about £60m (low), £301m (central) or £1.16bn (high), including time value. Identified losses to rivals in the central case are about £108m with interest. The heaviest are Arsenal (Champions League (CL) place 2016/17), Manchester United (CL place 2015/16) and Liverpool (2013/14 title). The sanction. A 50% SCR cap for 2027/28–2031/32 forces about £765m of cumulative squad-cost cuts against City’s projected baseline. A 70% cap would do nothing, because City already sits below UEFA’s 70%. The settlement condition. Every party that signs up waives the right to seek damages from every other party for the same matters. Clubs take payment from the fund instead of suing City; City, the League and participating clubs do not pursue one another for losses or costs arising from the case. The powers. Compensation orders and “such other penalty” are within the Commission’s existing Section W powers. Bans on individuals need separate proceedings by the Premier League, the FA or the Independent Football Regulator (IFR), not the Commission.

 

Measure	Figure	Status
Recorded Abu Dhabi sponsorship, 2009/10–2017/18	£949.94m	Confirmed (Core Decision)
Paid by sponsors (Base Sums)	£119.25m (12.6%)	Confirmed
Paid by ADUG (Tagged Sums)	£830.69m (87.4%)	Confirmed
Fordham: income overstated / expenses understated	£24.5m / £49.414m	Confirmed
Remuneration devices (three)	£8.866m (stated as “over”), £7.4m, £0.5m	Confirmed
Total P&L misstatement (aggregation of stated figures)	£921.37m (a floor)	Derived from confirmed figures
Derived benefit to City, with time value: low / central / high	£59.6m / £300.7m / £1,157m	Estimate (this paper)
Identified central-case losses to rival clubs (with interest)	£107.8m	Estimate
Recommended disgorgement and compensation fund	£300m	Proposal
50% SCR cap: cumulative cut vs projected baseline, 2027/28–2031/32	£764.8m	Estimate
50% SCR cap: spending power removed vs UEFA 70%	£883.3m	Estimate
60% SCR cap: cumulative cut vs baseline / vs 70%	£323.3m / £441.6m	Estimate
70% SCR cap: cumulative cut vs baseline	£0 (City has £118m headroom)	Estimate

 

What the numbers mean. The owner did not “find” £830m. It paid the money itself, as owners may. The wrong was dressing equity up as commercial revenue so that City appeared to comply with UEFA break-even and Premier League PSR when it did not, failing “by a very substantial amount” in every season tested. The advantage City gained was therefore regulatory headroom, not cash. The sanction that fits that wrong most closely is to take the headroom back, prospectively and in the same currency: permitted squad spending. Compensation then addresses the identifiable victims, the mutual no-damages undertaking closes off satellite litigation, and personal accountability addresses the people.

Facts of the decision

Chronology

Date	Event
Sept 2008	ADUG acquires 90% of the club, and the remaining 10% the following year. It injects over £190m of equity in its first season and £295m in 2009/10 (Core Decision ¶49, ¶53).
Early 2010	The club “devised a plan to disguise shareholder funding … as ‘commercial partner revenue'”, which the Commission calls the Disguised Funding Scheme (¶67).
Q3 2012	Project Longbow is launched. Most strands were legitimate, but the Fordham Arrangement was not (¶83–84).
25 May 2013	A £9.9m UEFA FFP shortfall is identified. Within days, and without the sponsors being approached, amended sponsorship agreements plug it (¶88–89).
May 2014	UEFA settlement: a £49m fine (£32m suspended), a 21-player Champions League squad for 2014/15 and a capped transfer budget. Compliance was “never resolved” (fn 11).
5–8 Nov 2018	Der Spiegel publishes four “Football Leaks” articles. The Premier League opens its investigation in December 2018.
14 Feb 2020	UEFA CFCB bans City from UEFA competitions for two seasons and fines it €30m.
13 Jul 2020	CAS lifts the ban: most alleged breaches were not established or were time-barred. The fine is cut to €10m for non-cooperation.
6 Feb 2023	The Premier League refers City to an Independent Commission under Section W.
14 Nov 2024	Arsenal, Liverpool, Manchester United and Tottenham reportedly lodge notices reserving compensation rights.
16 Sep–6 Dec 2024	42-day hearing, with 34 days of oral evidence and 27 factual witnesses.
2 Jun 2026	Burnley v Everton compensation award (PLJP 2023/3): £26.0m plus £9.1m interest, £35.0m in total.
29 Sep 2026	The Premier League publishes the redacted 40-page, 160-paragraph Core Decision. Sanction is to follow at a separate hearing before the same Commission.
1 Oct 2026	City lodges its appeal. The appeal hearing should take place within 12 weeks, with a decision within 30 days of the hearing.

 

Charges: proven and not proven

Charge	Subject	Seasons	Outcome
1(A)	Abu Dhabi Sponsorship Agreements: accounts not true and fair; revenue overstated	9 (2009/10–2017/18)	Proven. Sham; alternatively substance differed from form. Knowing or reckless
1(B) limb 1	Remuneration device, £8.866m (a manager)	4	Proven (sham)
1(B) limb 2	Remuneration and image-rights device, £7.4m (a player)	6	Proven (sham)
1(B) limb 3	Consultancy device, £0.5m	1	Proven (sham)
1(C)	Fordham image-rights arrangement	Redacted	Proven
1(D)	Non-disclosure of related-party transactions	9	Proven
2	UEFA break-even, via PL Rule B.14.6	2013/14–2017/18	Proven. Failed “by a very substantial amount” in every season
3	PL PSR	2015/16–2017/18	Proven. Failed “by a very substantial amount” in every season
4(A), 4(C), 4(D)	Non-cooperation, 2018–2023	—	Proven
4(B)	Non-cooperation	—	Not proven

 

Points on the record that matter for sanction.

• City’s alternative explanation, that the Abu Dhabi government subsidised the sponsors, was found to have been “concocted well after the event” (¶77).
• Several important Club witnesses gave evidence that was false in key respects, and some gave evidence they knew to be untrue (¶29).
• Regulators “and even the Club’s auditors” were unaware of the Scheme (fn 7).
• ¶70 records “no direct evidence” that one redacted individual knew of or authorised the Scheme.
• Footnote 13 records that some of City’s arguments “reduce the extent/degree” of the breaches; the detail is in the unpublished Appendices.
• The “114 of 115” figure does not appear in the decision, which says only “well over 100” breaches.

Reconciling the headline numbers. £830.69m of Tagged Sums, plus £24.5m of Fordham income and £66.18m of understated expenses (£90.68m together), gives £921.37m.

Sponsors: what is and is not confirmed

The published decision redacts every sponsor’s identity. It also records that two Abu Dhabi arrangements were accepted as arm’s-length (¶58, ¶60), again without naming them. Which partners were “AD Sponsors” under the Scheme cannot be verified from the decision. Press reporting of the 2018 leaks (Aabar, Etihad) is context only. Etihad rejects any implication of impropriety, says it was never heard, and is taking legal advice. That is relevant both to natural justice and to the scope of the no-damages undertaking (Section 7).

The manager remuneration device

• Confirmed: a manager’s remuneration of £8.866m, funded by ADUG, was recorded in a consultancy agreement with a third party over four seasons. It was a sham (¶92–93, ¶116–120).
• Strong inference, not a finding: Tax Policy Associates identified the manager as Roberto Mancini, from tenure, redaction width and payment totals matching the leaked bundle.
• Tax: Tax Policy Associates estimates about £11.6m of unpaid PAYE and NIC, and £23m–£24m including interest and penalties.

The player device (£7.4m over six seasons) has been linked in press reporting to Yaya Touré’s image rights. That link is not verified.

Individuals

The Core Decision names no individual. It states that the devices were operated with the knowledge and approval of at least those individuals identified in Appendices 16–18 (¶87, ¶98), which are unpublished. Officers and senior executives in post during 2009–2018 are a matter of public record at Companies House (club company 00040946), but inclusion in that record is not an allegation, and this paper does not identify any individual as responsible.

Status: sanction and appeal

• No sanction has been imposed. The sanction hearing will be before the same three-person Commission.
• The Appeal Board can dismiss or allow the appeal, remit the case, or alter any sanction or compensation order.
• There is no CAS route. A challenge under ss.67/68 of the Arbitration Act 1996 is possible but faces high thresholds.
• City says the decision “contains clear material errors, of law, principle and fact, and is unsafe”.

Quantifying the disguised funding

Season by season

Season	Recorded AD fees £m	Base (sponsor) £m	Tagged (ADUG) £m	ADUG share	Regime then binding
2009/10	27.00	4.50	22.50	83.3%	None
2010/11	41.25	12.75	28.50	69.1%	None
2011/12	86.75	16.00	70.75	81.6%	UEFA monitoring
2012/13	121.75	16.00	105.75	86.9%	UEFA monitoring
2013/14	127.50	16.00	111.50	87.5%	UEFA break-even
2014/15	123.20	16.00	107.20	87.0%	UEFA (settlement-varied)
2015/16	136.17	16.00	120.17	88.2%	UEFA + PSR
2016/17	140.59	11.00	129.59	92.2%	UEFA + PSR
2017/18	145.73	11.00	134.73	92.5%	UEFA + PSR
Total	949.94	119.25	830.69	87.4%

 

Phase 1 (2009/10–2012/13): £227.50m of Tagged Sums. No domestic loss cap applied, so ADUG could lawfully have injected the same money as equity. The wrong was misreporting; sporting causation is weak.

Phase 2 (2013/14–2017/18): £603.19m of Tagged Sums. Compliance genuinely bound City here. The Tagged Sums in each PSR window (£338.87m, £356.96m and £384.49m) were 3.2–3.7 times the entire £105m permitted three-year loss.

Other devices

Device	Effect	£m
Fordham fee	Income overstated	24.50
Fordham image-rights payments	Expenses understated	49.414
Manager device (App. 16)	Expenses understated (4 seasons)	8.866
Player device (App. 17)	Expenses understated (6 seasons)	7.40
Consultancy device (App. 18)	Expenses understated (1 season)	0.50
Sub-total		90.68

 

Uncertainty range

• Floor: £921.37m. The manager device is stated as “over” £8.866m.
• Possible downward adjustment: footnote 12 indicates £7.125m of the Fordham fee should later have been recorded as unpaid. If netted off, the total falls to £914.2m.
• Working range: £914m–£925m. The restated break-even and PSR figures (Appendices 29–30) are unpublished, so the true excess against each season’s threshold cannot be calculated from the public record.

The value of the benefit

Method

1. Spending counterfactual. A compliant City would have had to cut squad spending in each Phase 2 season by the Tagged Sum, less the loss it was allowed to make (£10m a year high case, £20m central, £35m low).
2. Points conversion. The Burnley v Everton Commission accepted a model converting overspend into 0.20–0.37 points per £1m. Because returns fall at the elite end, this paper applies 0.20 (high), 0.12 (central) and 0.06 (low).
3. Table re-run. Points are removed from City’s actual totals and final tables re-ordered, with ties broken against City.
4. Valuation. Premier League merit payments per place; City’s actual UEFA Champions League distributions; labelled estimates for matchday income, commercial bonuses, avoided UEFA penalties, player-trading value and legacy effects.
5. Time value. Low: none. Central: 4% simple a year over about 10 years (×1.40). High: the 11.81% rate set in Burnley v Everton (×2.18).

Counterfactual league positions

Season	Actual (pts)	Low	Central	High	Main effects
2013/14	1st (86)	3rd (–5)	4th (–11)	7th (–20)	Liverpool champions in all scenarios
2014/15	2nd (79)	2nd (–4)	4th (–10)	6th (–19)	Arsenal 2nd and Man Utd 3rd (central)
2015/16	4th (66)	7th (–5)	8th (–12)	13th (–22)	Man Utd into the CL places in every scenario
2016/17	3rd (78)	5th (–6)	6th (–13)	7th (–24)	Arsenal into the CL places in every scenario
2017/18	1st (100)	1st (–6)	1st (–14)	4th (–25)	Man Utd champions in the high case only

 

Even the low coefficient reverses the 2013/14 title and two Champions League places. Phase 1 outcomes, including Manchester United losing the 2011/12 title on goal difference, are not attributed in any scenario.

Valuation of the benefit to City (£m)

Component	Low	Central	High	Basis
A. Premier League merit payments	10.1	17.0	37.1	Confirmed rates × places
B. UEFA CL distributions retained	49.5	74.3	196.4	UEFA releases
C. CL matchday income	0	10.0	40.0	Estimate
D. Title-linked commercial value	0	10.0	25.0	Estimate
E. Avoided UEFA regulatory penalties	0	50.0	75.0	Anchored on 2014 settlement
F. Player-trading and asset value	0	50.0	150.0	Illustrative
G. Legacy effect (2018/19 title)	0	3.5	7.0	Probability-weighted
Nominal total	59.6	214.8	530.5
Time value factor	×1.00	×1.40	×2.18
Value of the benefit	59.6	300.7	1,157.0

 

The central derived benefit (£301m) is about a third of the £921m misstatement. That reflects the fact that ADUG’s money was real and the squad would have been strong without it; the figure isolates what City gained relative to a compliant City. The figure most robust to challenge is the low case.

SCR sanction modelling

The rules

• Premier League clubs voted 14–6 on 21 November 2025 to replace PSR with the Squad Cost Ratio from 2026/27.
• Squad costs (wages, amortisation and agents’ fees) may not exceed 85% of football revenue plus net profit on player sales, with a levied allowance and sporting sanctions beyond it.
• “Top-to-bottom anchoring” was rejected.
• Clubs in UEFA competitions must also meet UEFA’s 70% rule.

City’s starting point

• 2024/25 audited figures: revenue £694.1m; total wages £408.4m; player amortisation £170m; profit on player sales £95.2m; pre-tax loss £9.9m.
• Estimated squad cost, 2026/27: about £560m, an SCR of about 60%–68%. Published trackers range from 60.3% to 84.9%; the divergence is flagged. This paper uses about 68%.
• Projection (central): football revenue £760m in 2027/28 growing 4% a year, plus £60m a year of player-trading profit; baseline squad cost £560m rising 3% a year.

Permitted squad cost under each cap: central case (£m)

Season	SCR income	85%	70% (UEFA)	60%	50%	City baseline
2027/28	820.0	697.0	574.0	492.0	410.0	560.0
2028/29	850.4	722.8	595.3	510.2	425.2	576.8
2029/30	882.0	749.7	617.4	529.2	441.0	594.1
2030/31	914.9	777.7	640.4	548.9	457.5	611.9
2031/32	949.1	806.7	664.4	569.5	474.6	630.3
5-year total	4,416	3,754	3,092	2,650	2,208	2,973

 

Spending reduction (£m)

Season	70% forced cut	60% forced cut	50% forced cut	60% vs 70%	50% vs 70%	70% vs 85%
2027/28	0	68.0	150.0	82.0	164.0	123.0
2028/29	0	66.6	151.6	85.0	170.1	127.6
2029/30	0	64.9	153.1	88.2	176.4	132.3
2030/31	0	63.0	154.4	91.5	183.0	137.3
2031/32	0	60.8	155.7	94.9	189.8	142.3
Cumulative	0	323.3	764.8	441.6	883.3	662.5

 

Sensitivity of the cumulative forced cut:

Cap	Low income	Central	High income
50%	£969.0m	£764.8m	£535.7m
60%	£568.3m	£323.3m	about £50m
70%	£167.4m	£0	£0

 

Competitive impact

• 70% cap: no bite for a club in UEFA competition. Reject it.
• 60% cap: about £65m a year of forced cuts. City remains a top-three spender; estimated expected finish 2nd–5th.
• 50% cap: about £150m a year of cuts, around 27% of squad cost. Estimated expected finish 3rd–6th: competitive but no longer dominant.
• Pro-cyclical risk: a revenue-linked cap shrinks if income falls. That is City’s strongest proportionality argument and must be stated openly.

Why 50%: the regulatory equivalence anchor

Over five years, a 50% cap removes £883m of spending power City would otherwise be entitled to under UEFA’s 70%, within 4% of the £921m misstatement. City gave itself about £0.9bn of regulatory headroom; the cap takes about £0.9bn back, in the same currency. Owner wealth cannot neutralise it.

Anti-avoidance terms:

• Associated-party revenue measured at fair market value under the APT rules.
• Profit on player sales counts only up to £40m a year.
• No levy band: any excess triggers an automatic 6-point deduction, plus one point per further £5m.
• Quarterly monitoring, with look-through access to sponsor funding sources.

Redistribution model

Principles

1. Compensation follows proven loss, using the Burnley v Everton method.
2. Disgorgement exceeds compensation. The difference between City’s central benefit (£301m) and identifiable rival losses (£108m) goes to league-wide and pyramid solidarity.
3. Opt-in, full and final, and mutual. Clubs that accept payment waive all damages claims for the same seasons, and the waiver runs in every direction between participating parties (Section 7).
4. Pay the club entity, not past owners.

Central case: rival losses by club (£m)

Club	Event	Merit	CL / title value	Nominal	With interest
Arsenal	+1 place in three seasons; CL place for 2017/18	4.423	30.0	34.42	48.19
Manchester United	+1 place in three seasons; CL place for 2016/17	4.429	20.0	24.43	34.20
Liverpool	2013/14 title; +1 place in two seasons	4.420	10.0	14.42	20.19
Chelsea	+1 place in 2013/14	1.236	—	1.24	1.73
Southampton	+1 place in 2015/16	1.242	—	1.24	1.74
West Ham	+1 place in 2015/16	1.242	—	1.24	1.74
Total		16.99	60.0	76.99	107.79

 

Tottenham and Everton gain only in the high scenario.

Allocation of a £300m fund

Method A (pro rata by lost merit money): Manchester United £78.2m, Arsenal £78.1m, Liverpool £78.0m, Southampton, West Ham and Chelsea about £21.9m each. Simple, but it ignores European qualification.

Method B (weighted by total compensatory loss): Arsenal £134.1m, Manchester United £95.2m, Liverpool £56.2m, Chelsea, Southampton and West Ham £4.8m each. Tracks the economics, but overpays three clubs.

Method C (recommended): compensation, plus integrity dividend, plus pyramid solidarity.

Element	£m	Basis
Compensatory payments	107.8	Proven-loss method
Integrity dividend: 95 non-City club-seasons at £1.214m	115.3	Every club competed under constraints City evaded
EFL / pyramid solidarity pot	76.9	Existing solidarity formula, ring-fenced
Total	300.0

 

Club	Compensatory	Integrity dividend	Total
Arsenal	48.19	6.07	54.26
Manchester United	34.20	6.07	40.27
Liverpool	20.19	6.07	26.26
Southampton	1.74	6.07	7.81
West Ham	1.74	6.07	7.81
Chelsea	1.73	6.07	7.80
Tottenham, Everton, Crystal Palace, Stoke, Swansea, West Brom	—	6.07 each	6.07 each
Leicester, Newcastle, Sunderland	—	4.86 each	4.86 each
Aston Villa, Bournemouth, Burnley, Hull, Watford	—	3.64 each	3.64 each
Norwich	—	2.43	2.43
Brighton, Cardiff, Fulham, Huddersfield, Middlesbrough, QPR	—	1.21 each	1.21 each
EFL / pyramid pot	—	—	76.90

 

Relegated clubs and cup losers are served through the solidarity pot, because neither relegation causation nor cup outcomes can be modelled credibly from a league-spending counterfactual. Routing payments through the League as distributor avoids standing problems for former members.

Director and executive accountability

Legal bases

Route	Power	Fit
Premier League Owners’ and Directors’ Test	Disqualifying conditions and Board determinations	Whether a club-level Section W finding triggers individual disqualification must be checked against the 2026/27 Handbook
FA Rules and Disciplinary Regulations	Suspension from football activity, permanently or for a stated period	The most direct route to a football-wide ban
Football Governance Act 2025 (IFR)	Officer fitness: honesty, integrity, competence; review of incumbents; disqualification orders; appeal to the CAT	Strongest statutory basis; depends on the IFR’s operational commencement
Company Directors Disqualification Act 1986, s.8	Public-interest disqualification	Registered directors only; uncertain
Criminal law	False accounting, Companies Act and tax offences	No referral publicly known

 

Who is implicated

The findings implicate unnamed individuals: those identified in Appendices 15–19 as having knowledge of and approving the schemes, and witnesses found to have given evidence they knew to be untrue. Neither category can be matched to names from the public record, and press reporting is not a substitute.

Legal risk

Risk	Assessment	Mitigation
Natural justice	High if bans flow automatically from the club decision	Fresh individual proceedings with notice, disclosure and a hearing
Defamation	High for anyone naming individuals before determination	Do not identify redacted persons; this paper does not
Employment law	Moderate	Bans address roles in football; employment decisions rest with the club
Restraint of trade	Moderate	Fixed terms, a tiered scale and a right of appeal
ECHR / competition law	Rules must be transparent, objective and proportionate	Published criteria and appeal routes

 

Recommended standard

1. Trigger: identification in the unredacted Appendices as having knowledge and approval, or a finding of knowingly false evidence. Never press naming, and never mere board membership.
2. Process: separate proceedings (preferably IFR or FA) on the civil standard requiring strong, cogent evidence.
3. Tariff: knowing design or approval of a sham, 5–10 years’ disqualification; knowingly false evidence, 3–5 years; knowledge without approval, a fitness review and conditions; no knowledge, no sanction.
4. Precedent: Juventus executives were banned alongside the club’s points penalty in 2023.

Settlement condition: mutual undertaking not to seek damages

KEY TERM Agreement to this proposal by all parties is given on the basis that no party will seek damages from any other party arising from the matters determined by the Independent Commission. The fund, the SCR cap and the accountability process are offered in place of litigation, not in addition to it.

 

Scope

• Parties: Manchester City (and its parent and owner), the Premier League, and every club that accepts a payment from the fund. The EFL participates through its solidarity allocation.
• Claims waived: all claims for damages, compensation, restitution or costs, in contract, tort or under the Premier League Rules (including Rule W.51-type compensation claims), arising from the conduct covered by the Core Decision for seasons 2009/10–2017/18 and the investigation that followed.
• Direction: the waiver is mutual. Clubs do not sue City; City and its owner do not pursue the League, the Commission or participating clubs for losses or costs connected with the proceedings or the sanction; participating clubs do not pursue the League for regulatory failure in respect of the same matters.
• Mechanism: each participating party signs a deed of settlement and release on acceptance of its payment. Payment is conditional on the release, and releases take effect only once all designated parties have signed or a stated participation threshold is met.

What the undertaking does not cover

• Regulatory and disciplinary processes. It does not waive the sanction itself, monitoring of the SCR cap, or fitness proceedings against individuals by the Premier League, the FA or the IFR. Those protect the competition, not private interests, and cannot be traded away.
• Statutory and public authorities. HMRC, the Financial Reporting Council and any prosecuting authority are not parties and cannot be bound.
• Non-signatories. Sponsors such as Etihad, former club owners and clubs that decline payment are not bound. A club that declines payment keeps its right to claim, but forfeits its allocation.
• Appeal rights. City’s appeal against the findings is a separate matter. If City wishes to secure the release, the settlement would naturally be offered on the basis that the appeal is withdrawn; if it is not, the package can still be imposed by the Commission, but the releases would not take effect.

Why it matters

• Certainty for everyone. On the Burnley v Everton timetable, individual compensation claims would not produce awards before 2028, and a decade of satellite litigation would follow.
• Finality for City. City exchanges open-ended exposure to multiple damages claims for a defined, capped liability.
• Equal treatment. Clubs receive compensation by a published formula rather than according to litigation budgets.
• Protection for the League. The waiver closes off claims that the regulator itself failed to act sooner.

Legal points to confirm

• Enforceability of releases signed by club entities whose ownership has since changed.
• Whether the Premier League can make payment from the fund conditional on a release under its existing rules, or whether a resolution of member clubs is needed.
• Treatment of claims already notified (the four clubs that reserved rights in November 2024).
• Competition-law review of any term restricting clubs’ access to the courts.

Legal and policy feasibility

What the Commission can already do

• Compensation orders. Section W empowers a Commission to order payment of compensation, unlimited in amount, to any club, and to signal its intention to do so. The Everton Commission gave clubs 28 days to declare claims. No rule change is needed, but payments must rest on conventional causation.
• “Such other penalty as it shall think fit.” This supports a bespoke, time-limited SCR cap. City accepted bespoke spending limits from UEFA in 2014.
• Fines are unlimited in principle. Whether the Board can distribute fine proceeds to clubs must be confirmed. If not, the solidarity elements need City’s consent as part of the settlement in Section 7, or a resolution by the clubs.
• Director bans are outside the Commission’s powers and need separate proceedings.

Precedents

Case	Breach	Sanction	Lesson
Everton (2023/24)	PSR overspend	10 points, reduced to 6; a further 2 for FY23	Single-window breaches get modest deductions
Nottingham Forest (2023/24)	PSR overspend	4 points	As above
Burnley v Everton (2026)	Compensation for relegation	£35.0m including interest	Inter-club compensation works
Sheffield United v West Ham (2009)	Third-party ownership	Settled at a reported £20m over five years	Settlements land well below headline claims
Chelsea	Undisclosed payments, 2011–2018	UEFA €10m; Premier League £10.75m plus suspended transfer ban	Self-reporting earns leniency
UEFA v City (2014)	FFP	£49m (£32m suspended), squad and transfer limits	Bespoke spending limits on City have precedent
Juventus (2022/23)	False accounting	10 points; executives banned	Club and individual sanctions together
Calciopoli (2006)	Referee influence	Relegation, titles stripped	A match-fixing case, so weak read-across

 

Why this package beats expulsion or multi-season points deductions

1. It repairs the competition. Deductions pay nothing to the clubs that lost titles and Champions League places. The fund pays them.
2. It matches the wrong. City’s gain was regulatory headroom; the cap takes about £0.9bn back.
3. Owner wealth cannot neutralise it.
4. It is legally more robust. Expulsion invites proportionality, competition-law and broadcast-contract challenges, and senior executives at other clubs doubt the votes exist.
5. It ends the litigation. The mutual no-damages undertaking replaces a decade of claims with one settlement.

Counterarguments

• “Too lenient.” Breaching the cap triggers automatic deductions, and a one-season deduction for non-cooperation can be added without undermining the package.
• “Double jeopardy with UEFA and CAS.” Different rulebook, regulator and charges; CAS turned largely on limitation.
• “Strip titles.” Only 2013/14 is robustly reversed; annotation plus compensation to Liverpool is more defensible.
• “The counterfactual is speculative.” That is why low, central and high cases are published.
• “City will win on appeal.” The package is designed to be imposed only after the appeal.

Risks and data limitations

• Only the Core Decision is public. The 37 Appendices hold the restated figures, witness assessments and identities; the footnote 13 mitigations could reduce quantum.
• Redactions. Sponsor identities cannot be verified; the Mancini identification is inference, not a finding.
• Model sensitivity. The points-per-£m coefficients are calibrated, not estimated on City data. A season-level regression should be commissioned before any pleading.
• UEFA figures. Some City distribution figures are secondary-sourced; exchange rates are approximations.
• SCR inputs. Published estimates of City’s SCR conflict (about 60% to 85%).
• Rule numbering and powers. Section W numbering has changed between editions; distribution of fines and Owners’ and Directors’ Test triggers must be checked against the 2026/27 Handbook.
• Settlement uptake. The mutual no-damages undertaking depends on enough parties signing. A club that stays out keeps its claim and weakens the finality the package offers.
• Limitation. Clubs that did not lodge protective notices face limitation arguments, which is another reason for an opt-in fund.
• Third parties. Etihad’s threatened action, and any sponsor challenge, sit outside the settlement unless those parties join it.

Recommendations

1. The Commission should signal now that it may use its compensation power, and invite affected clubs to declare claims within 28 days.
2. Impose a £300m restitution order, structured under Method C: £107.8m compensatory, a £115.3m integrity dividend and a £76.9m EFL solidarity pot.
3. Make acceptance conditional on a mutual undertaking not to seek damages from any other party for the same matters, documented by deed of release.
4. Impose a 50% SCR cap for 2027/28–2031/32 with the anti-avoidance terms in Section 4.6. Use 60% as the fallback; reject 70%.
5. Order City to pay the Premier League’s costs in full.
6. Annotate the record for 2013/14 rather than strip titles.
7. Refer the findings to the IFR and the FA for individual fitness proceedings, which the settlement does not waive.
8. Refer the tax and accounting findings to HMRC and the FRC for their own assessment.
9. Make systemic changes: look-through confirmation of sponsor funding sources; sponsor-side attestations; an express power to distribute disgorged sums; and a deadline for Commission decisions.
10. Sequence everything after the appeal. If the appeal succeeds in part, rerun the model on the surviving findings.

Sources

• Premier League, Independent Commission Redacted Core Decision, 29 September 2026 (resources.premierleague.pulselive.com)
• Premier League statement: Manchester City FC, 29 September 2026 (premierleague.com)
• Burnley v Everton Compensation Decision (PLJP 2023/3), June 2026 (resources.premierleague.pulselive.com)
• The Esk, analysis of the Core Decision, 29 September 2026, and potential civil claimants and criminal exposure, 30 September 2026 (theesk.org)
• Tax Policy Associates, “Did Manchester City cheat HMRC out of £12m?”, 1 October 2026 (taxpolicy.org.uk)
• Sky Sports, key findings and Etihad response, September 2026; SCR vote, November 2025
• Al Jazeera, ESPN and Flashscore reporting on the verdict and appeal, September–October 2026
• Herbert Smith Freehills Kramer and LawInSport commentary on Burnley v Everton and Leicester City, 2026
• Brabners, ESPN and Sportcal on the Squad Cost Ratio rules, 2025
• Manchester City 2024/25 Annual Report; Swiss Ramble, PSR Watch, Read Man City and Greg Cordell analysis of City’s accounts and SCR
• UEFA Champions League financial distribution releases, 2014/15–2017/18
• Companies House, Manchester City Football Club Limited (00040946) officers
• Football Supporters’ Association, Football Governance Act 2025 clause-by-clause analysis; FA Disciplinary Regulations
• Der Spiegel / Football Leaks reporting as summarised by Sports Illustrated, November 2018