Inside the Man City Disciplinary Commission Report

The Situation

A week ago, before the complete findings were made public, I discussed the necessity of handing down a fitting penalty to Manchester City in light of their numerous infractions. My argument was that any fair discipline must, at the very least, involve kicking them out of both the Premier League and the English Football League.

This past week, once the exhaustive report was published, I dusted off my legal credentials and thoroughly examined the entire 40-page brief compiled by the Disciplinary Commission.

A couple of points to keep in mind:

  • The document lacked the accompanying Appendices, which appear to contain a significant portion of the supporting proof.

  • There are numerous blacked-out names, groups, and details, which restricts our capacity to form definitive judgments on certain sections.

  • Lastly, my background is specifically in environmental law. Nonetheless, that qualification could be put to far stranger uses, such as being a vaccine-skeptic eccentric who transports decaying marine carcasses on their vehicle for amusement while heading a federal health agency. Just to name a completely hypothetical scenario.

To get straight to the point, reviewing the documentation has only reinforced my stance. Seeing the details laid out so plainly makes me realize my previous suggestions for penalties might have been too lenient, considering the club deliberately and methodically violated league regulations to construct a period of supremacy rivaling the legendary eras of Manchester United or Liverpool.

The word manufacture is crucial here. This era of success was not forged through generations of club heritage, natural growth, or a deeply committed global and local community—which would normally generate genuine, lasting commercial value. Instead, it was engineered by flooding domestic and European competitions with a massive, continuous stream of illicit financial backing spanning at least nine years.

This is precisely the behavior detailed in the text. To clarify the exact nature of the allegations faced by City, here is how the Disciplinary Commission introduced the matter:

The team faced more than a hundred separate violations of league regulations spanning multiple campaigns.

…The organization disputed every single allegation…

…Proving the grave misconduct asserted by the league demanded compelling and persuasive proof for each specific count. Aside from allegation 4(B), we determined that the standard of proof was fully met by the presented evidence, as detailed hereafter and in the attached records.

That amounts to upwards of 100 distinct infractions. While the figure of 115 is frequently cited in the media, other estimates reach up to 130. A breakdown of these allegations provided by the BBC includes:

  • 54 infractions: Providing misleading financial data between the 2009/10 and 2017/18 seasons

  • 14 infractions: Not disclosing precise compensation details for staff and squad members from 2009/10 to 2017/18

  • 5 infractions: Violating UEFA guidelines, specifically Financial Fair Play rules, between 2013/14 and 2017/18.

  • 7 infractions: Infringing upon the league’s Profit and Sustainability parameters from 2015/16 through 2017/18.

  • 35 infractions: Obstructing and failing to assist with the league’s inquiries from December 2018 up to February 2024.

The findings group these hundred-plus violations into four main categories, with the first and fourth categories subdivided further. However they are organized, the reality remains that the club violated an immense volume of regulations, as verified by the panel. This outcome surprises absolutely nobody who has been watching the situation unfold.

Furthermore, having gone through the text, I suspect these counts only scratch the surface of the club’s misconduct. I wish to avoid looking like a conspiracy theorist mapping out connections with red string and photos of the manager, but when an organization is convicted of a massive plot to manipulate the competition, it naturally invites further suspicion and deeper scrutiny.

This is partly because the evidence shows they actually escalated their illicit activities between 2009 and 2018, even as their purchased victories helped them transition into a genuine sports and business giant. Considering this upward trend and the timeframe of the inquiry, one can easily assume that similar behavior continued past the investigation’s end date—details that may remain forever hidden from the public.

Yet, what has been brought to light is already incredibly damaging on its own. These are the verified facts.

The Proof

Directly after the verdict was reached, and prior to the league publishing the document, the club went on the offensive, criticizing the system and trying to sway public perception. While this strategy might influence popular opinion, it is unlikely to rescue them during the formal appeals process.

The panel made a point of emphasizing the massive volume of documentation they reviewed, likely expecting intense public interest and aiming to silence any doubters beforehand:

Every single avenue was thoroughly investigated.

…The league presented its allegations through a formal list of charges and a summary of events. Collectively, these files (totaling roughly 500 pages) detailed:

a) The more than 100 rule violations attributed to the organization, and

b) The underlying evidence the league used to back its assertions… the charging documents noted that the league viewed the team’s actions as representing ‘highly severe, substantial, prolonged, and deliberate or negligent violations of policies essential to the honest and balanced running of the competition.’

This theme was reinforced further down in the text:

The case produced a massive amount of paperwork and physical proof. To give an idea: b)…The collective testimony of witnesses exceeded 700 pages…

d)…By the conclusion of the sessions, the reference index alone was over 750 pages long, while the primary collection of critical documents spanned tens of thousands of pages…

…Verbatim transcripts of the proceedings filled about 7,000 pages.

Regarding how the club answered these numerous allegations, the panel observed:

The organization rejected all allegations completely. Across a response exceeding 200 pages, the team outlined the specific justifications for its denials, which were backed by additional submissions.

Right after the announcement, the club declared publicly that they possessed “an extensive collection of undeniable proof” confirming they did nothing wrong. This claim is difficult to reconcile with the tens of thousands of pages of incriminating files mentioned in the ruling. The club had ample opportunity to show this definitive proof, yet throughout the millions of reviewed records and the vast evidence files, no such exculpatory material emerged. In fact, the findings point in the exact opposite direction.

In reality, a 200-page response might sound substantial, but it is microscopic compared to the mountain of evidence against them. This breaks down to less than two pages of defense for each rule broken, which looks incredibly weak. It functions as a legal version of a simple denial. If my children blamed me for finishing the cereal, I could easily draft a longer defense highlighting their lack of concrete proof, criticizing their biased accusations, and casting doubt on their assumptions. How can they prove they didn’t have a late-night snack themselves? Did anyone check where the pet was during the incident? It is impossible to say. Simple denial.

To put it bluntly, the club’s counterarguments were incredibly feeble, particularly for an organization employing highly paid legal representation.

It was far from being an airtight, undeniable collection of proof.

It is absurd to suggest they chose to withhold vital, exculpatory evidence during the trial, deciding only to bring it out during an appeal after receiving a decisive guilty verdict. If I faced serious allegations, I would certainly present my strongest defense upfront rather than waiting for a conviction. But perhaps others operate differently.

Returning to the introduction, the league faced a strict burden of proof to establish guilt for every infraction. They noted that convincing and robust evidence was necessary for each allegation. Consequently, the club did not need to prove absolute innocence; they only had to introduce sufficient doubt. They failed to achieve even this modest goal, despite their best efforts.

Even more troubling is the fact that these counts are based solely on the records the league managed to acquire. The specific charges regarding non-cooperation indicate that the club actively obstructed the inquiry, making it highly challenging, if not impossible, to uncover the complete scale of their actions.

The text also includes a revealing note suggesting that much more evidence remains hidden from the panel’s view:

We understood that the discovery phase involved scanning through millions of pages. This process produced an immense quantity of shared files, with the vast majority of the administrative effort handled by the team itself.

Even though the league accessed some records directly, the club managed the majority of the document search and delivery (seemingly after exhausting their delay tactics). This means they had every opportunity to curate the disclosures in their favor, yet they still could not avoid being found liable for almost all infractions.

The panel also expressed frustration over absent testimony and unavailable files, noting:

Notwithstanding the massive quantity of records at hand and the thorough statements provided by the attending witnesses, the overall body of proof remained less comprehensive than would have been ideal.

Despite these gaps and the strict standards required for conviction, the panel nevertheless found the club responsible for nearly every allegation brought against them.

The Deception

The documentation begins by outlining the club’s standing before the acquisition by the Abu Dhabi United Group (ADUG). A decade prior to the takeover, the team was playing in the third tier, eventually returning to the top flight for the 2001/2002 campaign. From 2001 to 2008, they typically ended seasons between 8th and 15th place, operating as an average mid-table side occasionally threatened by relegation.

Then the massive investment arrived.

And alongside it, the rule-breaking.

The management understood that relying purely on owner funding was not a viable long-term strategy. It was essential to expand their marketing ventures and dramatically boost business income. When the takeover occurred, the team’s commercial earnings were merely a small percentage of those enjoyed by leading teams in the league and across Europe.

…Although commercial income rose in 2009, files from late that year reveal that the organization

a) Failed to meet its projected commercial income targets, finding it much harder than expected to secure profitable sponsorship agreements

b) Projected substantial financial deficits for the 2009/10 fiscal period and subsequent years

c) Accepted that maintaining their aggressive spending plans required the owners to continue injecting massive amounts of capital through equity.

The findings indicate that the new owners quickly recognized pressing financial challenges, primarily because they struggled to secure standard, legitimate sponsorships to match the league’s elite. They were staring down an imminent deficit that would surpass the historic £140 million loss recorded by Chelsea. Furthermore, they were conscious of upcoming European financial regulations and knew their planned deficits would breach those thresholds.

To bypass these hurdles, the ownership group created what the panel labeled a “Disguised Funding Scheme.” This mechanism served as the primary, though not exclusive, method of funneling illicit money into the club.

The arrangement was straightforward. Sponsors from Abu Dhabi contracted for a modest base amount, while the ownership group quietly covered the massive gap, ensuring the reported commercial income matched their inflated public claims.

Implementing this payment system allowed the organization

a) To present a false picture to external entities, such as financial examiners and regulators, suggesting that partnership revenues were vastly higher than reality, and

b) To mask the actual scale of capital injected directly by the parent company.

…Through this setup, the team falsely reported £949.94 million as legitimate commercial revenue between 2009 and 2018. Out of this total

a) A mere £119.25 million came from genuine partner obligations, which is the only amount that should have been declared as commercial earnings

b) The remaining £830.69 million consisted of direct subsidies from the ownership group, which legally should have been designated as equity injections rather than business revenue:

Thus, the club utilized this mechanism not only to gain an unfair competitive edge but specifically to deceive regulators regarding where their cash was coming from. Rather than using it just to achieve success, they intensified the practice over time. Their goal was absolute supremacy, not just winning.

The owners were not satisfied with simply establishing themselves among the elite. Even after capturing domestic championships and progressing deep into European tournaments, they expanded the scale of this financial manipulation, as illustrated by the following data:

The club’s backers channeled £135 million into the historic 2017/18 squad through this artificial mechanism, marking the highest annual injection recorded. That team achieved an unprecedented 100-point league finish, secured a domestic cup, and was poised to capture European glory until they were halted by Liverpool.

In retrospect, their true legacy from that season is one of systemic rule-breaking.

They dominated the competition during that campaign, finishing 19 points ahead of Manchester United. Back then, manager Jose Mourinho observed:

“If I suggest that guiding Manchester United to a runner-up spot in the league was among my finest professional achievements, people might think I have lost my mind. They would point to my trophies and question how a second-place finish compares. But I stand by it, because the public is unaware of what was happening behind closed doors.”

His comments were dismissed as typical exaggeration from a notoriously dramatic coach. Yet, given the revelations about what was occurring across Manchester, his words carry a lot more weight today. Furthermore, Mourinho is well-acquainted with heavily subsidized success, having managed the league’s original big spender, Chelsea, during the previous decade.

The Verdict

As discussed, the manipulation of sponsorship income was just one of several methods used to alter the financial records. Beyond the £830 million in inflated earnings from that specific setup, other tactics were employed to either exaggerate income or hide expenditures totaling another £90.68 million. This brings the total volume of artificial adjustments to over £900 million in less than a decade.

The findings present a very clear picture. Despite the heavy redactions, the scale of the manipulation is obvious to any observer.

The owners deliberately introduced nearly a billion pounds of unauthorized capital into the organization over nine years while actively hiding the transactions from regulators. Following this, they spent half a decade attempting to block the league’s inquiry, which originally began only due to data leaks and exposed emails.

Do I think we have uncovered every single infraction? Absolutely not.

Does that change anything? Not in the slightest.

The accumulated proof was more than sufficient to confirm over a hundred rule violations. The evidence clearly demonstrates that these regulations were bypassed intentionally and systematically.

Ultimately, the visible outcome of this financial intervention was clear on the pitch for years. Their strategy of leveraging massive wealth to construct a dominant force was highly successful.

It yielded massive rewards, resulting in 19 domestic honors, European silverware, and a Club World Cup. This dominance disrupted the balance of the domestic game, forcing rivals into a desperate struggle to keep pace. While their supporters enjoyed historic celebrations, rival teams and their followers were denied triumphs they might have otherwise achieved.

No clearance is on the horizon for the club. The mountain of proof is too massive to dismiss, despite the lengthy period it took for the league to act. Meanwhile, the club’s assurances of providing definitive proof of innocence remain unfulfilled because no such evidence exists.

They must face the most severe penalties available. A failure to impose strict sanctions would represent a major failure of the system and cast a permanent shadow over the league’s history.