Premier League v Manchester City: the verdict is out, what now?

As of 29 September 2026, a redacted version of the core decision in the long-running saga regarding the charges brought against Manchester City by the Premier League has now been published, with the vast majority of the charges levelled against the club being found proven by the disciplinary commission (the Commission).

Following the publication of the decision, City issued its own statement on its website in response to the decision (referring to the decision as an “opinion”). In that statement, the club expressed its disappointment and surprise with the decision and maintained its innocence, echoing that stance that has been taken by its senior officials since news of the outcome first broke. City’s statement also indicates that it intends to pursue all regulatory and legal routes available to it, including an appeal on the basis that the Commission’s decision “contains clear material errors, of law, principle and fact, and is unsafe”.

In this article, we answer some burning questions regarding what happens next for City, and legal avenues that are available to it.

What are the Premier League Rules?

The Premier League rules are set out in the Premier League Handbook (the Rules) which is published on its website. Section W of these Rules governs disciplinary proceedings.

The procedures and powers provided for in Section W are not the same as those of a traditional civil court. In essence, the Rules are a contractual arrangement between the Premier League and its member clubs. The effect of this agreement is that any proceedings brought under Section W of the Rules are governed by their own procedures and timeframes which allows for a greater degree of flexibility and (importantly) confidentiality.

How would an appeal work under Premier League Rules?

City has 14 days from the date of the decision to commence its appeal. The Premier League has confirmed that this deadline expires on Friday, 2 October 2026. It remains to be seen whether City will appeal, but it does seem likely given the robust statements that have been made by the club and its senior executives.

The Rules state that an appeal hearing should conclude no later than 12 weeks after the filing of any appeal and that the hearing should be no longer than five days. However, these timeframes can be disapplied either by agreement of the parties or at the discretion of the appeal board appointed to hear the appeal (the Appeal Board). Given the complexity of this case, it seems likely that an extension of some kind to these time frames will be necessary.

Can new evidence be heard as part of the appeal process?

Executives at City have stated that there is evidence which exonerates the club. We don’t know whether that evidence was before the original Commission (although we do know that the trial bundle index alone ran to 650 pages, and the ‘core documents’ bundle many tens of thousands). One suspects that the club’s key evidence was before the Commission.

Where that evidence was not put before the Commission previously, it is possible to introduce this evidence as part of the appeal process only if that evidence was not available at the time of the original hearing.

Would any decision of the Appeal Board be the end of the matter under the Premier League Rules?

No, the Rules contain a further avenue of appeal. Section X sets out the basis on which a decision by either Commission or the Appeal Board can be submitted to a final and binding arbitration.

The grounds on which such an appeal can be made are more restrictive. Essentially, only a decision which was subject to serious procedural errors or at odds with natural justice will reach the threshold.

Can the decision be appealed to the Court of Arbitration for Sport (CAS)?

No, neither a decision made by the Appeal Board nor following a Section X arbitration can be appealed to CAS.

Once the process under the Rules is exhausted, the only route of challenge is via the Arbitration Act 1996.

What is the Arbitration Act 1996?

The Arbitration Act 1996 is a piece of UK legislation which governs arbitration proceedings in England, Wales and Northern Ireland.

How could a decision under the Premier League Rules be challenged under the Arbitration Act 1996?

There are two ways in which a decision can be challenged under the Arbitration Act 1996:

 o    Section 68 allows a party to challenge a decision made in an arbitration on the grounds of a serious irregularity. These grounds include, but are not limited to, the following:

               o   The tribunal exceeding its powers;

                o   The failure of the tribunal to conduct in accordance with the agreed procedure;

                o   The failure of the tribunal to deal with all the issues that were put to it;

                o   Uncertainty or ambiguity as to the effect of the decision;

                o   The award being obtained by fraud;

                o   An irregularity in the conduct of the proceedings.

- These are similar grounds to those which the Club would have to satisfy in order to commence a Section X arbitration.

 o    Section 69 allows a party to appeal a decision made in an arbitration on a point of law.

- It is possible for the parties to an arbitration to agree that this path of appeal should be excluded. Indeed, the Rules expressly state that no such appeal can be made to a decision made under Section X of the Rules.

- However, no such restriction exists in the Rules in respect of proceedings brought under Section W (covering decisions of the Commission and Appeal Board). Whilst it would be surprising if City chose to jump directly to High Court proceedings at this juncture, the right to do so is not expressly excluded by the Rules.

Any challenge under the Arbitration Act 1996 needs to be brought within 28 days of the decision to be challenged, which means that City are once again facing a tight deadline.

This does not necessarily mean that High Court proceedings will run in parallel with any appeals brought under the Rules. The Premier League and City may agree to stay any High Court proceedings for now to reduce (no doubt exorbitant) costs.

What is clear is that, despite there being no recourse to appeal to CAS following the Commission’s decision, there are still a number of legal avenues available to City which could see an ultimate resolution to this saga a long way off.

Our LP Sports Team will be following developments closely as this issue evolves. We will share further updates via our LinkedIn or our website.