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Part 2 · Section 7 of 10

A case from start to finish

Consequences: sanctions, finality and containment

By the end of this section you can place any step of a case in the whole process, say when the punishment is decided and by what rules, what limits apply, who pays, and when the matter is over for good.

In one screen

Once the charges are proved, what happens next, who pays, and when is it over?

Proving the charges is one step of eleven. Next comes a separate sanction hearing, then appeal, review, the courts' supervision, compliance, other clubs' claims, publication and a notice to the statutory regulator.

The Commission's sanction powers are wide and largely open; fixed tariffs exist only for some breaches. Each stage becomes final if no one challenges it in time.

Law and forum

The Premier League’s Rules are governed by English law (A.7), and every arbitration under them is seated in England and Wales (X.2). That is the law of one part of the United Kingdom. It is not Swiss law, which governs UEFA’s statutes, and not EU law. Scotland and Northern Ireland have their own legal systems and are not the forum here.

A contract, not a crime

Everything in this section happens between private parties under a contract. The rules on spending, reporting and cooperation are conditions the clubs accepted as the price of playing in the League (B.14). A breach is a breach of contract between civil parties, decided on the civil standard. It is not a criminal offence, the League cannot imprison anyone, and a Commission’s finding is not a conviction.

So a Commission cannot charge anyone with a crime, or impose a criminal penalty. Its sanctions are the ones the Rules list, such as a reprimand, a fine, a points deduction, a suspension, compensation, conditions and costs (W.51), and they bind only those who agreed to the Rules. We found no mention of the police or prosecutors anywhere in Section W.

A criminal charge is a different process in a different place. It is brought in the criminal courts by a prosecutor: ordinarily the Crown Prosecution Service (Prosecution of Offences Act 1985, s.1), or, for serious or complex fraud, the Serious Fraud Office, which may investigate and prosecute such fraud (Criminal Justice Act 1987, s.1). Any person may also bring a private prosecution (Prosecution of Offences Act 1985, s.6(1)), but that too is a case in the criminal courts, decided to the criminal standard, not a step in the League’s process. A Commission’s findings do not bind a criminal court (Section 3).

The link runs the other way. A conviction from a court can have consequences under the Rules: a person with an unspent conviction for an offence involving dishonesty or fraud, among others, is disqualified from acting as a club director under the owners’ and directors’ test (Rule F.1.8; Handbook 2026/27, p.81; the same rule in 2022/23, p.75).

The City case shows why this matters. As the Commission found it, the case is not about money taken from anyone. It is about how money from the club’s owner was recorded: the Commission found that shareholder funding was disguised as sponsorship income, so that the club’s income looked far higher than it was under financial rules that ignore owner funding (Core Decision, paras 66 to 68 and footnotes 5 and 6). Those are the Commission’s findings, on the civil standard, and the club has appealed and says it is innocent.

The whole process, step by step

Deciding whether the charges are proved is one step of eleven. Each step below names who acts, the rule that gives the power (tap a rule number to read it and open the League’s PDF at that page), what is decided, and what happens if nobody challenges it.

The whole process

Eleven steps. Proving the charges is step 3; the punishment is step 5.

  1. Step 1: Inquiry · The Board

    Rules: W.1 · W.15

    Whether there is anything to answer. Clubs, players and officials must cooperate; confidentiality is no excuse.

    If unchallengedNot a decision anyone appeals. Refusing to cooperate is itself a breach, and the Board can seek interim orders, such as withholding central funds (W.2, W.59).

  2. Step 2: Route and referral · The Board

    Rules: W.3 · W.8

    How to deal with it: a reprimand, a fixed penalty, a summary fine up to £100,000, an agreed sanction, or a Commission. A referral is announced (W.82.1).

    If unchallengedA summary fine stands unless the club elects, within 14 days, to go to a Commission instead (W.10).

  3. Step 3: Findings: are the charges proved? · A Commission

    Rules: W.45 · W.80

    Liability only. The Board must prove each charge, more likely than not, on any reliable evidence.

    If unchallengedLeads to step 5. The findings decision can also be appealed on its own: City appealed the findings on 1 October 2026, before any sanction hearing.

  4. Step 4: Notice to the statutory regulator · The League

    Rules: Football Governance Act 2025, s.55

    Since 5 May 2026 a competition organiser must notify the Independent Football Regulator before a penalty or sanction is imposed on a club for breaching a “relevant rule”.

    If unchallengedA statutory duty, not a step anyone appeals. Whether a given rule is a “relevant rule” is a question the course has not verified for any case.

  5. Step 5: The sanction hearing · The same Commission

    Rules: W.50 · W.51

    The punishment. Each side puts mitigating factors (and, from 2026/27, aggravating factors); the Commission chooses from a wide menu.

    If unchallengedIf no one appeals within 14 days, the decision on findings and sanction stands.

  6. Step 6: Appeal · An Appeal Board

    Rules: W.62 · W.67 · W.74

    Whether the Commission went wrong. The club can appeal; so can the Board, including against a sanction it thinks unduly lenient.

    If unchallengedThe 14 days is strict (“time being of the essence”) and the Rules give no power to extend it. A missed deadline leaves the Commission's decision standing.

  7. Step 7: Section X review · An arbitral tribunal

    Rules: X.4 · W.79

    Only five things: jurisdiction; fraud, malice or bad faith; serious procedural error; a perverse reading of the law; a decision no reasonable body could reach.

    If unchallengedThe Appeal Board's decision is final (W.79).

  8. Step 8: Court supervision · The High Court

    Rules: X.37 · Arbitration Act 1996, ss.67, 68, 70

    Whether the arbitration was within jurisdiction and free of serious irregularity. Not the merits, and not the law (s.69 is excluded).

    If unchallengedNo challenge within 28 days of the applicable date (s.70(3)): the award is final.

  9. Step 9: Compliance and enforcement · The League and the Board

    Rules: W.56 · B.6

    A points deduction is applied in the table. A fine and costs are a civil debt the Board can sue for. Failing to comply is a further breach.

    If unchallengedThe final lever is expulsion, which only the clubs can vote for, by three-quarters (B.6).

  10. Step 10: Other clubs' compensation claims · A rival club and the Commission

    Rules: W.27 · W.28

    Whether a rival recovers its loss. It can run for years after the sanction (Burnley v Everton: 2024 to 2026).

    If unchallengedA rival refused compensation that does not appeal can bring no further claim over that breach (W.28).

  11. Step 11: Publication · The League

    Rules: W.82

    Hearings are private; referrals are announced and final decisions published. Parties may ask for medical or safeguarding material to be redacted (W.83).

    If unchallengedEvery club and person bound by the Rules is deemed to have consented to publication (W.83).

Where the punishment comes in: the sanction hearing

Only after a complaint is proved does the Commission turn to sanction. In 2022/23 it invites the club to put its mitigating factors (W.50); in 2026/27 it invites both sides to put mitigating and aggravating factors. It then chooses from the menu in W.51: a reprimand, a fine without limit, suspension, a points deduction, a recommendation to replay a match or to expel, compensation, conditions, costs, or any other order it thinks fit.

How that choice is made is best seen in a decided case. In Everton’s case (2023 to 2024) the Commission said:

  • Four aims. The League argued, and the Commission broadly accepted, that a sanction serves punishment, vindicating clubs that complied, deterrence, and the integrity of the game, but must not be disproportionate (paras 91 to 96).
  • The size of the breach first. “The greater the excess, the greater the culpability” (para 99). The extent of the breach is the starting point, so counting it again as an aggravating factor would be double counting (paras 104 to 105).
  • Who proves a factor. “The party asserting an aggravating or mitigating factor bears the burden of proving that factor on the balance of probabilities” (para 99).
  • Deliberate breaches. A “deliberate cynical breach” to gain a sporting advantage might increase culpability; Everton's was not that kind of case (para 104).
  • Factors weighed. Overspending despite warnings; incorrect information to the League; an improving trend in losses (accepted as mitigation); Covid and the war in Ukraine (rejected) (paras 101 to 132).
  • The result. Ten points (para 139). On appeal, six: the Appeal Board found two legal errors and treated the English Football League's sanction guidelines as the closest benchmark for a proportionate sanction (Appeal Board decision, summary).

Sources: Commission decision, 17 November 2023; Appeal Board decision, 26 February 2024. Both are decided records. They show how two panels reasoned, not a rule binding the next one.

Is it all at the League’s discretion? The guardrails

Mostly it is the Commission’s discretion, not the League’s, and it is wide. But it is not unlimited:

GuardrailWhat it does
No general tariffSection W has no formula. In 2023 the League proposed one for profitability breaches (six points plus one for every £5 million over the threshold); the Commission treated it as a submission, not a rule, and said a binding formula would have to be written into the Rules (Everton decision, paras 85 to 90).
Fixed tariffs for some breachesNine points for an insolvency event (E.33). For joining a breakaway competition, 30 points in 2022/23 and up to 30 in 2026/27 (L.10.1). For the 2026/27 Squad Cost Ratio, a written formula: six points plus one for every £6.5 million over the club’s Red Threshold, multiplied for consecutive breaches (Appendix 2, F.4 to F.5).
ReasonsThe Commission must give reasons (W.49), so the sanction can be tested.
Appeal, by either sideThe club can appeal a sanction it thinks too heavy; the Board can appeal one it thinks unduly lenient (W.62). The Everton Appeal Board tested proportionality against the nearest benchmark.
Section X reviewA sanction that “could not reasonably have been reached” by a properly directed body can be set aside (X.4).
The general lawCourts supervise whether a sports body acted fairly and within lawful limits, and a body’s rules can be invalid if they are in unreasonable restraint of trade (Bradley v Jockey Club [2004] EWHC 2164 (QB), quoting Enderby Town v FA; Section 6). Competition law applies to the League’s rules (Section 8).
The statutory regulatorSince 5 May 2026 the League must notify the regulator before imposing a sanction for a relevant rule (Football Governance Act 2025, s.55).

Check yourself

Is a Commission bound by the League's own sanctioning formula for profitability breaches?

Who pays, and how it is enforced

The respondent pays: a club, or an individual manager, official or player charged in their own right. A fine has no upper limit, and costs can include the Commission’s fees (W.51.2, W.51.9). A points deduction needs no enforcing: the League applies it to the table. Not complying with a sanction or a Board notice is a further breach (W.6, W.11), and the final lever is expulsion, which only the clubs can vote for (B.6). Fines recovered go to the League’s operating expenses or, at the Board’s discretion, to charity; costs go to the cost of the Commission (W.57).

“Recoverable as a civil debt”: what that actually means

The Rules say fines and costs are “recoverable by the Board as a civil debt”, and compensation “by the Person or Club entitled to receive it” (W.56). That makes an unpaid fine an ordinary money debt owed under the contract, like an unpaid invoice. It is not a criminal fine and not a court fine: no one is prosecuted for not paying it. In practice there are three ways to collect it, from the easiest to the hardest:

  1. 1. Take it from the club's own money. The League collects the broadcast and commercial money and pays each club its share. If a club fails to pay the League, or another club, the Board can deduct the sum from that club’s central distributions and pay the creditor; it can also withhold distributions, on conditions about how recently the club has failed to pay (E.19). This is why the court route is rarely needed: the League is usually holding money it can use. A rival owed compensation is covered too, because “another Club” is one of the creditors the power protects.
  2. 2. More discipline. Not paying a fixed penalty or ignoring a Board notice is itself a breach (W.6, W.11), which can be sanctioned in turn, up to a recommendation of expulsion.
  3. 3. Court, as a last resort. A debt claim like any other: a claim form; if the club files no acknowledgment or defence, judgment without trial, called default judgment (CPR 12.1, 12.3); then enforcement of the judgment by seizing goods, ordering a bank or other debtor to pay the money over, a charge over property, or a receiver, using one method or several (CPR 70.2; Practice Direction 70, para 1.1). Against a company there is also the insolvency route: a written demand for more than £750 left unpaid for three weeks means the company is “deemed unable to pay its debts”, the ground for a winding-up petition (Insolvency Act 1986, s.123(1)(a)).

One complication sits on the court route. The Rules send “all disputes” between the League and its clubs to arbitration (X.2), so a club that genuinely disputes the debt could ask the court to stay a debt claim for arbitration under section 9 of the Arbitration Act 1996. Whether a stay would be granted for a debt the club does not really dispute is our inference from the Act, not a holding we have found. We have also not found a reported case of the League suing a club for a fine, and we have not searched exhaustively for one.

Check yourself

A club refuses to pay a £1 million fine. What is the League's simplest route to the money?

How the Rules keep disputes inside, and where they cannot

Inside the League’s system

  • One forum: all disputes go to Section X arbitration, and to no other system, so not CAS (X.2).
  • Confidential, private hearings (W.82).
  • A rival’s compensation claim is heard inside the League’s case (W.27), with one appeal and then no further claim (W.28).
  • Agreed sanctions, ratified by three panel members (Sanction Agreements).
  • In 2026/27, chief executives must meet before any arbitration (X.7), and appeals run to a standard 12-week timetable (W.86).
  • A court claim brought instead is stayed under section 9 of the Arbitration Act 1996 (Section 6).

Beyond its reach

  • Anyone who never agreed to the Rules, such as sponsors, broadcasters, lenders or fans, can go to court on their own contracts (Section 10).
  • Statutory employment rights cannot be signed away to the League’s arbitration (Section 3).
  • Tax authorities and prosecutors are not bound by a Commission’s findings (Section 3).
  • The statutory regulator has its own powers over owners and directors (Section 1).
  • UEFA competitions follow UEFA’s rules and CAS (Section 1).

This describes how the Rules channel disputes. It is not a view on whether that is the right design.

A sanction in football and a judgment in court, side by side

Side by side

From liability to the end of the road

  1. Step 1: Liability, then remedy

    Premier League Section W

    Two stages before the same Commission: findings, then a sanction hearing (W.50 to W.51).

    Civil litigation in England and Wales

    Usually one trial deciding liability and remedy, though the court can split them.

  2. Step 2: What is imposed

    Premier League Section W

    A sporting or financial sanction: points, fines, suspension, conditions, compensation.

    Civil litigation in England and Wales

    Damages, an injunction, a declaration; no “sanction” in the disciplinary sense.

  3. Step 3: Who enforces it

    Premier League Section W

    The League itself: it applies points to the table and sues for fines as a debt (W.56).

    Civil litigation in England and Wales

    The winning party, through the court’s enforcement procedures.

  4. Step 4: When it is final

    Premier League Section W

    After 14 days with no appeal; or after the Appeal Board, Section X and 28 days for a court challenge.

    Civil litigation in England and Wales

    When the time to appeal passes, or the last appeal is decided.

The civil column is the general position in England and Wales, not a statement about any particular case.

As at 2026-10-07. Rules are cited by Premier League Handbook edition and rule number; decisions and judgments by date and paragraph; commentary is attributed and never stated as the law. probative.io is a research and investigations practice, not a law firm, and does not provide legal advice; nothing here is a view on any particular matter.