Manchester City: What the Core Decision Found

Three days ago, the central limitation on assessing Manchester City's financial case was that the independent commission's decision had not been published. It has now been released. The commission found all of the serious financial charges proved, concluded that City's accounts overstated income by more than £830 million across the relevant years and identified substantial additional income and expense adjustments. It also found that the club would have breached both Premier League and UEFA spending limits by a very substantial amount on restated numbers. The sanction comes next. City dispute the findings and have said they will appeal.

TL;DR

The Premier League published the independent commission's redacted Core Decision on 29 September, replacing last week's reported finding with an official determination.
Manchester City dispute the findings and have said they will appeal. City's full position is set out in its club statement of 29 September.
The commission found every charge proved except Charge 4(B), one element of the allegations concerning City's co-operation with the investigation.
The commission found that commercial arrangements used by City were shams through which, on its findings, owner Abu Dhabi United Group funded amounts recorded as sponsorship income.
City's income across the relevant years was found by the commission to have been overstated by more than £830 million.
The commission separately identified £24.5 million of Fordham operating income that it concluded should have been treated as an ADUG equity contribution, £49.414 million of Fordham-related costs that it found should have appeared as City operating expenses, and further understated expenses.
On restated numbers, the commission found City breached UEFA break-even requirements and Premier League PSR requirements by a "very substantial amount".
The commission also found City made "concerted efforts to stop and frustrate" the Premier League investigation, although one category of co-operation charge was not proved.
No sanction has yet been imposed. That will be determined at a separate private hearing.
The decision gives potential compensation claimants a materially stronger factual foundation, but does not establish either causation or the value of any losses.

From Reported Finding to Published Decision

Sunday's Bloodstone briefing deliberately stopped where the evidence stopped. At that point, Reuters, The Athletic and The Times had reported that the commission had found against Manchester City on 114 of 115 charges, but the decision itself was unpublished, no sanction had been determined and City maintained that significant parts of the process remained incomplete.

That position changed on 29 September when the Premier League published a redacted 40-page Core Decision from the independent commission. The document says the commission found each charge proved except Charge 4(B). City dispute those findings and have announced their intention to appeal.

This is therefore no longer an analysis built around source-based reporting of liability. There is now a published first-instance regulatory decision against which the financial consequences can begin to be assessed, alongside a stated challenge from the club.

What the Commission Found

The largest finding concerns income. The commission concluded that City's financial statements from 2009/10 to 2017/18 wrongly recorded as income sums that, on its findings, should instead have been treated as equity contributions from Abu Dhabi United Group, City's owner, which was not a party to these proceedings. It states that the club's income across those years was consequently overstated by more than £830 million.

The decision identifies further adjustments. The commission found that expenses had been understated by more than £8.866 million under one arrangement, £7.4 million under another and £500,000 under a third. Under the Fordham image-rights arrangement, it concluded that £24.5 million recorded as operating income should instead have been treated as an ADUG equity contribution. It also found that £49.414 million of costs excluded from City's operating expenses should have been recognised as City's operating expenses.

These figures show why the financial scope of the case extends beyond the £830 million income finding. They should not, however, simply be added together and presented as a single measure of City's financial benefit: they comprise different accounting adjustments across both income and expenditure, and the commission itself did not define a combined headline total.

The commission concluded that City's financial statements did not provide a true and fair view of its financial position and that relevant sponsorship agreements should have been disclosed as related-party transactions. More significantly, the commission found that City knew its accounts did not give a true and fair view, or was reckless as to whether they did, and concluded at paragraph 114 that by its conduct the club "clearly intended to circumvent the PL Rules". City rejects that conclusion and says the decision contains material errors of law, principle and fact.

The Alternative Finding Matters

The commission's conclusion does not depend entirely on its finding that the sponsorship arrangements were shams.

It also considered what would follow if its primary characterisation of those arrangements were wrong. On that alternative case, the relevant sponsorship agreements would have to be reduced to fair market value for regulatory purposes. The commission found those fair values were very substantially below both the recorded sponsorship fees and the commercial-revenue figures used in City's accounts. After substituting fair-market values, the commission found that City still failed the Premier League's PSR requirements in every season covered by the relevant charge.

The same basic issue arose under UEFA's break-even regime. On the commission's primary findings, removing overstated revenue and adding understated liabilities and expenses left City failing the applicable break-even requirements by a "very substantial amount".

That alternative analysis is important because it gives the first-instance decision a second regulatory route to substantially the same conclusion. It does not make the decision immune from appeal, but an appeal aimed solely at overturning the commission's finding that the arrangements were shams would not necessarily dispose of the spending-limit findings.

The Investigation Became a Finding in Its Own Right

The commission also examined City's conduct during the Premier League investigation. It found that the club made "concerted efforts to stop and frustrate" the investigation and breached its duties of co-operation in the majority of the respects alleged under Charge 4(A), every respect under Charge 4(C), and the respect alleged under Charge 4(D). Charge 4(B) was not proved.

The commission also showed an important limit to its approach. The Premier League had reserved the right to argue that statements made by City during the investigation amounted to additional and potentially more egregious acts of non-co-operation if the substantive financial charges were proved. But those allegations were never formally added to Charge 4, and the commission therefore declined to determine them.

That procedural restraint matters. The tribunal was prepared to make serious findings where it considered the evidence sufficient, but it did not extend those findings to allegations that had not formally been put before it.

Sanction Is Now the Principal Unknown

Nothing published on 29 September determines City's punishment. Sanction will be considered at a separate private hearing, and the Premier League rules give commissions broad powers including fines, points deductions and other sporting sanctions.

It would therefore be premature to translate the scale of the accounting findings into a particular points deduction, relegation outcome or monetary penalty. The economic consequences vary substantially by sanction: a fine creates a direct cash cost; a points deduction can affect league position, UEFA qualification and central distributions; a more severe sporting sanction could affect broadcasting income, commercial revenue, player values and squad retention simultaneously.

The appropriate financial approach is therefore to separate liability, which has now been determined at first instance, from sanction, which has not.

Compensation Exposure Has Become More Concrete

The publication also changes the analysis in Sunday's briefing concerning Arsenal, Manchester United, Liverpool and Tottenham, which preserved rights in 2024 to pursue compensation for alleged lost earnings. Reported estimates have put potential losses above £100 million per club and potentially above £200 million for some claimants, but those remain press estimates rather than adjudicated liabilities.

Potential claimants now have a published decision concluding that City's accounts were materially misstated, that financial rules were breached by a very substantial amount and that, on the commission's findings, the underlying conduct was intended to circumvent Premier League rules. That materially strengthens the factual foundation from which a claim could be constructed. It does not establish causation.

Any claimant would still have to show what would probably have happened absent the breaches and quantify the resulting loss. That becomes difficult where the counterfactual involves league positions, Champions League qualification, commercial contracts or sporting outcomes several seasons removed from the conduct itself. The Burnley-Everton case remains an important first-instance reference point: £26 million of damages plus £9.1 million of pre-award interest, currently under appeal. City's case could involve much larger claimed sums, but it is also materially more complex.

There is a wider transaction implication. If the commission's principal findings survive appeal, regulatory due diligence in football cannot be reduced to current PSR headroom. Historical commercial agreements, related-party structures, the economic substance of owner funding, contingent sporting sanctions and potential inter-club claims can all become transaction-level liabilities. Audited statutory accounts are an essential starting point, but this decision demonstrates why the economic arrangements behind reported revenue and costs bear examination in their own right.

The Appeal

Manchester City dispute the commission's conclusions. The club says the decision contains material errors of law, principle and fact and has said it will pursue the appeal routes available to it.

That replaces speculation about whether last week's reporting was accurate with a narrower set of financial questions: which findings City challenges, whether the accounting and intentionality findings survive, how the alternative fair-market-value analysis is treated and how the appeal interacts with sanction.

Until those processes conclude, the Core Decision should be treated as the operative first-instance finding rather than a final determination of City's ultimate regulatory liability. City's statement of 29 September sets out its position in full.

Outlook

Base case: City proceeds with its appeal while the disciplinary process moves towards a separate sanction determination. Compensation actions remain contingent on the underlying proceedings moving closer to finality.

Escalation: The principal accounting and regulatory findings survive appeal and the eventual sanction has material sporting consequences. Preserved compensation claims would then have a substantially firmer basis from which to proceed.

De-escalation: The appeal materially changes the commission's accounting, intentionality or regulatory findings, reducing either the basis for sanction or the factual foundation available to prospective claimants.

What would change the view: The grounds and scope of City's appeal, the sanction decision, any further publication of the commission's appendices, the outcome of the Everton-Burnley compensation appeal and any formal action by prospective claimants.

Key Risks

Appeal risk. The published Core Decision is a first-instance determination. City dispute it, and material findings could be overturned or varied.

Sanction uncertainty. Liability and sanction are separate. No responsible financial model can yet assume a particular fine, points deduction or sporting consequence.

Compensation uncertainty. A regulatory breach does not automatically establish damages. Rival clubs would still need to demonstrate causation and quantify their losses.

Accounting interpretation. The commission identifies more than £830 million of overstated income alongside separate Fordham and expense adjustments. Those figures should not be combined into a single measure of financial benefit, damages or sanction.

Incomplete disclosure. The Core Decision is redacted and refers repeatedly to detailed appendices. The published document therefore does not contain the complete evidential record underlying every finding.

Intelligence Monitoring Points

City's appeal and the specific findings challenged.
Timing and outcome of the separate sanction hearing.
Any further publication of the commission's appendices or reasoning.
Any formal action by clubs that preserved compensation rights.
Everton's appeal against the Burnley compensation award.
Treatment of historic regulatory liabilities in football-club M&A and financing.
Implications for related-party and fair-market-value assessments under current financial rules.

FAQ

Has Manchester City officially been found guilty? At first instance, yes. The independent commission found every charge proved except Charge 4(B). City dispute the decision and have said they will appeal.

What does the £830 million figure represent? The commission found that City's income across the relevant years had been overstated by more than £830 million. It separately identified additional Fordham and expense adjustments. The figure is not a fine, damages award or measure of City's total financial benefit.

Did City breach PSR? The commission found that after the relevant accounts were restated, City failed the Premier League's PSR requirements by a very substantial amount in every season covered by Charge 3. City dispute the commission's findings.

What happens if the sponsorship arrangements were not shams? The commission considered that alternative. It found their fair-market values were very substantially below the recorded figures and that City would still have failed the relevant PSR requirements after substituting those values. City dispute the decision.

Has a punishment been decided? No. Sanction will be determined separately.

Do rival clubs automatically receive compensation? No. The findings provide a stronger factual foundation for potential claims, but claimants would still need to establish causation and quantify loss.

Data and source note: This briefing updates Bloodstone Research's 27 September football-finance briefing following publication of the independent commission's redacted Core Decision. References to breaches, accounting treatment, intentionality, sham arrangements, owner funding and investigative conduct are findings of the independent commission and remain disputed by Manchester City. The commission states that income was overstated by more than £830 million and separately identifies a £24.5 million Fordham income adjustment, £49.414 million of Fordham-related expenses and expense understatements of more than £8.866 million, £7.4 million and £0.5 million. These figures are not aggregated in this briefing into a new measure of financial benefit, damages or sanction.

This briefing is a report of a published decision of an independent commission. Manchester City dispute the findings in full and have said they will appeal. Abu Dhabi United Group was not a party to the proceedings. No commercial counterparty is identified in this briefing.

Sources

This document is published by Bloodstone Research for informational and institutional research purposes only. It does not constitute investment advice, an investment recommendation, an offer or solicitation to buy or sell any financial instrument, commodity or security, or a forecast of future performance. Market conditions and data may change without notice. Readers should conduct their own analysis and, where appropriate, seek independent professional advice before making investment decisions. For institutional enquiries contact research@bloodstonecapital.co.uk.

Football finance briefing — 2026-09-30