Can another club recover its losses?

Start with the pieces: who is who?

Five kinds of actor matter in a claim between clubs: the twenty clubs acting together as owners, the League company and its Board, the Judicial PanelThe pool from which Premier League Commissions and Appeal Boards are drawn, created by the clubs in 2020. The clubs appoint its Chair. that supplies the deciders, the two clubs at the centre of the dispute, and the players and officials bound through their clubs. The map shows how they connect. The explorer under it lets you pick any one of them and see what it is made of and every role it plays.

The overlap is the thing to hold on to. The same twenty clubs own the company, write the Rules, approve the directors who prosecute, appoint the Chair who picks the deciders, and then appear in a case as the club accused or the club that lost out. The Board is the company’s management and also its investigator and prosecutor. Players are not owners or parties to the clubs’ arbitration agreement at all, yet they can be questioned, called as witnesses and charged in their own right.

Why can one club claim against another at all?

Because the Rules are a contract between the clubs, not only between each club and the League. Membership is an agreement “between the League and each Club” and “between each Club” to be bound by the Rules (B.14Membership is a contract with the League and between the clubs2022/23: B.14, p.57 ↗2026/27: B.14, p.61 ↗“Membership of the League shall constitute an agreement between the League and Club” (2026/27)Joining binds each club, with the League and with every other club, to the Laws of the Game, FA rules, the Articles, the Rules and FIFA and UEFA statutes.All rules, both editions →). When one club breaks them, it breaks a promise it made to every other club. That is why the Commission in Burnley v Everton treated a rival’s claim as “a contractual claim in which conventional principles of causation applied” (decision, para 16), and why the clubs in that case accepted that the Rules create “a multi-lateral contract” (decision, Attachment 5, para 3).

The Rules then add their own machinery on top of the contract: a Commission may order a club in breach to pay compensation to another club (W.51.5), and the rival can ask it to (W.27A rival asks for compensation2022/23: W.27, p.138 ↗2026/27: W.31, p.155 ↗“it may wish to exercise its power under Rule W.51.5 to award compensation to any Person or to any Club (or club)” (2022/23)The Commission may signal it may award compensation, on its own or on a rival's representations.All rules, both editions →). The rest of this section is about how that machinery works and where it stops.

The doors: which routes are open?

A club that thinks a rival’s rule breach cost it points has a small number of routes. Two lie inside the League’s own process and the others are narrower or shut. The table gives the whole map; the sections after it take each in turn.

Inside the League: how a rival gets a hearing

Through the side door, not the front. In 2023 five clubs asked to join the League’s case against Everton. The chair ruled that the Commission “has no inherent jurisdiction”, that “it is the role of the Premier League to bring and prosecute complaints”, and that W.27 is how a club claiming loss is heard “in the same proceedings” — its claim “contingent upon the breach being upheld, causation and other factual issues” (ruling of 9 May 2023, paras 3 to 6).

So the clubs were not made parties. They had no say on whether there was a breach, and no disclosure of the documents about it (para 8). Their moment was the compensation stage, once the League had won. A rival that wants the League to act has the Board to persuade: the Rules we read give a club no right to make the Board prosecute, and the Board chooses between a reprimand, a fixed penalty, a summary fine, an agreed sanction or a Commission (W.3The Board's choice of route2022/23: W.3, p.137 ↗2026/27: W.6, p.153 ↗“The Board shall have power to deal with any suspected or alleged breach of these Rules by” (2022/23)Reprimand, fixed penalty, summary fine, agreed sanction, or referral to a Commission.All rules, both editions →, W.7). A rival also cannot ask for interim measures against the club, because only the Board and the respondent are parties (W.22Who the parties are2022/23: W.22, p.138 ↗2026/27: W.26, p.155 ↗“The parties to proceedings before a Commission shall be” (2022/23)The Board and the club or person accused. Nobody else.All rules, both editions →, W.58 to W.59).

What a rival can do is make representations to the Commission, which may then indicate that if the complaint is upheld it may award compensation, and direct evidence of loss (W.27, W.52, W.53). A rival invited to address the Commission on compensation may attend the hearing but speaks only with the chair’s leave (W.53). The rule reaches beyond the twenty: a Commission may order compensation “to any Person or to any Club (or club)” (W.51.5), and a capital-C “Club” is a member while a small-c “club” is “an association football club not in membership of the League” (A.1.41 to A.1.42).

Walk through a claim, step by step

Twelve steps, from the contract to the payment. At each one the strip lights up who is acting. Switch between the real case and an invented one to see the same step twice.

Two things in the table are easy to miss. The compensation claim was paused while the League’s case ran, and Burnley revived it only after that case, and the appeal from it, had ended. And the rule numbers in the decision are not the 2022/23 ones: the Commission records that the clubs quoted different editions of the Rules and used 2022/23, “the numbering is different”, while “nothing turns on this” (decision, Attachment 5, “The Rules”, para 2). Section 2 explains why a rule number means nothing without its season.

What must the claimant prove, and to whom?

To the Commission, not to the League. The League prosecutes the breach; the claimant proves its own loss to the body hearing the claim. In Burnley v Everton the decision breaks it into links, and the claimant had to win each one. Step through them: for each link, what Burnley argued, what Everton argued, and what the Commission held.

A note on “£6.5 million”, because the figure appears twice in this area and the two are unrelated. In Burnley v Everton, Everton’s expert spread the £19.5 million overspend evenly at £6.5 million per season; the Commission rejected that split, holding the benefit cumulative (para 96). Separately, the 2026/27 Squad Cost RatioThe Premier League rule, from 2026/27, limiting a club's squad costs to 85% of its football revenue plus an error margin. A breach costs points by formula. Rules price a breach for sanction purposes at one point for every £6.5 million over a club’s Red Threshold, plus six (Appendix 2, F.4 to F.5Squad Cost Ratio: the points formula2022/23: not in this edition2026/27: Appendix 2, F.4 to F.5, p.319 ↗““Fixed Point Deduction” means six points” (2026/27)Six points, plus one point for every £6.5m over the club's Red Threshold (rounded up), multiplied for consecutive breaches.All rules, both editions →). That formula decides a sanction, not a rival’s loss: a points deduction “is not designed to assess and reflect the sporting benefit from the breach” (para 67, quoting Lord Dyson).

The claim is not a further punishment. The Commission held it is “a contractual claim in which conventional principles of causation applied” (para 16). The decision is read here as published on 10 June 2026. Everton is appealing, and the course treats every holding as a first-instance finding that could change on appeal.

Does money buy points? What the evidence says

Over the long run, strongly. The economist Stefan Szymanski reports that wage spending is “highly correlated with league position over time”, explaining around 90% of the variation (OpenLearn interview). In Burnley v Everton it was common ground that spending confers a sporting advantage (para 71), and Burnley’s experts found a high correlation between wages plus amortisation and points over twelve seasons (para 82).

But a long-run correlation across many clubs is not proof that a particular sum changed a particular result. The Commission accepted that no mathematical correlation could be drawn from the industry evidence alone, and decided on the balance of probabilities, weighing the experts’ models and that witness’s experience together (paras 80, 167 to 170). Any claimant has to answer the same questions:

1. How much money was involved, and in which seasons?
2. What did it buy (players, wages, a coach), and when?
3. How did that turn into points, and in which matches?
4. Without it, would the outcome that caused the loss have been different, more likely than not?

The course asks these questions of no live case. For City it states only what the Commission found about amounts and arrangements (Section 7 and the running case below).

Try it: change the results, match by match

Every opponent played the chosen club twice, so what it could have gained depends on its two actual results: up to six points if it lost both, five if it lost one and drew one, three if it lost one and won one. Flip a result and both clubs’ points move; the table re-ranks by the Rules’ own tie-breaks (C.17Separating clubs level on points2022/23: C.17, p.59 ↗2026/27: C.17, p.63 ↗“two or more Clubs are equal on points, Goal Difference and goals scored” (2026/27)Points, then goal difference, then goals scored; if still level where it matters, head-to-head results.All rules, both editions →). The tool covers the seasons whose full results the League prints in the Handbooks held; it starts on no particular club.

The issues map: who might claim, what they must prove, and when

A broad-brush map of the web of contracts around a breach. Each row is a category, not a view on any case; where the course has not researched a route, it says so.

Players, managers and agents: can they claim too?

Possibly, but by a narrower path than a rival club, and one no decision we have read has tested. A club’s bonus scheme can pay on a league position, a title or a European place (Section 9). A player who missed such a bonus because a rival broke the Rules has lost money. The hard question is not the loss but the route: how a player, who never signed the clubs’ agreement with each other, gets a hearing against another club.

There are three doors to try, and each has a question behind it.

1. 1. Inside the League’s case. The Commission may indicate that it may award compensation “either of its own accord or as a result of representations from a Person, Club (or club)”, and may award it “to any Person” (W.27A rival asks for compensation2022/23: W.27, p.138 ↗2026/27: W.31, p.155 ↗“it may wish to exercise its power under Rule W.51.5 to award compensation to any Person or to any Club (or club)” (2022/23)The Commission may signal it may award compensation, on its own or on a rival's representations.All rules, both editions →, W.51.5; W.31 and W.64.5 in 2026/27). A “Person” includes “any natural person” (A.1.170; A.1.220 in 2026/27). On the wording, then, a player can ask. But the Commission decides in its “sole discretion”, the route exists only while a League case is running, and the one-chance rule in W.28 is written for a “Club” claiming compensation, not a Person, so it says nothing about a player who is refused.
2. 2. The FA’s arbitration. The FA’s rules send “any dispute or difference between any two or more Participants”, including one arising out of a competition’s rules, to FA arbitration, and a Participant includes clubs, players, managers and FA-registered agents (FA Rules 2026/27, Rules A2 and K1). This is the kind of tribunal Sheffield United used against West Ham in 2008. But Rule K1 “shall not apply to any dispute or difference which falls to be resolved pursuant to any rules” of a competition. Whether a player’s claim falls to be resolved under the League’s Rules, because door 1 is open to a Person, is not decided in anything we have read.
3. 3. A court. The clubs’ arbitration clause binds the League, each club and each director, not players (X.2Everything goes to arbitration, and nowhere else2022/23: X.2, p.144 ↗2026/27: X.2, p.163 ↗“that no other system or mode of arbitration will be invoked to resolve any such dispute” (2022/23)All disputes between the League, clubs and club directors go to arbitration in England, under English law; no other arbitration system (so not CAS).All rules, both editions →), so it does not send a player to Section X. A court claim still needs a legal basis, and a player’s contract is with their own club, not the rival. One possibility is the Contracts (Rights of Third Parties) Act 1999, which lets a non-party enforce a term that “purports to confer a benefit on him” (s.1(1)(b)). The Rules exclude that Act for particular rules, such as D.3, but we found no general exclusion, and no decision on whether the financial rules confer a benefit on players. If door 2 covers the dispute, a court would ordinarily stay the claim for arbitration (Arbitration Act 1996, s.9).

Whichever door, the player carries the club’s whole burden and one link more. They must show the breach changed their club’s outcome, link by link, exactly as in the causation walk-through above; then that their bonus turned on that outcome under the scheme’s own wording, and that they would have qualified (still at the club, enough appearances); then the amount. The clock is the same as a club’s: six years, held back if the breach was deliberately concealed (Limitation Act 1980, ss.5, 32).

A manager stands in the same place, with their own contract in place of the bonus scheme. An agent is a step further back: any loss would come through the agent’s own contract with the player, such as a fee calculated on the player’s earnings. We found no published analysis of an agent’s claim.

Has it been tried? Once, as far as we found. After Sheffield United’s arbitration win over West Ham, a number of its players, through a lawyer, looked at claims of their own for lost earnings and bonuses after the 2007 relegation, and their former manager said, “I’ll be looking into this now” (reported 17 March 2009, citing The Times; The National). We found no report of how those claims ended.

Also changes, on approval: the fifth row of the routes table, the player row of the issues map and a new manager and agent row (both already shown on this preview), the “two points remain open” paragraph below, and the running case.

“One chance, then silence”, in plain words

This is the rule at W.28One appeal, then no further claim2022/23: W.28, p.138 ↗2026/27: W.32, p.155 ↗“will not be able to bring any further claim of any kind (whether for compensation, in damages or otherwise)” (2022/23)A club refused compensation that does not appeal, or loses, can bring no further claim over that breach.All rules, both editions →. It matters only to a club that has gone down the Section WThe disciplinary part of the Premier League's Rules: inquiries, Commissions, sanctions and appeals. route above. Read it as a trap with a door in it.

1. You go through the door. The Commission indicates that it may award compensation (W.27), hears evidence from both sides, and decides.
2. It says no. If the Commission decides after that hearing that no compensation is to be awarded, the claimant club may appeal to an Appeal Board.
3. After that, the door shuts. If the club does not appeal, or its appeal is dismissed, it “will not be able to bring any further claim of any kind (whether for compensation, in damages or otherwise)” against the club in breach, arising out of that breach (W.28).

So the rule is a bar on a second attempt, not on a first. Three points follow from the wording. It applies once the Commission has indicated that it may award compensation and then, having heard evidence from both sides, refuses it. It stops claims “of any kind”, so a club cannot lose in Section WThe disciplinary part of the Premier League's Rules: inquiries, Commissions, sanctions and appeals. and then arbitrate or sue for damages over the same breach. And it speaks of the Respondent club and the breach “in respect of which the Commission was appointed”, so it does not bar a claim for a different breach. In the 2026/27 Handbook the same rule is W.32.

What the rule does not say is what happens to a club that never asks for a W.27 indicationA Premier League Commission's signal that it may order compensation to a club harmed by a breach, letting that club prove its loss. at all. On the face of the wording W.28 does not reach it. No decision we have read says whether such a club could go straight to arbitration, and the course does not guess.

Taking it outside the League: how far can it go?

Not into court first. Rule X.2Everything goes to arbitration, and nowhere else2022/23: X.2, p.144 ↗2026/27: X.2, p.163 ↗“that no other system or mode of arbitration will be invoked to resolve any such dispute” (2022/23)All disputes between the League, clubs and club directors go to arbitration in England, under English law; no other arbitration system (so not CAS).All rules, both editions →makes every dispute between the clubs a matter for private arbitration, in England and Wales, under English law, and “no other system or mode of arbitration will be invoked” (X.2.1 to X.2.4). A club that sues anyway will be stopped: the court “shall grant a stay” unless the agreement is void, inoperative or incapable of being performed (section 9 of the Arbitration Act 1996). The Court of Appeal applied the League’s clause in Fulham v Richards [2011] EWCA Civ 855.

What is left is a Section XThe arbitration part of the Premier League's Rules. It reviews a disciplinary decision on five narrow grounds, not as a second appeal. arbitration (X.3.3, “other disputes arising from these Rules or otherwise”). It begins with a request in Form 26 in 2022/23 (X.7); in 2026/27 the chief executives must first meet and wait a week, and the form is Form 25 (X.7Starting an arbitration2022/23: X.7, p.144 ↗2026/27: X.8, p.163 ↗“upon the party requesting an arbitration serving upon the other party (and copied to the Board) a request” (2022/23)By serving a request on the other side, copied to the Board.All rules, both editions →, X.8). The tribunal is three lawyers, one chosen by each side and a chair chosen by them (X.8 to X.10). It can order the payment of money and award interest (X.26.4 and X.26.5 in 2022/23). A court then only supervises (Section 6). The Rules also bar CAS: a Premier League dispute stays in this system.

The idea is not new. In 2008 a football tribunal under an FA rule held that West Ham’s breach of the League’s rules “amounted to a breach of contract” and was “an effective cause” of Sheffield United’s relegation (chambers case note on [2008] EWHC 2855 (Comm)). West Ham then tried to appeal to CAS and was stopped by an injunction, because the award was final and binding. That route has the same lesson as X.2.4: a club-against-club claim for a breach of the Rules stays in the football arbitration system.

For those who never agreed to the Rules (a sponsor, a lender, a broadcaster, a fan), the court is open on their own contracts, and the League’s arbitration clause does not bind them. That would be an ordinary civil claim: a claim form and particulars, disclosure, witnesses and experts, a public trial, and an appeal with permission (the civil column in Section 4). It would turn on that party’s own contract and the general law, not on the Rules, and a Commission’s findings would not bind it the way they bind two member clubs.

Two points remain open and the course says so. Whether a rival can start a Section XThe arbitration part of the Premier League's Rules. It reviews a disciplinary decision on five narrow grounds, not as a second appeal. arbitration without first asking a Commission for a W.27 indicationA Premier League Commission's signal that it may order compensation to a club harmed by a breach, letting that club prove its loss. is not decided in anything we have read. And the FA’s rules still have an arbitration clause like the 2008 one (Rule K), but it does not apply to a dispute that falls to be resolved under a competition’s own rules; between two member clubs X.2 does that, so the wording points away from the FA route. No decision we have read says so.

When is it too late?

Ordinarily six years after the cause of action arose (Limitation Act 1980, s.5). But where “any fact relevant to the plaintiff’s right of action has been deliberately concealed from him by the defendant”, the clock starts only when the claimant found out, or with reasonable diligence could have (section 32(1)(b) of that Act). Arbitrations run on the same clock as courts (section 13 of the Arbitration Act 1996).

A letter reserving rights does not, on its face, stop that clock; bringing a claim, or agreeing a standstill, does. Whether a W.27 application or a notice counts as bringing a claim before a Commission, no source we have found decides. That is why the question of when to act, in the season or afterwards, is a real one: the clock may be running while the League’s own case is still undecided.

A rival’s claim in football and a claim for breach of contract in court