Manchester City and the IFR: What the Act Could Do

The Premier League's published commission decision, finding against Manchester City on all but one of the charges referred to it, has prompted a blunt question: could the Independent Football Regulator now intervene? It could, but each power has its own test. The IFR can ask for evidence about the club's finances and controls. Assessing an owner under section 34, refusing a licence or forcing a sale would require further steps. Here is what the Act allows today, and what City's first licence application may have to address.

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What do we actually know about the City case?

On 29 September 2026, the Premier League published the independent commission's redacted core decision. The commission found each of the Charges proven against the club, with the exception of one part of the cooperation charge, Charge 4(B). Among its findings, the commission concluded that the club had devised what it termed a Disguised Funding Scheme to present shareholder funding as commercial revenue, overstating the club's income across the relevant years by over £830 million. Premier League chief executive Richard Masters said the core decision “establishes the facts of what happened at Manchester City during this period.” The published document deals with liability only. No sanction has yet been announced, and Manchester City has confirmed it will appeal.

The Premier League's 2023 referral has several strands. It alleges inaccurate financial information for the 2009/10 to 2017/18 seasons, including sponsorship revenue, related parties and operating costs. It also concerns manager and player remuneration, compliance with UEFA and profitability rules, and cooperation with the League's investigation from December 2018. The published referral tells us what was alleged; the commission's own published core decision now tells us what was found, and the two use different structures: the referral's individual alleged breaches sit within four broader Charges in the commission's decision, with Charges 1 and 4 each split into four further parts.

City denies wrongdoing. In its statement of 29 September, the club said it was “disappointed and surprised” by the decision and maintained it is “innocent of the accusations made by the Premier League.” The club said a “comprehensive body of irrefutable evidence” supported its position, and confirmed it would “pursue the appeal avenues open to it” on the basis that the decision contains “clear material errors, of law, principle and fact, and is unsafe.” Any IFR response would have to take account of that position, the appeal, and the evidence eventually available, not just the headline finding.

The familiar ‘115 charges’ shorthand also needs care. It covers different rules, seasons and alleged acts, and it is not how the commission's own decision is structured; the published core decision addresses four Charges, two of them split into further parts, rather than 115 separately numbered charges. The number alone, in either form, tells us nothing about the role of a particular owner or director, or whether City's current financial position has changed. Those are the questions that matter under the new Act.

What the Published Decision Actually Establishes

What the published decision actually establishes

Confirmed

The commission found each of the Charges proven except Charge 4(B), a narrow part of the cooperation charge. The commission's central finding is the Disguised Funding Scheme, which it found overstated the club's income by over £830 million across the relevant years.

Not yet decided

Any sanction. The published document is a liability decision, not a sanctions decision.

Confirmed

Manchester City disputes the finding and has stated it will appeal on grounds of material error of law, principle and fact.

Premier League v Manchester City FC, independent Commission, Redacted Core Decision, published 29 September 2026 | Lagom Sports Compliance commentary

The Premier League and the IFR are asking different questions

The Premier League commission decides whether City breached League rules and what sanction follows under those rules. The IFR has a different job. The Football Governance Act 2025 gives it responsibility for club licensing, financial soundness and the suitability of owners and officers. It cannot simply take over the League case or issue a points deduction for an old League breach.

The commission's published core decision is now that reasoned decision, and it could still be important evidence. It might raise questions about the club's current forecasts and controls, or about a person who made a particular decision, though the redacted version made public does not itself name individuals. Section 37 tells the IFR to consider a relevant competition organiser determination about the person when assessing that person's suitability. A finding about City as a club does not, by itself, decide the fitness of anyone who owns or runs it.

The IFR would have to identify the evidence relevant to its own test. Manchester City's confirmed appeal, and any further League proceedings on sanction, would affect the weight it gives to a disputed finding. The Act does not make the IFR wait for every other process to finish if it has proper grounds to use one of its powers.

Section 34: when an owner becomes the question

The Independent has highlighted section 34. That is understandable. It gives the IFR a route to assess an existing owner, but only where the statutory trigger is met.

The section applies to an individual incumbent owner. The IFR may test that person's honesty and integrity and financial soundness if information gives it grounds for concern. It has a separate power to examine whether the person has a source of wealth connected to serious criminal conduct, but that requires grounds to suspect such a connection. Even a proven breach of League accounting rules would not automatically establish an illicit source of wealth.

The IFR must tell the owner and club before it makes a determination. If it is considering an adverse finding, section 36 requires it to explain why and give both at least 14 days to respond. An adverse outcome can lead to the owner being treated as unsuitable, with the decision published. That is a serious power. It is an evidence based process about an individual, not an automatic result of a club level verdict.

Section 35: what about directors and senior executives?

Section 35 provides a similar route for an incumbent officer, which can include a director or relevant senior executive. The IFR needs information giving it grounds for concern about that person's fitness. It can then consider honesty and integrity, financial soundness and competence. The individual and club must have an opportunity to respond before an adverse finding. If a later League decision identifies conduct by someone who still runs City, section 35 could matter as much as section 34.

There are also notification duties now. Under section 33, an owner, officer or club must tell the IFR as soon as reasonably practicable if they consider that there has been, or may have been, a material change relevant to the individual's suitability. Section 50 deals with a material change affecting the club that is relevant to the IFR's functions. Neither section sets a fixed number of days after a news report. The trigger depends on what the person or club considers has changed.

The IFR can ask for evidence before reaching a view

Sections 65 and 66 may be the most practical powers in the near term. Section 65 allows the IFR to require information it considers necessary for its functions. A notice must explain why the information is needed and when and how it must be supplied. Section 66 allows the IFR to appoint an expert reporter to examine a matter concerning a regulated club, again where the report is necessary for its functions. The reporter may require information needed for that work.

What might that look like here? The IFR could ask how the club verifies sponsorship and related party income today, who signs off regulatory returns, and what has changed in the controls since the years covered by the League case. It could ask for forecasts showing the effect of a possible fine, legal costs or a change in league income. If independent assurance is needed, an expert reporter could examine a defined issue. That would support an IFR decision; it would not rerun the Premier League hearing.

The League also has duties under section 55 to notify the IFR when it considers or suspects a breach of a relevant competition rule and, generally, before imposing a penalty for such a breach. The IFR may therefore learn facts through a formal route before the public sees a complete sanctions decision. The League still decides its own case.

Not an Extra Refusal Ground

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A published League liability finding is not, by itself, an extra refusal ground. The IFR would still need to show why the club's own plan, commitments or ability to meet its duties fails the section 17 test.

Football Governance Act 2025, section 17 | Lagom Sports Compliance commentary

City's provisional licence application is the next practical test

The IFR published its final licensing framework on 1 July 2026. The ordinary application window for clubs in the top five divisions opens on 2 November 2026 and closes on 26 February 2027. Clubs will need a provisional operating licence for 2027/28. City's ordinary application cannot have been refused or put on hold before that window opens. A pilot involving selected clubs is under way separately.

The application asks for a strategic business plan, financial forecasts and a personnel statement naming owners and senior managers. An authorised director must confirm that the submission is accurate and complete to the best of their knowledge. The IFR also asks how the club is funded, what related entities do, and what it would do if expected funding did not arrive. These are the questions that turn a distant League dispute into a current licensing issue.

City's plan would need to explain the facts and uncertainties known when it applies. A possible fine, further legal costs, a points deduction or a change in league status could have very different effects on revenue and cash. None should be treated as an imposed sanction before it is one. The IFR could ask to see the assumptions behind the forecast and how the club would cope if a material scenario occurred.

The decision has a timetable. Under the final Licensing Rules, the IFR must decide as soon as practicable and within three months of telling a club its application is complete. It may add up to one month in the limited circumstances set out in those rules. If information is missing, it tells the club what is needed. If it proposes to refuse a provisional licence, section 17 gives the club at least 14 days to make representations. A complete application cannot simply be left open indefinitely while the League process continues.

Could the IFR refuse a provisional licence?

Yes, we actually discuss it in this article here, but if the statutory test is not met. Section 17 says the IFR must grant a provisional licence if it is satisfied that the club would operate a relevant team, comply with the mandatory licence conditions and comply with the duties in sections 45 to 53. It may not grant one if those matters are not established. The IFR's guidance describes refusal as a last resort and allows closer supervision or conditions for higher risk clubs.

A published League liability finding is not, by itself, an extra refusal ground. The IFR would need to show why the club's present plan, commitments or ability to meet its duties fails the section 17 test. If City can meet that test, it could receive a provisional licence even while the League's sanction decision and City's appeal continue. The IFR could attach conditions where the Act permits them. It must explain a proposed refusal and hear the club's response.

A full licence asks more. Section 18 adds the Schedule 4 thresholds for financial resources, governance and fan engagement. It also requires that no current owner or officer has been found unsuitable under Part 4. The IFR's guidance says clubs first licensed for 2027/28 could move to full licences from June 2028 at the earliest, after a year of reporting. A suitability decision about an individual could therefore become decisive at that later stage.

Once a club is licensed, the IFR can attach discretionary conditions for the purposes set out in section 21. Section 22 limits conditions about non-financial resources to internal controls, risk management and financial reporting. Financial conditions have their own limits, including debt, liquidity and overall spending. If the evidence showed weaknesses in City's current controls, targeted reporting and control requirements would be a plausible response. The IFR would still need to follow the Act's procedure and act proportionately.

Could the IFR force an owner to sell?

There is a route to removing an owner, but it begins with a decision about that owner. If an incumbent individual owner is deemed unsuitable under section 34, section 39 requires the IFR to direct that person to take all reasonable steps to cease being an owner within a specified period. The IFR must consult the owner, club and relevant competition organiser first. Section 41 also gives it powers concerning an unsuitable person's rights at the club.

A section 43 ownership removal order is a further step. For an incumbent owner assessed under section 34, it can follow, for example, failure without reasonable excuse to comply with a section 39 or 41 direction, or obstruction of a person appointed under the Act in the specified circumstances. An order may provide for trustees and steps to end ownership. A finding against the club alone does not satisfy those conditions.

That is why ‘the IFR could force a sale’ is a possible end of a long legal route, not a description of what the published liability finding does today. The individual test, notice, opportunity to respond and further removal grounds all matter.

What the IFR is likely to want to see from Manchester City now

None of this depends on the League's sanction decision or on the outcome of City's appeal. Whatever happens next in that process, the Act's own provisions on financial resources, governance and information gathering point fairly precisely to what the IFR would look for if it turned its attention to City's current position. In our experience advising clubs through comparable scrutiny, that is likely to mean five things in particular.

Financial reporting that stands on its own. Not just historic accounts, but current financial statements and forward forecasts that are complete and accurate in their own right, with sponsorship, related party and other income recognised and verified on a basis the club can explain and defend, distinct from the practices the commission's decision examined in the historic years. This is precisely the ground the Act's financial resources threshold requirements and mandatory licence conditions on financial plans are designed to test.
Clear evidence on source of funds. Where shareholder funding, sponsorship income and other capital genuinely originates, traceable back to verifiable and legitimate sources. Source of wealth sits at the centre of the section 34 owner fitness test, and a club in City's position should expect that evidence to be tested more closely, not less.
Club governance that can show independent oversight, not just sign-off. Board composition, the role of independent non-executive directors, and who beyond the individuals connected to the historic arrangements now owns oversight of financial controls and regulatory reporting. The IFR's apply-and-explain corporate governance expectations are built around exactly this distinction.
Evidence of genuine board challenge. Board minutes and papers that show real scrutiny of financial disclosures and related party arrangements at the time they were made, not simply formal approval after the fact. A board that can demonstrate it challenged management, asked for evidence and tested assumptions is in a materially different position to one that can only show it signed off what it was given.
Contemporaneous evidence and record keeping. The practical ability to produce, quickly and on request, documentary evidence of decisions, approvals and controls as they existed at the time, rather than reconstructed afterwards. Sections 65 and 66 give the IFR the means to test exactly this. The commission's own findings show how much weight can ultimately attach to what a club did, and did not, put in writing at the time.

None of this assumes that any of these weaknesses exist at Manchester City today. It is simply what a club under this kind of scrutiny would need to be able to demonstrate, clearly and quickly, if asked, and it is the same standard any club preparing for IFR licensing should be holding itself to now.

Three ways this could develop

The League's liability finding stands as published, but sanctions and the appeal remain unresolved. The IFR can ask for information relevant to its functions and prepare for licensing. It would need more than the published finding alone before reaching an adverse conclusion about a person.
The published decision finds breaches by the club but, in its redacted form, says little about current individuals. The IFR's focus may be the accuracy of City's current disclosures, forecasts and controls. Sections 34 and 35 still require grounds for concern about a qualifying owner or officer.
Evidence points to a current individual, or a sanction changes the club's outlook. The first could trigger an owner or officer fitness assessment. The second could require updated forecasts, a material change notification or licence conditions if the club is licensed. They are different responses under different parts of the Act.

There is a wider lesson for clubs. The new regime asks directors to stand behind current information, explain where funding comes from and show how the club would withstand a shock. A club with a live dispute needs a clear account of what it knows, what it does not yet know and who is responsible for each answer.

Who ar Lagom Sports Compliance?

Lagom Sports Compliance is the leading specialist governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football, globally. We support club leadership teams with evidence-based SMF mapping. We work through the organisation chart, delegated authorities, committee structures, reporting lines and the way decisions are made in practice, then test each role against the Act, the final ODSE Rules and the IFR's current Guidance. If your club has a Sporting Director, Head of Recruitment, General Counsel, Head of Medical or another role whose title does not settle the answer, get in touch and we will help you build a defensible mapping before an appointment or IFR query creates urgency.

For licensing, we offer:

Review Only support for clubs preparing their own application who want an independent, criterion-by-criterion review before submission;
Part Support for clubs that want to lead certain work-streams while we own others; and
Full Support, where a named senior consultant leads the entire licensing project from readiness assessment through to post-submission.

For ODSE specifically, we help CEOs and their leadership teams map exactly who in the organisation is in scope, assess individual readiness against the fitness and source of wealth tests, and build the material change notification process that keeps you compliant for as long as you hold the role, not just at the point of your original determination. If any of the concerns above sound genuinely familiar, get in touch and we will talk through what the right level of support looks like for your specific position.

We have also built a self service IFR readiness assessment tool. It takes around 15 minutes to complete and gives you a guide as to what you may need to, based on what you already have in place.