Business of Sports · SOCCER

Man City financial case: What rivals must prove to win compensation

The reported ruling leaves rival clubs facing a separate task: connecting proven breaches to financial losses. The Burnley–Everton decision shows how that evidence can be tested.

The Manchester City crest above the Etihad Stadium entrance.
The Manchester City crest outside the Etihad Stadium. File photograph. · Credit: Getty Images
The illuminated exterior of Manchester City’s Etihad Stadium.
Manchester City’s Etihad Stadium. File photograph. Photo: AP · Photograph source

Manchester City’s reported financial-rule breaches could expose the club to compensation claims from rivals, but a finding against City would leave those clubs with another task: proving what the breaches cost them.

BBC Sport reported Friday that sources said an independent panel had found City guilty of most of the alleged breaches. The BBC cited The Athletic’s reporting that sanctions had not been decided. City has consistently denied wrongdoing and said the proceedings remained unfinished.

“The Premier League process remains ongoing, with significant elements to be completed, and subject to strict confidentiality,” a club spokesperson said in a statement reported by the BBC.

Publication of the commission’s written judgment was still awaited, the BBC reported. Until those reasons are available, the precise conduct established by the panel and its treatment of the financial evidence remain unclear to readers outside the proceedings.

Those details would matter to any club seeking compensation. A finding that rules were broken would not, by itself, establish how much another club lost or whether the breach caused that loss.

What the financial case concerns

The Premier League’s February 2023 referral concerns several different obligations. Its allegations about accurate financial information cover the 2009/10 through 2017/18 seasons and specifically address revenue, including sponsorship, related parties and operating costs.

Other allegations concern disclosure of manager remuneration from 2009/10 through 2012/13 and player remuneration from 2010/11 through 2015/16. The referral separately identifies compliance with UEFA regulations, Premier League profitability and sustainability rules, and cooperation with the investigation.

The cooperation allegations run from December 2018 to the date of the referral. That distinction matters when discussing the years covered: the published charge sheet does not accuse City of the same financial-reporting conduct across every season through 2023.

These categories also explain why a charge total does not supply a damages calculation. The referral lists obligations and seasons; it does not put a price on the harm allegedly suffered by each opponent.

A compensation argument would need to connect the particular breaches established in the proceedings to the losses being claimed. The panel’s written reasons would explain which parts of the league’s case it accepted and the evidence supporting those conclusions.

What rival clubs would have to establish

Arsenal, Liverpool, Manchester United and Tottenham reportedly took steps to protect their ability to seek compensation before a ruling. In November 2024, AFP reported, citing The Times, that the four clubs had lodged notices reserving their rights because of concerns about legal time limits.

Reserving the right to claim does not establish liability or determine what a club might recover. The November report concerned steps taken before the outcome of City’s case, rather than compensation already awarded.

A published decision involving Burnley and Everton provides a detailed example of how financial harm can be argued. Burnley sought compensation after its relegation in 2021/22, claiming Everton’s breach of profitability and sustainability rules had enabled Everton to stay up at Burnley’s expense.

Burnley initially proposed using Everton’s six-point deduction as a measure of the advantage gained. Applied to the earlier season’s table, that deduction would have placed Everton below Burnley.

The commission rejected that shortcut in paragraph 66 of its decision. A points deduction was a punishment for breaking the rules, it explained, and did not measure how many points the offending expenditure actually produced.

Both clubs instead presented expert evidence about the sporting effect of Everton’s spending. The commission then assessed the financial difference between Burnley’s actual experience following relegation and its position in scenarios in which it had remained in the Premier League.

Herbert Smith Freehills Kramer’s analysis describes the substantial disagreement between the experts. Burnley’s experts estimated that Everton’s excess spending generated between 3.85 and 7.13 additional points. Everton’s expert put the benefit between 0.2 and 2.6 points, which would have left Burnley relegated.

The decision assessed approximately £26 million in loss before interest. Herbert Smith Freehills Kramer’s published analysis described a further approximately £9.1 million in pre-award interest calculated to July 31, 2025, with interest continuing to accrue.

The commission preferred Burnley’s evidence and concluded, on the balance of probabilities, that Everton’s breach caused Burnley’s relegation. Its reasoning depended on that season’s circumstances and expert evidence. It did not establish a universal formula assigning league points to each pound spent.

Everton appealed the decision, so its reasoning remains contested. The comparison does not establish that a City claimant would succeed; it demonstrates the additional work required after a financial breach has been found.

The Burnley commission also limited the compensation proceedings to breaches already established in the underlying case. Burnley could not expand its claim by relying on further allegations that had not been adjudicated.

For a club alleging it missed European qualification because of City’s conduct, the equivalent questions would concern the relevant season, the established breach, its sporting effect and the income actually lost. Finishing immediately below City would identify a possible argument, rather than establish its financial value.

The financial significance of competition results

City’s own accounts show why a change in sporting outcomes can have substantial financial consequences. The club reported £694.1 million in revenue for the year ended June 30, 2025, including £278.6 million from broadcasting.

Broadcasting therefore supplied approximately 40.1% of revenue, calculated from the financial statements. UEFA broadcasting income fell from £104.6 million to £70.7 million between 2023/24 and 2024/25, a decline of approximately £33.9 million.

The directors principally attributed that fall to City exiting the Champions League in the knockout phase play-off after reaching the quarterfinals the previous season. Club World Cup income partially offset declines in broadcasting revenue.

These are historical figures, not an estimate of what a future punishment would cost. They show the financial importance of competition performance without establishing a loss caused by the current case.

Why City’s other cases do not settle this one

City’s successful challenge to its European ban in 2020 concerned a separate UEFA proceeding. The Court of Arbitration for Sport overturned the exclusion and reduced the fine to €10 million for failing to cooperate with UEFA’s investigation.

CAS said most alleged breaches were either not established or time-barred. The decision therefore contained different conclusions about different allegations, alongside the retained noncooperation fine. It did not determine the Premier League charges brought three years later.

The dispute over associated-party transaction rules was also separate. In September 2025, City and the Premier League reached a settlement ending that arbitration, with City accepting that the current rules were valid and binding.

That settlement concerned the rules governing transactions involving associated parties. It did not announce a settlement of the financial charges brought in February 2023.

What remains unresolved

The Premier League’s current handbook distinguishes several possible consequences. Its commission powers include fines, points deductions and compensation, alongside the power to recommend expulsion from league membership.

A fine and compensation also have different recipients. Under the handbook, fines recovered by the league support its operating expenses or, at the board’s discretion, charitable purposes. Compensation would instead be paid to the person or club awarded it.

Those powers establish available options, not the punishment City will receive. The handbook also provides for appeals and permits variation of standard procedural directions, making a guaranteed completion date impossible to derive from the usual timetable alone.

For prospective claimants, the written City findings would identify the breaches on which a compensation case could be built. Evidence would then be needed to establish the alleged sporting consequences and the financial loss flowing from them, as the Burnley proceedings illustrate.

A published judgment would allow clubs and readers to examine what the panel found and why. Any disciplinary penalty, the income consequences of a sporting sanction and compensation payable to another club would still need to be distinguished when assessing the eventual financial cost.

Sources and notes

  1. https://www.bbc.com/sport/football/articles/cr89jjwy4nqpo
  2. https://www.bbc.com/sport/football/articles/cx30540044q0o
  3. https://www.premierleague.com/en/news/3045970
  4. https://sportstar.thehindu.com/football/arsenal-liverpool-man-united-spurs-reserve-compensation-claims-manchester-city-found-guilty-financial-breaches/article68866979.ece
  5. https://resources.premierleague.pulselive.com/premierleague/document/2026/06/10/14b0acd1-3d6a-41e0-a862-fffce1d6c2cc/BURNLEY-v-EVERTON-Compensation-Decision-with-Attachments-Redacted-.pdf
  6. https://www.mondaq.com/uk/trials-appeals-compensation/1806682/first-inter-club-compensation-award-for-breach-of-premier-league-rules
  7. https://www.bbc.com/sport/football/articles/cqx1wqr3yjno
  8. https://www.mancity.com/annualreport2025/wp-content/uploads/2025/11/mcfc_financial_report_2025_.pdf
  9. https://www.tas-cas.org/generated/assets/lists/dceab111-07bc-435f-b5f9-de88eff9db72/CAS_Media_Release_6785_Decision.pdf
  10. https://www.premierleague.com/en/news/4407130/premier-league-statement
  11. https://resources.premierleague.pulselive.com/premierleague/document/2026/07/31/8a890ff9-176c-4364-a8ff-e08f995e2c86/TM2040_PL-Handbook-and-Collateral-2026-27_Digital_31.07.pdf