Man City comments — Chelsea Supporters' Club Vancouver

Chelsea and Manchester City – Understanding the Financial Cases

Following the recent findings against Manchester City, there has understandably been discussion about how City's financial-rule breaches compare with those recently settled by Chelsea. Although there are similarities, there are also some very important differences.

Chelsea

Chelsea's Premier League offences concerned historical transactions between 2011 and 2018 under the previous Roman Abramovich ownership.

Following the 2022 takeover, Chelsea's new owners discovered and voluntarily reported irregularities involving undisclosed third-party payments to players, unregistered agents and others. Chelsea subsequently admitted breaches and cooperated extensively with the Premier League investigation.

The important point is that the Premier League recalculated Chelsea's historical accounts to include these payments and concluded that in no scenario would Chelsea have exceeded the Premier League's permitted £105m loss limit.

Chelsea therefore committed serious financial-reporting and disclosure breaches, but the undisclosed payments did not result in Chelsea breaking the Premier League's Profitability and Sustainability spending limits.

Chelsea accepted fines totalling £10.75m, together with an immediate nine-month restriction on certain Academy registrations and a suspended one-year first-team transfer ban.

The Premier League specifically recognised Chelsea's voluntary self-reporting, admissions and exceptional cooperation as significant mitigating factors.

Manchester City

The independent Premier League Commission's findings against Manchester City are considerably broader.

The Commission found that between 2009/10 and 2017/18 City used "sham" commercial contracts which misrepresented the true arrangements between the parties, artificially inflated revenues and reduced costs.

It found that City filed misstated accounts, concealed the true state of its finances from auditors and football regulators and "clearly intended to circumvent the PL Rules."

Crucially, the Commission concluded that if City's arrangements had been correctly reported, Manchester City would have breached both Premier League and UEFA spending limits by a very substantial amount.

The Commission also upheld three of four charges concerning City's failure to cooperate with the Premier League investigation and concluded that the club had made concerted efforts to stop and frustrate that investigation.

The Key Difference

Both cases involve failures to provide complete and accurate financial information, and Chelsea's historical breaches should not be dismissed as merely technical.

However, there is a fundamental difference.

Chelsea: Undisclosed payments should have been included in the accounts, but the Premier League established that including them would not have caused Chelsea to breach its permitted financial-loss limits. The current ownership discovered the historical wrongdoing, reported it voluntarily and cooperated exceptionally with the investigation.

Manchester City: The Commission found that City deliberately used sham arrangements and misstated accounts to circumvent the rules. Once the club's finances were corrected, City would have exceeded Premier League and UEFA spending limits by a very substantial amount. The Commission also found that City failed to cooperate properly with the subsequent investigation.

An Important Qualification

That said, Manchester City has lodged an appeal and continues to deny wrongdoing. The club says the Commission's findings contain material errors of law, principle and fact and maintains that it has evidence supporting its position.

The appeal process is therefore ongoing, and the final outcome — including any sanctions — has yet to be determined.

What About UEFA?

There is another useful comparison.

Chelsea: In 2023 UEFA investigated the same type of historical financial-reporting irregularities discovered by Chelsea's new owners relating to transactions between 2012 and 2019. Chelsea had voluntarily reported the matters to UEFA. UEFA concluded that Chelsea had submitted incomplete financial information, and Chelsea agreed to pay €10m to fully resolve the historical case.

Separately, Chelsea subsequently breached UEFA's newer Football Earnings Rule covering the financial years ending in 2023 and 2024. In 2025 Chelsea entered a four-year settlement with UEFA, including a potential €80m financial sanction (€20m unconditional and the remainder conditional on future compliance), restrictions on registering players for UEFA competitions and annual financial targets through 2028/29. This is a separate matter from the Abramovich-era undisclosed-payment case.

Manchester City: UEFA originally found City guilty in 2020 of serious Financial Fair Play breaches involving alleged disguised owner funding through sponsorship arrangements. UEFA imposed a two-season European competition ban and €30m fine.

City appealed to the Court of Arbitration for Sport (CAS). CAS overturned the European ban, finding that some alleged breaches were time-barred and that the principal allegations of disguised equity funding had not been sufficiently established. However, CAS found that City had failed to cooperate with UEFA's investigation and imposed a reduced €10m fine.

The new Premier League Commission has now reached significantly different factual findings after its much more extensive investigation, concluding that City's true financial arrangements would have put it in breach of both Premier League and UEFA spending limits by a very substantial amount.

Manchester City's appeal against those Premier League findings is now pending.