Regulation·Analysis·By Arthur Lewis·

Manchester City Reportedly Found Guilty: How Far Could They Fall Down the pyramid?

Manchester City have reportedly been found guilty on 114 of the 115 Premier League charges against them. No sanction has been announced, the independent Commission's decision has not been published, and the club is expected to appeal. But the reporting has raised a question the rulebook answers less clearly than most of today's coverage assumes: if the punishment were expulsion rather than a points deduction, where would Manchester City actually play?

TL;DR
  • Reuters reported on Friday that The Athletic and The Times have both reported the Commission finding against City on 114 of 115 alleged breaches of Premier League financial rules.
  • The Premier League has not published the decision and declined to comment, citing confidentiality. City say the process remains ongoing with significant elements to be completed.
  • No sanction has been announced. City are expected to appeal.
  • Two different routes lead downwards. A points deduction could cause relegation through the ordinary league table. Expulsion would not place City anywhere at all.
  • A Commission's sanctioning powers include recommending that the Premier League expels a club. Expelling a member requires a Special Resolution of the clubs — 15 of the 20.
  • The rules do not give a Commission an express power to place a club into an EFL division, because the Championship is not the Premier League's to allocate.
  • The EFL rules provide no automatic right of admission for an expelled club, and its membership is capped at 72.

Manchester City have reportedly been found guilty on 114 of the 115 Premier League charges against them.

What has actually been reported

The distinction matters more than usual, so it is worth being precise about it.

Reuters reported on Friday that The Athletic and The Times had both reported the independent Commission finding against Manchester City on 114 of the 115 charges brought by the Premier League. The club is expected to appeal, and no sanction has been determined.

The Premier League has not published the Commission's decision and declined to comment, citing the confidentiality of the process. A Manchester City spokesperson said: "The Premier League process remains ongoing, with significant elements to be completed, and subject to strict confidentiality. As such Manchester City FC's position remains consistent with the club's statement of February 2023." City have consistently denied wrongdoing.

The charges cover several areas: failures to provide accurate financial information giving a true and fair view of revenues, including sponsorship income, and operating costs; player and manager remuneration; UEFA financial regulations; the Premier League's profitability and sustainability rules; and the club's cooperation with the League's investigation. The hearing began in September 2024 and concluded that December.

Everything below concerns what the rules permit. It is not a prediction of what will happen.

Two routes, and only one of them is simple

Almost every discussion of City falling down the pyramid conflates two entirely different mechanisms.

The first is a points deduction. A Commission can impose one, and if the deduction were large enough to leave City in the bottom three at the end of a season, they would be relegated in the ordinary way. That is not a sanction of relegation; it is a sanction that produces relegation through the normal sporting mechanism, and the destination would be the Championship, exactly as for any other relegated club.

The second is expulsion. A Commission's sanctioning powers include recommending that the Premier League expels the club, and the League's own material identifies expulsion as available for an extreme breach. No club has ever been expelled from the Premier League.

The critical point is that the rules do not give a Commission an express power to place a club into an EFL division. It can recommend removal from the Premier League. It cannot allocate a place in the Championship, because the Championship is not the Premier League's to allocate. The EFL runs tiers two, three and four; the National League and the wider National League System run everything below.

Expulsion would therefore answer the question of where Manchester City do not play. It would not answer the question of where they do.

Who actually does the expelling

There is a further complication inside the Premier League's own rulebook.

A Commission can recommend expulsion. But the Premier League's rules provide that expelling a member requires a Special Resolution of the clubs, which in a 20-club league means 15 voting in favour.

Aaryaman Banjeri, head of football governance at Lane Clark & Peacock, has said it will be instructive to see whether the Commission is held to that requirement or whether it can be worked around, so that the Commission imposes the sanction itself. That is not a technicality. It is the difference between a sanction decided by an independent panel on the evidence and one decided by a vote of the club's own competitors — and with no precedent, there is no established answer.

The EFL is not obliged to take them

Assume, for the sake of argument, that expulsion happens. The instinctive assumption is that City would enter the EFL somewhere.

The EFL's rules provide no automatic right of admission. Reporting in The Telegraph has set out that the EFL has no duty to admit a club expelled from the Premier League, and that its constitution caps membership at 72 clubs across three divisions of 24. There is no spare place. Admitting City would require a rule change or the displacement of an existing member, and neither is within the Premier League's gift.

The ordinary connection between the two competitions runs the other way. At the end of each season, the three relegated Premier League clubs transfer their Premier League shares to the three clubs promoted from the Championship. That mechanism explains what happens on relegation. It establishes nothing about a Commission's ability to nominate an EFL division and require another competition to accept a club into it.

Which is why the scenarios lawyers have discussed since 2023 range from EFL admission on negotiated terms to City having to seek a place considerably further down the system, where entry is governed by the FA's regulations, ground grading and the rules of the individual competitions. Below tier four, nothing about the club's history would entitle it to a place. It would be an applicant like anyone else.

The cups are tied to league membership too

One consequence is easy to miss.

Entry to the domestic cups is defined by league membership. The FA Cup rules provide that where a club has been admitted to the competition but is then removed from the league in which it competes, or has its league fixtures suspended, the Professional Game Board may remove the club from the competition. The EFL Cup defines its participating clubs as the members from time to time of the EFL and of the Premier League.

A club expelled from the Premier League and not admitted elsewhere would not simply be without a league. It could be without a route into either domestic cup.

Why it matters

English football is usually described as a single connected structure, and in sporting terms it is: promotion and relegation link every level from the Premier League to tier ten and below.

What it is not is a single organisation. The Premier League runs tier one. The EFL runs tiers two to four and has 72 places. The National League and the FA run everything beneath. A club moves between them by winning or losing football matches and by satisfying the requirements of the competition it is joining.

Ordinary promotion and relegation make those boundaries almost invisible. Expulsion would expose them. A points deduction operates inside the system as designed, and the system knows what to do with it. An expulsion operates outside it, and would leave a club standing in a gap that no rulebook currently fills.

None of which is a prediction. No sanction has been announced, an appeal is expected, and the range of realistic outcomes remains wide. But if expulsion is genuinely available, the interesting question is not how far Manchester City could fall. It is whether anything in the structure of English football would catch them.

What to watch

The Commission's decision. Proceedings are heard in private and the final decision is published on the Premier League website once they conclude. That has not happened yet, and the reasoning will matter as much as the outcome.

The sanction, and how it is framed. Whether the question becomes one of points, relegation or competition membership depends entirely on the wording.

Whether a Special Resolution is required. If expulsion is recommended, whether it needs a vote of the 20 clubs becomes the central governance question of the case.

The EFL's position. It has said nothing about what it would do with an expelled club, and its rules give one no automatic right of entry.

The appeal. The Premier League's framework provides for decisions to be challenged before an Appeal Board with broad powers to allow, dismiss or vary. Nothing is settled until that concludes.

Frequently asked

Have Manchester City been found guilty?

Reuters reported on Friday that The Athletic and The Times have both reported the Commission finding against City on 114 of 115 charges. The Premier League has not published the decision and declined to comment, citing confidentiality. City say the process remains ongoing and have consistently denied wrongdoing.

Have Manchester City been relegated?

No. No relegation or other sanction has been announced.

What punishment could they receive?

The Premier League says independent Commissions have wide sanctioning powers, including significant fines and sporting sanctions such as points deductions, with expulsion available for an extreme breach. No club has previously been expelled.

Could they be relegated to League One or League Two?

Not by a Premier League Commission. Those are EFL competitions, and the rules do not give a Commission an express power to place a club in them. A points deduction could cause relegation to the Championship through the ordinary mechanism.

Would they automatically join the EFL if expelled?

No. The EFL's rules provide no automatic right of admission for an expelled club, and its membership is capped at 72.

Can they appeal?

Yes. The Premier League's framework provides for Commission decisions to be challenged before an Appeal Board, which can allow or dismiss an appeal or vary the order. Reports say City are expected to appeal.

Sources

Primary document
Club statement
Press
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