Manchester City face “substantial hurdles” in their attempt to overturn a guilty verdict for breaching Premier League financial rules, a leading lawyer has told BBC Sport, and the Manchester City appeal is unlikely to be straightforward.
The club were found guilty of all charges relating to financial rule breaches across the 2009-10 to 2017-18 seasons, including creating what the Independent Commission described as “sham contracts” to inflate sponsorship income by £830m. City have rejected the verdict in full, saying they are “innocent of the accusations made by the Premier League” and hold “irrefutable evidence” that the ruling “contains clear material errors, of law, principle and fact, and is unsafe”.
What City must prove to succeed
James Severn, a partner at Penningtons Manches Cooper and member of the London Solicitor Litigation Association, said the appeal is “not simply an opportunity to invite a new panel” to revisit the decision. He told BBC Sport: “City will need to identify a material error of law, principle or fact, or serious procedural unfairness, which materially affected the Commission’s decision.”
City’s main argument is that payments at the centre of the case were made by the United Arab Emirates government in its capacity as a shareholder of the sponsors (not by the club’s owners) and that the Commission’s judgement contains inconsistencies. On that basis, they maintain the sponsorship sums were legitimate.
A central piece of evidence is likely to be bank statements, government records and payment documents. Severn said these “could be powerful evidence if they establish a clear audit trail showing the disputed funds came from the Abu Dhabi government rather than the owners”. He added, however: “If that evidence was already before the Commission, which nevertheless concluded that the arrangements were a sham, City will face an uphill struggle to demonstrate the finding was materially wrong.”
Etihad Airways, one of the principal sponsors at the heart of the case, issued a statement shortly before City’s appeal was confirmed, saying it had never been “given the opportunity by the Premier League to be represented, to provide relevant information, or to ensure the accuracy and fairness of information relied upon”. Severn told BBC Sport that complaint “does not, of itself, establish procedural unfairness”, adding that Etihad “was not the respondent and is unlikely to have had an independent right to participate in the proceedings”.
Court documents from a US investigation in New York in 2015 had previously shown Etihad Airways declaring that Abu Dhabi government money was not behind its Manchester City sponsorship payments. City say those documents lack the full context and are not proof of inconsistency in their evidence.
The Football Leaks emails and what the professors think
Another strand of City’s case will target the Commission’s reliance on emails obtained through the Football Leaks files. Severn said that “if City can demonstrate the Commission fundamentally misunderstood the emails, failed to consider their proper context or reached conclusions inconsistent with other contemporaneous documents, that could amount to a material factual error”. He cautioned, though, that “the Commission heard extensive witness and documentary evidence but nevertheless made serious findings of sham arrangements and disguised owner funding”.
According to BBC Sport, Kieran Maguire, professor of football finance at the University of Liverpool, concluded that the Commission found “the documents were retrofitted to fit the crime”, and that it “must have concluded that the evidence and the credibility of the witnesses put up by Manchester City were poor”. Maguire did identify one possible line of attack: arguing the Commission itself was structurally flawed because its members were Premier League picks rather than City’s. He said, however, that “seems remote”.
City have brought in Mark Howard KC to advise on the appeal, while Etihad Airways has enlisted law firm Quinn Emanuel. Maguire described one potential approach as a “mess and noise” strategy, seeking to discredit the Commission’s process rather than the underlying evidence, and said that, while it will be difficult, “there is a route” for City to succeed.
In September 2026, the Premier League confirmed that the Independent Commission’s hearing ran across 42 days, concluding in December 2024, and that an Appeal Board requires a panel of three, with at least one member having held judicial office to serve as chair. The Board has wide discretion: it may allow or dismiss the appeal, or vary any element of the original decision. Premier League regulations require the appeal to be heard within 12 weeks (or by Christmas Eve) though Severn said that “given the scale and complexity of the proceedings, a final outcome may not be known for some time”.
