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Sport · England & Wales

What a disciplinary commission decided, and what the record supports

October 2026·UK
SportPremier LeagueDisciplinary CommissionFinancial rulesLive matter

Sport · England & Wales · what a disciplinary commission decided, and what the record supports

On 29 September 2026 the Premier League published the redacted core decision of an independent commission in its case against Manchester City. The decision is long, the commentary louder, and the two have already drifted apart. This dossier reads the decision first, tests the headline figures against its text, sets it beside the 2020 award that went the other way, and sorts what is said about it into three piles: on the record, only reported, and unsupported. City has appealed. Nothing here is a finding of ours.

The gist in five lines, if you read nothing else:

  • The Commission found every charge proven except Charge 4(B). "114 of 115" is press shorthand; no primary document uses it.
  • The League says the schemes inflated revenues and cut costs by "more than £900 million". That measures what was misstated. It is not a fine, and no sanction has been imposed.
  • In 2020 CAS reached a different conclusion on the sponsorships, on a narrower record and under a time bar. Different records, different rules — not a contradiction.
  • The decision does not mention tax. The tax questions come from general law and an outside analysis; Parliament's Treasury Committee wants HMRC's answer by 15 October.
  • City says it is innocent of the accusations and that the decision contains clear material errors of law, principle and fact. It appealed on 1 October.

What was decided#

The proceeding. On 6 February 2023 the League referred alleged breaches to a Commission under Rule W.3.4, in five categories: accurate financial information (2009/10 to 2017/18); manager and player remuneration; compliance with UEFA's club-licensing and financial fair play rules; the League's own profitability and sustainability rules; and co-operation with the League's investigation. The Commission sat for 42 days between 16 September and 6 December 2024 and heard 27 factual witnesses. The core bundle ran to "many tens of thousands of pages" (para 16).

The findings. In its own words, it "found each of the Charges proven against the Club bar Charge 4(B)" (para 7). The decision speaks of "well over 100 individual breaches" (para 1), grouped as Charges 1 to 4, and Charge 4(A) was proved only "in the majority of the respects" alleged (para 157). Among the findings:

  • The sponsorship agreements with Abu Dhabi entities were shams, part of what the Commission calls a "Disguised Funding Scheme" devised in early 2010 (paras 67, 110).
  • Income for 2009/10 to 2017/18 was "hugely overstated by over £830 million" (para 101).
  • The agreements underlying what the Commission calls the "Fordham Arrangement", under which a fee was paid to the club for players' image rights, were a sham; the fee was "an injection of funds into the Club by ADUG", the owner group (paras 136 to 137). Three remuneration arrangements funded through ADUG (£8.866m, £7.4m and £0.5m) were also shams (paras 93 to 99).
  • The auditors were unaware (fn 7). Certain City witnesses gave evidence "they knew to be untrue and so had been dishonest" (para 29).
  • The League's profitability rules were breached "by a very substantial amount" in each season charged under Charge 3 (the rules allow aggregated losses of up to £105m over three years, para 43), and City "made concerted efforts to stop and frustrate the PL investigation" (para 157).

Status. These are disciplinary findings on the civil standard, not criminal ones, and they are under appeal. The League published the decision because the Commission ruled, and an Appeal Board confirmed, that it is a "final award". Only the redacted core is public; at least 37 appendices are not.

Reading the numbers#

"114 of 115." A press figure. The 2023 charge statement, the decision and the League's 2026 statement use neither number. On the primary text the accurate phrase is "all charges bar one".

"£900 million." The League's statement says the schemes sought to "artificially inflate the club's revenues, and reduce its costs, by more than £900 million". The decision gives the underlying items separately at para 101: income overstated by over £830m and by £24.5m; expenses understated by £8.866m, £7.4m, £0.5m and £49.414m. We do not add them up: the League shows no total, and the appendices that would show whether the items overlap are unpublished. The figure measures misstatement — not a penalty, and not a sum owed to anyone.

The 2020 award, and why it differs#

In February 2020 UEFA's club-finance body imposed a two-season exclusion and a €30m fine. In CAS 2020/A/6785 (13 July 2020) the panel set the ban aside and cut the fine. The majority held that "prosecution" under the five-year limitation rule starts when charges are filed, not when the investigation opened or when the sanction issued, so the period ran back from the Referral Decision of 15 May 2019 and breaches before 15 May 2014 were barred (paras 170 to 174). That put the Etisalat charges and the accounts for the years ended May 2012 and May 2013 out of time (para 343(iii), (vi)). On the Etihad arrangement the majority was "not comfortably satisfied" the arrangements discussed in the leaked emails were executed (paras 291 to 293), and it noted UEFA "by no means filed frivolous charges" (para 325). It found non-cooperation a "severe breach" (para 331) and, reducing UEFA's fine by two thirds, substituted a €10m fine with no ban (paras 334 to 335).

The 2026 Commission heard 42 days of evidence across nine seasons, under no such time limit, and found witnesses dishonest. The two bodies answered different questions on different records. Neither can be summarised as overturning the other.

The Der Spiegel history#

The public story began on 5 November 2018, when Der Spiegel published the first of four chapters from the Football Leaks material alleging that Abu Dhabi sponsorships were partly funded by the club's owner group and booked as commercial revenue (Sports Illustrated, 5 November 2018). A later chapter reported that the club "helped set up a shell company called Fordham Sports Management with two British investors" (Sports Illustrated, 6 November 2018); the decision records £24.5m under the Fordham Arrangement wrongly recorded as operating income (para 101). City described the material as "purportedly hacked or stolen" and used "out of context", and the reporting as an "organised and clear" attempt to damage its reputation (Inside World Football, 16 January 2019). The decision itself refers to "a hack of the Club's servers in 2017" (para 103).

Provenance. We cite this reporting through Sports Illustrated; Der Spiegel's own site could not be reached for this check. The emails Der Spiegel attributed to individual executives came from a leak City disputed, and the decision names none of them.

Remuneration, image rights and tax#

What the decision says. Remuneration findings concern arrangements whose terms "ought to have been set out" in the individual's contract with the club (paras 93, 116 to 127). The individuals are redacted, and the decision does not use the words "tax", "HMRC" or "PAYE".

Who has been named, and in whose voice. Outside reporting and analysis have linked the £8.866m manager arrangement to Roberto Mancini. Der Spiegel reported in 2018 that he signed a second contract, as an adviser to Al Jazira, a club with the same owner, and that payments reached a Mauritius company, Sparkleglow Holdings (Sports Illustrated, 8 November 2018). Tax Policy Associates reasoned in 2026, from the rule, the seasons, the amount and the width of the redaction, that the Commission's £8.866m arrangement is the same one. That is their reporting and inference, not a finding: the Commission's text does not name him. Mancini told Gazzetta dello Sport: "Manchester City are not guilty and the double contract is not my problem, but theirs if anything" (as reported by Sports Mole). We name no other individual as the subject of a finding.

The tax law, in outline. UK law has no free-standing image right. HMRC accepts image-rights payments only where they are commercially real (Employment Income Manual EIM00733 to EIM00739). Earnings include "anything else that constitutes an emolument of the employment" (ITEPA 2003 s.62(2)), and the disguised-remuneration rules in Part 7A apply from 2011. Inaccuracy penalties can reach 100% of the tax lost where the error is deliberate and concealed (FA 2007 Sch 24 para 4), and HMRC can assess back 20 years for deliberate loss (TMA 1970 s.36(1A)). From April 2027 all employment-related image-rights payments become employment income (Budget 2025). The Premier League stated in December 2016 that "guiding principles" agreed after talks with HMRC included a base level of 20% of total remuneration in image rights; that is the League's statement, not law.

What has been said about this case. Tax Policy Associates (1 October 2026) estimates about £11.6m of unpaid income tax and National Insurance on the £8.866m arrangement, and says it alleges no offence by any individual. That is an attributed estimate. On the same day the Treasury Committee's chair wrote to HMRC's chief executive asking whether HMRC is aware of the findings, whether it has sought the unredacted report and for an overview of its football work; a reply is due by 15 October 2026.

Company law, as a frame only. The Companies Act 2006 criminalises failures to keep or preserve accounting records (ss.387, 389), knowingly or recklessly misleading auditors (s.501), fraudulent trading (s.993) and false statements to the registrar (s.1112). No authority has charged anyone. We describe these provisions as law; we do not apply them to any person or to the club.

What is not supported#

Three claims in circulation do not survive the record:

  • Yaya Touré and Fordham. The Fordham Arrangement (found a sham at paras 136 to 137) and the remuneration limbs are separate matters. Nothing we have opened links Touré to Fordham, and we do not name him as the subject of the £7.4m limb.
  • "Sparkle Horse". We found no Al Jazeera investigation by that name. The vehicle in Der Spiegel's 2018 Mancini reporting is Sparkleglow Holdings.
  • Insolvencies. Nothing sourced connects any insolvency to these arrangements.

What happens next#

City lodged its appeal at 7pm on 1 October 2026; the League confirmed it the next day. The Appeal Board sits in private and reviews the evidence the Commission heard. The proceedings ran under the 2022/23 Handbook, which sets no fixed appeal timetable; the 2026/27 Handbook sets one of 12 weeks (Rule W.86) but does not say whether it reaches cases begun earlier. As at 7 October 2026 the League has published no date and no further statement. Sanction is for a separate hearing. The Sport course sets out every step that follows a finding.

After the Appeal Board the routes narrow sharply: arbitration under Section X on five grounds only, then the High Court on jurisdiction or serious irregularity, with no appeal on a point of law. The companion dossier, Who hears an appeal in football, and where the courts come in, walks each step.

Limitation. The 2020 time bar was a UEFA rule applied by CAS. We found no limitation rule in Section W of the 2022/23 or 2026/27 Handbook, and the published decision does not discuss one; the appendices that might are unpublished. The two outcomes differ in the rules applied as well as the records.

DateEvent
15 Oct 2026HMRC's reply to the Treasury Committee due
to be confirmedAppeal Board outcome; sanction hearing; publication of appendices
April 2027Image-rights payments become employment income

Sources#

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