Manchester City and the '115 Charges': The Commission's Verdict

Timeline

1. Dec 2018The Premier League begins investigating Manchester City.
2. Feb 2023The League issues a complaint and refers the case to an independent commission.
3. Dec 2024A 42-day hearing concludes.
4. Feb 13, 2025An arbitral tribunal declares the League's associated-party transaction rules void as a whole after City's challenge.
5. Sep 8, 2025City and the League settle the APT dispute; City accepts the current rules as valid and binding.
6. Sep 29, 2026The League publishes the commission's redacted core decision finding City guilty of all financial charges.
7. Oct 1–2, 2026City lodges an appeal; the FA says the verdict has 'significant implications for the integrity of the game.'

The ethical issues

• Integrity of competition when financial rules are breached.
• Transparency versus confidentiality in disciplinary proceedings.
• Delay and fairness in a process lasting nearly eight years.
• Ownership by state-linked investors and 'sportswashing' concerns.
• Cooperation and good faith toward regulators.

Stakeholders

Stakeholder	Interests & obligations
Manchester City	Its titles, reputation and the right to a fair appeal.
Rival clubs	Fair competition and redress for lost revenue or places.
The Premier League	Enforcing its rules and its credibility.
Fans	Trust in results and fairness.
Sponsors	Their reputations and commercial relationships.
Regulators and lawmakers	Accounting integrity and football governance.

The case

Manchester City, owned by Abu Dhabi United Group (ADUG), has been one of English football’s most successful clubs.^[1][2] For years, it faced allegations that it had broken the Premier League’s financial rules. In September 2026, an independent commission found it guilty.^[1] The club denies wrongdoing and has appealed, so the findings are not yet final.^[2]

Background

The Premier League began investigating Manchester City in December 2018. In February 2023, it issued a complaint under Section W of its rules and referred the matter to an independent commission.^[1] The case became known as the “115 charges.” The BBC reported that City was found guilty of 114 of them.^[2]

The League’s February 6, 2023, statement grouped the alleged breaches into five categories: failing, in each season from 2009–10 to 2017–18, to provide “in the utmost good faith” accurate financial information giving “a true and fair view” of the club’s revenue (including sponsorship), related parties and operating costs; failing to include full details of manager remuneration (2009–10 to 2012–13) and player remuneration (2010–11 to 2015–16) in contracts; breaching rules requiring compliance with UEFA’s financial fair play regulations (2013–14 to 2017–18); breaching the League’s Profitability and Sustainability Rules (2015–16 to 2017–18); and failing to cooperate with the investigation from December 2018 onward.^[3] Each category listed separate rules for each season.^[3]

The case had a European precedent. In February 2020, UEFA’s Club Financial Control Body banned City from its competitions for two seasons and fined it €30 million for disguising equity funding as sponsorship. On July 13, 2020, CAS set that aside: it found that most of the alleged breaches “were either not established or time-barred,” lifted the ban and reduced the fine to €10 million for failing to cooperate with UEFA’s investigation.^[4]

The commission held a 42-day hearing that concluded in December 2024. It took until September 2026 to issue its decision. The commission called the delay “regrettable,” citing about 7,000 pages of transcripts and extensive written submissions.^[1]

A parallel fight over sponsorship rules

While the disciplinary case was pending, City also challenged the League’s rules on commercial deals in a separate arbitration. The League introduced its Associated Party Transaction (APT) rules in December 2021, after the Saudi-led takeover of Newcastle United. They let the League test whether deals with companies linked to a club’s owners were at “fair market value.”^[10] City began the arbitration in January 2024, after the League had blocked two of its Abu Dhabi-linked sponsorship deals in 2023 as not being at fair market value.^[7][10]

In its first partial award, the tribunal found the rules unlawful in three respects. Two breached the Competition Act 1998: the exclusion of shareholder loans from the rules, and pricing changes made in February 2024. The third was a breach of public-law fairness: clubs could not comment on the comparable-transaction data the League relied on before it decided a deal’s value.^[7] City said the tribunal had also set aside the League’s decisions on its two sponsorship deals and found an unreasonable delay in assessing them. It said the League “was found to have abused its dominant position,” and the club welcomed the award as a win.^[8] The tribunal later summarized its own conclusion more narrowly, saying the rules were unlawful “in just two respects” under competition law and “in just one respect” under public law.^[7]

The League’s clubs voted through amended rules in November 2024 over City’s opposition.^[10] In a second award on February 13, 2025, the tribunal of Sir Nigel Teare, Christopher Vajda KC and Lord Dyson held that the three unlawful elements could not be severed. As a result, the APT rules “as a whole are void and unenforceable.” The tribunal acknowledged what it called the “surprising result” that the older related-party rules came back into force even though clubs had voted to replace them.^[7] It explained that permitting below-market shareholder loans while scrutinizing sponsorships was “an obvious distortion of competition as it permits one form of subsidy… but not another.”^[7] City started a new arbitration against the November 2024 rules. On September 8, 2025, the two sides settled: City accepted that the current APT rules were “valid and binding,” and both agreed to end the proceedings and make no further comment.^[9][10] BBC Sport reported that the settlement had no bearing on the disciplinary case.^[10]

The findings

On September 29, 2026, the League published a redacted version of the commission’s core decision.^[1] The commission found that, between 2009-10 and 2017-18:

• City arranged “sham” contracts with a number of commercial partners, and relied on other “sham” agreements, “to artificially inflate the club’s revenues and reduce its costs”;
• the sponsorship deals were “part of a disguised funding scheme,” in which sponsors paid only part of the fees and ADUG funded the rest, with further ADUG-funded arrangements to reduce recorded expenses, and a “sham” circular arrangement concerning players’ image rights;
• the schemes inflated revenue and reduced costs by more than £900 million, to appear to comply with financial rules;
• the club filed misstated accounts and concealed its true finances from its auditors and regulators; and
• had the agreements been reported accurately, City would have breached both the League’s and UEFA’s spending limits “by a very substantial amount.”^[1]

The commission concluded that “by its conduct the club clearly intended to circumvent the PL Rules.”^[1] It upheld three of four allegations that City breached its duties of cooperation and good faith during the investigation, finding that the club had “made concerted efforts to stop and frustrate the PL investigation.”^[1]

The rules and governance

Section W proceedings are confidential and heard in private. Commission members are selected by the independent chair of the League’s Judicial Panel.^[1] Commissions have broad discretion over sanctions, including fines and points deductions, and sanctions are decided at a separate private hearing.^[1] The League could publish the core decision because the commission ruled, and an appeal board confirmed, that it was a “final award.”^[1]

The League’s chief executive said the decision showed how the club “systematically broke Premier League Rules for nearly a decade,” and called the case “the most significant in Premier League history.”^[1]

Aftermath

City lodged an appeal, saying the ruling contained “clear material errors, of law, principle and fact and is unsafe,” and that “a comprehensive body of irrefutable evidence exists in support of all of its positions.”^[2] The appeal will be heard in private by a new three-person panel. A rule added in 2026 says appeal hearings should conclude within 12 weeks, with a decision within 30 days, though the timeline can be disapplied.^[2] BBC Sport reported that City was expected to argue that key sponsorships were funded by the Abu Dhabi government rather than its owners; League rules allow state-owned bodies to sponsor clubs.^[2]

The Football Association said the verdict had “significant implications for the integrity of the game” and that it would “take action where appropriate.”^[2] Parliamentary committees raised questions about tax and corporate accounting.^[2] Etihad Airways, a major City sponsor that was not named in the redacted findings, said it “categorically rejects any finding, conclusion or implication” that it was involved in improper arrangements.^[2]

City’s chief executive told employees in a video that the decision was based on a “Premier League conspiracy theory.”^[5] The commission also found “sham” image-rights arrangements with players and the club’s then manager.^[5] The appeal was expected to run alongside a separate sanctions hearing before the commission.^[5] In October 2026, the chair of the Independent Football Regulator said that, under a prescribed 12-week process, the appeal was expected to be heard by “the middle or the end of January,” while stressing it was the Premier League’s process, not the regulator’s. No sanction had been announced. City was top of the table at the time, and there was speculation it could lose the three league titles it won in the period covered by the findings.^[6]

The core dilemma

Financial rules are meant to keep competition fair. If a club can evade them for years, rivals and fans lose confidence. But the club is entitled to a fair process, including an appeal, and the process has already taken nearly eight years. How should a league enforce its rules against its most powerful member, fairly and in time to matter?

Competing values

• Integrity vs. due process: enforcing rules against a club’s right to defend itself.
• Confidentiality vs. transparency.
• Thoroughness vs. timeliness.
• Investment vs. fair competition.

Strongest arguments

For strong sanctions if the findings stand: the commission found intentional, long-running concealment and obstruction, affecting competition for nearly a decade. Weak sanctions would make financial rules meaningless.

For caution: the findings are under appeal and the club disputes them. Sanctions should await the final outcome, and the process must be fair even to unpopular parties.

For reform regardless of outcome: the length and secrecy of the process show the need for faster, more transparent enforcement.

Applying the frameworks

Justice

A justice lens asks what fairness requires for rival clubs that competed against City, and for City as a party entitled to due process and appeal.

Utilitarianism

A utilitarian lens weighs the deterrent value of strong sanctions against the costs of uncertainty, disruption and harm to fans of all clubs.

Virtue ethics

A virtue lens asks what integrity requires of clubs and owners, and what the commission’s findings on cooperation say about the club’s conduct.

Walk it through: the Simple Decision Model

1. Spot the issue. You sit on the appeal board. Stakeholders include the club, rivals, fans, sponsors and the League. Less visible are clubs that may have missed places or revenue. The codes are the Premier League rules, especially Section W.
2. Gather facts. What errors does the club allege? What evidence supports each finding? Beware public opinion and the size of the stakes.
3. Test options. (a) Dismiss the appeal. (b) Allow it in part. (c) Allow it in full.
4. Check codes and law. Apply Section W’s standards for appeal.
5. Decide and document. Explain each ground of appeal and your conclusion.
6. Communicate and follow up. Publish the decision when permitted and move promptly to sanctions.

What’s settled and what’s contested

• Settled: the commission’s findings as published; the appeal; that sanctions are still to be decided.
• Contested: whether the findings will survive appeal; what sanctions are appropriate; how the outcome should affect past titles.

Why this case matters

The Manchester City case is the largest test of financial regulation in English football. Its outcome will shape how leagues enforce rules against wealthy, powerful clubs.

See also: Docked for Spending: Everton, Forest and the Premier League’s Profit Rules.

Key terms

Institutional accountability

Structures that make a sport organization explain its decisions and face consequences: clear authority, transparency, appeals, independent oversight and enforcement.

Due process

Fair procedures before a sanction: notice, a chance to respond, an impartial decision-maker and a right of appeal.

Sportswashing

Using sport, through events, teams or sponsorship, to improve the reputation of a state or company and distract from wrongdoing.

Integrity

A commitment to honesty and ethical principle in competition and administration, including when nobody is watching.

Fair play

Integrity put into practice: respecting both the written rules and the spirit of competition.

Sanction certainty

The principle that the likelihood of being caught and punished deters misconduct more than the severity of the punishment.

Definitions from the Ethics Cases glossary.

Discussion questions

1. The commission found that City's conduct was intended to circumvent the League's rules. If upheld, what sanction would be proportionate for breaches spanning nine seasons?
2. The process took nearly eight years from investigation to verdict. How should leagues balance thoroughness against timely justice?
3. Should disciplinary proceedings involving a club's integrity be held in private?
4. How should the outcome affect titles and trophies won during the period in question?

Sources

1. Premier League statement: Manchester City FC (29 September 2026) — Premier League
2. Man City confirm appeal against guilty verdict — BBC Sport
3. Premier League statement (Feb. 6, 2023) — Premier League
4. Manchester City FC did not disguise equity funding as sponsorship contributions but did fail to cooperate with the UEFA authorities (media release, July 13, 2020) — Court of Arbitration for Sport
5. Manchester City guilty over Premier League charges after £900m of 'sham' contracts (Sept. 29, 2026) — The Guardian
6. Manchester City's charges appeal to be heard by January, regulator says (AFP, Oct. 14, 2026) — Al Jazeera
7. Manchester City FC v. Football Association Premier League Ltd, Second Partial Final Award (Feb. 13, 2025) — Jus Mundi (arbitral award text)
8. Club statement on Rule X Arbitral Tribunal Award (Oct. 7, 2024) — Manchester City FC
9. Premier League statement (Sept. 8, 2025) — Premier League
10. Man City & Premier League end sponsor rules dispute (Sept. 8, 2025) — BBC Sport