Premier League v Manchester City FC: MCFC’s appeal routes and the sanctions to come (Part 1)

A^[1] Disciplinary Commission appointed pursuant to the Premier League (PL) Rules recently issued a bombshell decision in Section W proceedings brought by the PL against Manchester City Football Club Limited (City). City were found guilty of almost all of the charges. The wrongdoing that was found to have been established (applying the strong/cogent evidence test applicable for allegations of serious wrongdoing^[2]) was more serious, more sustained and had far larger financial implications than most could have imagined. A heavily redacted, and much abbreviated, Core Decision was released on 29 September 2026^[3] (Core Decision), following an initial leak of the outcome, as reported on 25 September 2026^[4].

The heavy-hitting, indeed devastating, findings and conclusions of the Commission included the following:

• City entered into ‘sham’^[5] transactions with AD Sponsors (sponsors connected to Abu Dhabi (AD)) which were designed falsely to represent ADUG^[6] (Abu Dhabi United Group Investment & Development Ltd, City’s owner) equity contributions as genuine commercial revenue;
• City used dishonest devices (a) to conceal the true origin of funds, enabling the Club to “pretend that such funds represented operating income”, (b) to meet Club liabilities with ADUG funds; and (c) to conceal operating losses;
• A specific finding that important factual witnesses for City had given evidence in relation to key aspects of the disputes that “they knew to be untrue and so had been dishonest”;
• A conclusion that City had “concocted” an untrue ‘explanation’ in relation to AD Sponsorship revenue “in an attempt to obscure and conceal the realities of the Disguised Funding Scheme” (the Commission’s term for the scheme by which equity contributions from ADUG were disguised as AD Sponsorship revenue);
• Multiple findings that City had intentionally or recklessly misrepresented its true financial position; and
• A finding that City had “made concerted efforts to stop and frustrate the PL investigation” and “breached duties of co-operation that it owed to the PL”.

On 1 October 2026 City confirmed^[7] that they had lodged a ‘comprehensive’ appeal against the ‘opinion’^[8] of the ‘Premier League Commission’^[9] in relation to the PL disciplinary matter. City asserted that the ‘opinion’ “contains material errors, of law, principle and fact and is unsafe”. They reiterated a previous statement that “a comprehensive body of irrefutable evidence exists in support of all of its positions, relating to this case”; in that prior statement City had stated, somewhat ominously, that they had “diligently respected due process for eight years on the basis that the Premier League Board and Executive would behave as an independent, impartial and fair-minded regulator, free from partisan influence”^[10].

This article (Part 1) addresses City’s appeal, possible further challenges to an Appeal Board decision,  and the sanctions process. A second article (Part 2 – see here) will address possible further legal or regulatory consequences outside the PL’s disciplinary framework, possible compensation claims by other Clubs against City and potential issues/claims relating to City’s sponsors.

It looks at:

• The Rules behind the Appeal
  • The Appeal Board
  • New evidence?
  • Limited “review” not a full rehearing
• The possible scope of City’s appeal
• The Appeal Board’s powers
• What next after the Appeal Board decision – arbitration?
  • Would a final arbitration award be the end?
  • Is the dispute resolution process in the PL Rules sub-optimal?
• The sanctions process
  • Bifurcation of liability and sanctions
  • Possible range of sanctions
  • Likely extent of sanctions
  • How soon can the sanctions be handed down?
  • Sanctions vs sporting advantage/benefit