Potential litigation against Man City following guilty decision

What kinds of claims might Man City face?

Manchester City Football Club (“the Club” / “Man City”) has been found guilty of 114 charges brought by the Premier League (“PL”) by an independent commission (“Commission”) following a 42-day hearing concluded in December 2024.

Man City released a statement on 2 October 2026 stating that it has filed an appeal against the Commission’s decision and that “…on multiple grounds, the opinion contains clear material errors, of law, principle and fact and is unsafe”.

Broadly, the charges relate to breaches of financial rules, including breaches of accounting obligations, financial fair play rules and obligations to cooperate during the PL’s investigation prior to bringing the charges.

The Club won eight trophies during the period subject to the investigation.

The Commission found that the Club had adopted a “Disguised Funding Scheme”, which gave the misleading impression to third parties that its commercial revenues were far greater than was in fact the case and concealed from third parties the true extent of equity contributions being made to the Club by the Club’s owner during the period subject to investigation, Abu Dhabi United Group.

Whilst it is the Commission’s role to deal with PL sanctions against the Club (if the initial decision is maintained, subject to the outcome of the appeal), rival clubs may seek their own means of redress following the Commission’s decision.

Claims by rival clubs

Under the PL Rules, the Commission has the power to order a Respondent to pay compensation “unlimited in amount” to another club.

This power was invoked in a recent decision by the Commission dated 2 June 2026 in a claim brought by Burnley Football & Athletic Company Limited against Everton Football Club Company Limited, pertaining to Burnley’s relegation from the Premier League.

That decision is also open to appeal but, as it stands, the Commission concluded that Everton breached the PL Rules causing Burnley recoverable loss and the Commission assessed the compensation at over £35m. It was found that Burnley’s relegation was caused by the sporting advantage conferred on Everton by its breach of the PL Rules. The Commission held that Burnley was limited to claiming losses resulting from the breaches adjudicated in the original complaint proceedings (brought by the PL).

Man City’s rival PL clubs may bring similar compensation claims under the PL Rules. They may also / alternatively issue claims in the civil courts, as may rival clubs which are not PL clubs. The nature of such claims will be highly fact-specific, but Man City could face tort claims for remedies including damages in relation to a variety of losses said to have been caused by its actions as found by the Commission, such as prize money, revenue and/or league qualification, broadcasting income and related losses of sponsorship / commercial opportunities.

Any such claims by rival clubs will likely need to address the legal hurdles of causation, remoteness and quantification of loss. As in Burnley v Everton, rival clubs will need to show that, as a direct result of Man City’s actions, the Club achieved an unfair sporting advantage, which resulted in recoverable losses to the rival club(s) that they will need to quantify. If pursued, such legal claims would involve a complex process, likely involving detailed expert evidence.

Claims by other third parties

The Commission’s findings referred (amongst other things) to third parties being presented with misleading impressions of the Club’s financial affairs. Those third parties may be numerous. The core decision published by the Commission is only part of the decision and, even in its partial form, is heavily redacted. As a result, information which may have revealed identities of persons involved in the various arrangements referred to have been withheld from the public domain.

However, one may speculate that third parties, for example, players or commercial parties, may have decided to enter into contracts with the Club as a result of representations about the Club’s financial affairs. If so, and if such third parties allege that they have suffered loss as a result, they may seek to pursue tort and/or contract claims for damages against the Club.

Any potential claimants will likely await the outcome of Man City’s appeal to the Commission filed on 1 October 2026 before pursuing legal action and review the position in light of any new findings on appeal.

Blake Morgan's expertise

The potential fallout from this decision extends beyond the proceedings between Man City and the PL. Clubs and other parties that consider they have suffered financial or commercial loss will need to assess carefully whether they have a claim and the legal and evidential hurdles involved.

Blake Morgan brings together extensive Litigation and Dispute Resolution capability with dedicated Sports Law expertise. The firm’s dispute resolution lawyers advise on complex commercial disputes in the Courts and through arbitration, while its sports lawyers have experience across professional football and understand the legal and commercial context of the sector. This combined expertise enables Blake Morgan to support clients considering potential claims or seeking to understand how developments could affect their contractual and commercial interests.