Manchester City's 115 Charges Explained

What the case teaches business owners about audit, governance and financial rules.

On Friday 25 September 2026, news broke that an independent commission had found Manchester City guilty of 114 of the 115 breaches of Premier League financial rules it had been accused of. The verdict has been reported, not officially published. Sanctions have not been decided. The club denies wrongdoing and is expected to appeal, and the process may run for years.

Within days, the conversation had moved beyond football. Commentators began asking a different question. The club's accounts were audited every year throughout the period in question, so how could this happen?

That question matters more to an owner-managed business than any debate about points deductions. The honest answer is uncomfortable, and it applies to companies of every size: an audit opinion was never designed to answer it.

This article explains the case in plain terms: where it came from, what the charges allege, why the alleged conduct breaks the rules and what happens next. It then looks at what it means for businesses that have nothing to do with football.

STATUS AT THE TIME OF WRITING (OCTOBER 2026)

Verdict: reported by The Athletic and The Times; not officially published.

Sanctions: not yet decided.

Appeal: widely expected. The club denies all wrongdoing.

What has actually happened?

Several outlets reported the verdict on 25 September, citing The Athletic and The Times. The reports say the commission found the large majority of the charges proven.

The Premier League has not commented, describing the process as private and confidential. City's position is that the process is ongoing, with significant elements still to be completed. The club says its stance is unchanged from its statement in February 2023, when it first denied the charges.

Two things have not happened yet: a decision on sanctions, and the appeal City is widely expected to bring. Everything below should be read with that in mind.

How did the case start?

In late 2018, the German magazine Der Spiegel published a series of articles based on internal emails from Manchester City. The emails had been obtained by Rui Pinto, a Portuguese hacker later convicted in Portugal, and also appeared on the Football Leaks website.

The documents were reported to show how parts of the club's finances had been arranged during its rapid rise after the 2008 takeover by Abu Dhabi United Group. Two governing bodies opened investigations: UEFA, which runs European club competitions, and the Premier League.

UEFA moved first. In February 2020, it banned City from European competition for two years and fined the club €30 million. Five months later, the Court of Arbitration for Sport (CAS) lifted the ban and reduced the fine to €10 million. CAS found that most of the alleged breaches were either not established or fell outside UEFA's five-year time limit. It did, however, criticise the club's lack of cooperation with UEFA's investigation.

The Premier League has no such time limit. In February 2023, it charged City with more than 100 breaches stretching back to 2009. The club denied all of them and said its position was supported by a comprehensive body of irrefutable evidence.

A three-person independent commission heard the case in London over 12 weeks, from September to December 2024. The reported verdict came almost two years later.

What are the 115 charges?

The Premier League grouped the charges into five areas:

■     Inaccurate financial information, across nine seasons from 2009-10 to 2017-18. This is the largest group. The allegation is that the club's reported revenue, particularly sponsorship income, and its operating costs did not reflect the true position.

■     Player and manager pay. The allegation is that the full pay of a manager over four seasons, and of some players, was not disclosed in their contracts with the club, with additional payments said to have been made through separate arrangements.

■     UEFA financial rules, across five seasons. The allegation is that the club did not comply with UEFA's own financial fair play requirements.

■     Premier League profitability and sustainability rules, across three seasons. The allegation is that the club breached the league's own loss limits.

■     Failure to cooperate, from 2018 to 2023. The allegation is that the club did not provide documents and information when the league asked for them.

During the nine seasons covered by the charges, City won the Premier League three times. That is why the case matters so much to rival clubs.

Why is the alleged conduct considered wrong?

To see why these allegations matter, it helps to understand what football's financial rules are trying to do.

UEFA's financial fair play rules and the Premier League's Profitability and Sustainability Rules (PSR) were both designed to stop clubs spending far beyond what they earn. Under PSR, a club could lose up to £105 million over three seasons. Above that, it faced sanctions.

The rules treat two kinds of money very differently:

■     Revenue counts towards what a club is allowed to spend. This includes ticket sales, broadcasting and sponsorship.

■     Owner investment, such as new share capital, does not count as income for these tests. An owner can fund a stadium or an academy, but cannot inject cash to cover wages and transfers beyond the limit.

That distinction is the heart of the case. The leaked emails were reported to suggest that much of the sponsorship paid by Abu Dhabi-linked companies was in fact funded by the owner's group. If so, owner money would have been reclassified as commercial revenue. The club could then spend more on players than the rules allowed while appearing compliant. City has always denied this, and CAS did not find it established in the UEFA case.

The pay charges follow the same logic from the other side. If part of a manager's or player's pay is made outside the disclosed contract, the club's reported costs are lower than its real costs. Lower reported costs, like higher reported revenue, make the test easier to pass.

Is a transaction recorded according to what it really is, or according to how it has been papered?

In accounting terms, both allegations go to the principle of substance over form.

The cooperation charges matter for a simpler reason. The whole system depends on clubs providing information. A regulator that cannot see the documents cannot enforce the rules.

What could the punishment be, and what happens next?

The Premier League has no fixed scale of sanctions for financial breaches. The commission can impose whatever it considers appropriate, including:

■     a fine

■     a points deduction

■     a recommendation that the club be expelled from the league

For comparison, Everton and Nottingham Forest received points deductions in the 2023-24 season for PSR breaches. Those cases involved far fewer alleged breaches and no allegations of non-cooperation.

Either side can appeal within 14 days of the judgment. An appeal is heard by a new three-person board, also in private, and City cannot take the case to CAS this time. The club's leadership has signalled that it expects the dispute to take years to resolve. A final outcome may therefore be some way off.

Same facts, different rulebooks, different outcomes

One detail in this story deserves attention from any business owner. The same leaked documents led to two separate proceedings with very different results.

UEFA's case largely failed, in part because of its five-year time limit. The Premier League, with no such limit, pursued conduct going back to 2009 and reportedly reached the opposite conclusion on most of it.

The lesson is not about football. Your exposure depends on the rulebook, not just the facts. Tax authorities, lenders and regulators each have their own time limits, standards of evidence and powers to request information. A matter closed in one forum can remain open in another.

Where were the auditors?

BDO has audited the club's accounts since 2007. Following the reported verdict, some commentators called for the firm's role to be examined. Press reports suggested the Financial Reporting Council was assessing whether anything falls within its remit. No investigation has been confirmed, and BDO has said it is bound by client confidentiality.

This article makes no judgement on the audit work. Its point is more useful than that: what an audit is for.

An external audit gives an opinion on whether the financial statements present a true and fair view under the applicable accounting framework. It is a test of the financial statements. It is not:

■     a guarantee that there is no fraud

■     confirmation that you have complied with every contract, covenant or rulebook that uses your numbers

■     a transfer of responsibility from directors to auditors

That last point matters most. Under company law in the UK and most comparable jurisdictions, directors are responsible for preparing accounts that give a true and fair view. They are also responsible for the systems and controls behind those accounts.

Auditors plan their work around risk. They rely in part on information and explanations given by management. If that information is wrong at source, particularly if it has been arranged to look right, the auditor's job becomes much harder.

"Our accounts are audited" is a statement of fact, not a defence.

Your accounts answer to more than one rulebook

City's numbers had to satisfy accounting standards and football's financial rules at the same time. An owner-managed business is in the same position, just with different rulebooks:

■     Your lender, if your loan has covenants based on EBITDA, debt service or net assets

■     The tax authority, which in most jurisdictions applies the arm's length principle to transactions with connected persons

■     Grant and public funding bodies, whose conditions often depend on reported costs and eligibility

■     Licensing regulators, if you operate in a regulated sector with capital or reporting requirements

■     A future buyer or investor, whose due diligence will rebuild your numbers from scratch

Each of these reads your accounts with its own question in mind. A transaction that is properly disclosed in a note can still breach a covenant. It can fail a transfer pricing review. It can collapse in due diligence.

It is also worth noting what football did next. The Premier League has replaced PSR with a Squad Cost Ratio system from the 2026-27 season. It has also closed the route by which clubs sold assets to owner-linked companies to improve their figures. Rulebooks tighten after they are tested, and yours will too.

Who checks what: the lines of defence in a small business

Large organisations describe governance as "three lines of defence". For a company with 20 staff, the idea still works, scaled down.

First line: management and day-to-day controls. Who can approve a payment, sign a contract or agree a deal with a connected company? Is there a second pair of eyes on anything unusual? In most SMEs, this is where governance lives or dies.

Second line: independent review. Someone who did not prepare the numbers checks them. In a small business, this might be:

■     an outsourced internal review once a year

■     a finance director who reports to the board rather than to the founder

■     an external adviser who reviews related-party arrangements

Third line: external audit. An independent opinion on the financial statements, with the limits described above.

Behind all three: the regulator or authority. It has the power to ask questions later, sometimes years later. In the City case, the charges relate to seasons that ended in 2018.

The common mistake is to treat the third line as if it were the first. The audit comes at the end of the year. Governance happens every time a decision is made.

Related-party transactions: where it usually goes wrong

The allegation at the centre of the City case concerns related-party income: money from a connected source, presented as an ordinary commercial deal. This is the most common governance weak spot in owner-managed groups, because the owner sits on both sides of the transaction.

Consider three scenarios.

Scenario 1: well governed

A trading company receives a marketing fee from its owner's hospitality business for joint promotion. The arrangement is handled properly:

■     there is a signed agreement

■     the fee is benchmarked against what an unrelated partner would pay

■     the board minutes record that the owner declared an interest

■     the arrangement is disclosed in the accounts

If the tax authority or a lender asks, the file answers the question.

Scenario 2: exposed

The same fee is agreed verbally. It rises sharply in the year the company needs to meet a bank covenant, and nothing in particular was delivered for the extra amount. The auditor sees an invoice and a payment, and the transaction is disclosed. The accounts may still pass.

But the lender has been shown a profit figure that depends on the owner's other business, and the arm's length test would be hard to meet. Nobody intended to deceive anyone. Yet the business now carries a risk that could surface in a covenant review, a tax inspection or a sale.

Scenario 3: the documentation gap

A group lends money between its companies on informal terms. Under transfer pricing rules in the EU, the UK and most other jurisdictions, transactions with connected persons must be priced at arm's length.

Larger groups face formal documentation requirements. Smaller ones are often exempt from the full file, but are still expected to show, on request and at short notice, how they arrived at the price. Many owner-managed groups discover this only when the request arrives.

The pattern is the same in each case. The question is not whether the transaction is allowed. It is whether you can show it was real, fairly priced and properly approved.

When the questions come: cooperation is part of compliance

One group of charges against City concerned not the numbers but the response to the investigation. CAS made a similar criticism in the UEFA case. That is easy to overlook, and it is a genuine lesson for any business.

When a tax inspector, a lender or a regulator asks questions, the way you respond becomes part of the record. Delays, incomplete answers and a defensive tone rarely help. In some regimes, failing to provide information is a breach in its own right.

The practical answer is preparation:

■     Keep agreements, board minutes and approvals for connected-party deals in one place.

■     Make sure more than one person knows where the records are.

■     Remember that emails and messages are records too. This whole case began with leaked internal correspondence.

■     Agree in advance who leads the response to an inquiry, and when to involve your advisers.

The honest cost-benefit

Governance has a cost, and pretending otherwise does no one any favours.

What it costs a typical owner-managed business:

■     management time to set approval limits and document connected-party arrangements

■     adviser fees for transfer pricing documentation where it is needed

■     possibly an annual independent review of key controls

■     some loss of speed, since decisions involving the owner's other businesses take longer

What you probably don't need:

■     a full internal audit department

■     a formal audit committee, unless your size, sector or investors require one

■     policies written for a listed company

What it buys:

■     fewer surprises at audit, tax inspection or covenant testing

■     faster, cleaner due diligence when you raise finance or sell

■     protection for directors, who carry the responsibility whatever the audit report says

■     credibility with lenders and investors, which tends to show up in terms and valuation

For most SMEs, the proportionate version is modest. The expensive version is the one you build in a hurry, after the questions have started.

What this means for you

The Manchester City case may take years to resolve, and the final outcome may differ from what has been reported. But the governance questions it raises are already settled, and they apply to businesses of every size.

A short self-check:

1.     Can you list every transaction your company has with connected people or companies, and show each one is fairly priced?

2.    Do you know which rulebooks your accounts feed into, and what each one tests?

3.    If your auditor signed off tomorrow, would you, as a director, be comfortable defending every number on your own?

4.   If the tax authority asked how your intra-group charges or loans were priced, could you show them quickly?

5.    Does anyone other than the person who prepared the numbers review them before they matter?

If any answer is "not sure", that is not a crisis. It is a starting point, and far cheaper to address now than when someone else is asking.

Frequently asked questions

Has Manchester City been officially found guilty?

Not officially. The verdict has been widely reported, but the Premier League has not published it. Sanctions have not been decided, and City is expected to appeal.

What are the Manchester City 115 charges about?

They allege that the club provided inaccurate financial information between 2009 and 2018, including sponsorship revenue and the pay of a manager and some players. They also allege breaches of UEFA and Premier League financial rules, and a failure to cooperate with the league's investigation.

Why did UEFA's case fail when the Premier League's reportedly succeeded?

CAS found that most of UEFA's allegations were either not established or fell outside its five-year time limit. The Premier League has no such limit.

Does an audit guarantee that a company's accounts are correct?

No. An audit gives an opinion on whether the financial statements present a true and fair view. It is not a guarantee against fraud, and responsibility for the accounts stays with the directors.

What is a related-party transaction?

A transaction between a business and a person or company connected to it, such as an owner, a director or a group company. In most jurisdictions, such transactions must be priced at arm's length under transfer pricing rules.