What did the Premier League commission actually find against Manchester City? That for nine seasons, from 2009/10 to 2017/18, the club presented money from its owner as sponsorship income from Abu Dhabi companies, kept some manager and player pay out of the contracts it should have been in, and then made (in the commission’s words) “concerted efforts to stop and frustrate” the League’s investigation. Every charge was proved except one of the co-operation charges, Charge 4(B).
The redacted core decision was published on 29 September 2026. It’s 40 pages, a fair amount of it blacked out, and it’s really a roadmap to 37 appendices that haven’t been published yet. There’s no sanction yet, so this piece is about what was found and how.
The sponsorship deals were shams, and the fallback got to the same place
The commission calls it the Disguised Funding Scheme. From early 2010 the club signed sponsorship agreements with Abu Dhabi sponsors at fees well above fair market value. The sponsor was only ever liable for a fraction of the fee (the “Base Sum”), and the rest (the “Tagged Sum”) was paid by ADUG, the owner’s investment company. The club booked the whole fee as commercial revenue.
Across the nine seasons the accounts showed £949.94 million of sponsorship income from Abu Dhabi sponsors. The sponsors actually paid £119.25 million, and the other £830.69 million came from ADUG and should have been recorded as equity.
The point of doing it was that owner funding doesn’t count as income under UEFA’s financial fair play rules, whereas sponsorship does. In 2010 there was a simpler motive as well, which was that the club didn’t want to beat Chelsea’s record single-season loss of £140 million. The example I found most telling is from May 2013, when the club found itself £9.9 million short of UEFA’s break-even requirement less than a week before the year end. Within days, amended sponsorship agreements appeared (bonuses for events that had already happened, and a US tour) without the sponsors, the decision says, even being approached.
The commission’s primary finding is that the agreements were shams. It then says that, if it’s wrong about that, the economic substance differed from the legal form anyway, so the accounts still didn’t give a true and fair view. I’d expect that approach in a decision everyone knew would be appealed, and it means City has to overturn both findings rather than one. The commission also sidestepped the most politically awkward question, about how Abu Dhabi governance works, by deciding it didn’t need to know how or why the sponsors agreed to take part, only whether they did.
Pay that sat outside the contracts
The second group of charges is about liabilities rather than income. Three people connected with the club (the names are redacted) were paid under consultancy agreements with other entities, funded by ADUG, when the money was really remuneration the club owed them. Those sums came to £8.866 million, £7.4 million and £500,000. Separately, under what the decision calls the Fordham Arrangement, the club sold its entitlement to benefit from players’ image rights to a company the commission describes as little more than a front for ADUG, at an inflated price, with ADUG money then used to make the image rights payments to players.
Image rights arrangements and consultancy agreements are a normal part of how people in football get paid, and nothing in the decision suggests otherwise. The problem here was that they moved the club’s own costs off its books and, in the manager and player cases, breached the rules requiring the terms of employment to be set out in the contract with the club.
Breaching the accounting rules was also a breach of good faith
Each accounting finding comes with a second one: the club knew the accounts didn’t give a true and fair view (or was reckless about it), so it also breached its duty of utmost good faith to the League and the other clubs, and “clearly intended to circumvent the PL Rules”.
I found that interesting, because English law generally doesn’t impose a duty of good faith in ordinary commercial contracts. A members’ association can write one into its rules, and the Premier League has.
On the co-operation charges, the League reserved the right to argue that City’s answers during the investigation were dishonest, which would have been a more serious form of non-co-operation. It never amended its charges to say so, and the commission therefore declined to say anything further about it. Anyone bringing disciplinary proceedings should take from that the need to put the whole case in the charge.
How the commission decided it
The decision says each charge needed strong, cogent evidence (the detail on burden and standard is in an appendix I haven’t seen). A lot turned on inference: what documents meant, what could be drawn from witnesses who weren’t called and documents that weren’t produced. The commission found that several of City’s important witnesses gave evidence that was false, and that some of them knew it was untrue.
It also refused to treat each charge in isolation. Having found intentional misconduct on one, it looked harder at the others, and I’d expect other tribunals dealing with multi-charge cases to do the same.
What the League and the club have said since
Neither side’s statement is neutral, and I wouldn’t expect them to be. The Premier League’s statement says the decision “vindicates” its decision to bring the case, which is what anyone says after winning at first instance. Its headline figure of more than £900 million adds the overstated income and the understated costs together. That’s fair on the decision’s own numbers, although you won’t find that total in one place in it.
City’s statement of 29 September calls the decision the commission’s “opinion”, says it contains clear material errors of law, principle and fact, and confirms the club will appeal. Calling it an opinion is a choice; the League says the commission ruled, and an Appeal Board confirmed, that it’s a final award, which is why it could be published at all. The chairman’s letter to fans, written after the result leaked but before publication, said confidentiality stops the club sharing why it’s confident, and that every word of its February 2023 statement still holds true.
That 2023 statement welcomed an independent commission to consider “the comprehensive body of irrefutable evidence” supporting the club. I’ve found that line hard to get past. City got its independent commission and put its evidence in, including a 200-page Answer, 24 witnesses, expert reports and the explanation that the top-up payments came from government support for the sponsors. The commission rejected that explanation as concocted after the event and found that some of the club’s witnesses knowingly gave untrue evidence. If there’s irrefutable evidence somewhere, either it wasn’t put in front of the one body that had to decide, or it didn’t persuade three panel members who spent 42 days listening, which is a long way short of irrefutable.
In fairness to City, confidentiality is real, and it binds the League too, so I wouldn’t make much of the club not publishing its evidence. Until the appendices are out, we’re reading the conclusions without most of the reasoning. The decision isn’t one-sided either. The commission accepted that most of Project Longbow was legitimate and dismissed one of the co-operation charges, and the League itself accepted that two of the Abu Dhabi deals were negotiated at arm’s length and at fair value. The club’s complaints about how the League ran the investigation were considered and rejected, though, so the “partisan influence” line in its statements hasn’t got anywhere so far.
What happens next
Sanction will be decided at a separate private hearing before the same commission. City has until 2 October to appeal to an Appeal Board of three, chaired by someone who has held judicial office, which can allow the appeal, dismiss it or vary the decision. Anything you read about points deductions or stripped titles is, for now, speculation.
Whether City has any route to the courts after that, and how narrow it would be, depends on how the Rules and the Arbitration Act interact, and I’d rather not guess in public.
What I’d take from it if I ran a club
If a sponsor is connected to your owner, assume someone will one day ask whether the fee is at fair value and who really paid it. Get the valuation evidence at the time and disclose the relationship as a related party transaction. City was found in breach on disclosure alone, separately from the true and fair view point.
If someone is being paid for work they do for the club, the terms belong in their contract with the club. Paying part of it through a consultancy agreement with an owner-linked company is what caused City problems here.
And if you’re buying a club, a governing body investigation into pre-completion conduct is exactly the sort of thing due diligence should dig into, with indemnities in the purchase agreement to match, because on a share sale any sanction falls on the club after completion rather than on the seller.
I advise on sports law alongside company sales and purchases, including sponsorship, player contracts and buying a club. Get in touch if you need some help.
Written by Steven Mather, a business solicitor acting on company sales and purchases. This is general information about the law, not legal advice on your situation.
Written by Steven Mather, a business solicitor acting on company sales and purchases. This is general information about the law, not legal advice on your situation.
