CASE STUDY · L1

City’s title premium was £3.9m. The larger sums lie elsewhere.

An independent commission has reportedly found Manchester City guilty on 114 of 115 Premier League charges. No sanction has been set, and City are expected to appeal. Much of the debate has focused on titles. The figures point elsewhere: first place paid little more than second, the Champions League places City occupied carried far larger sums, and the club with the largest potential claim is not the one most often named.

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7 min
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27 Sep 2026
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CASE STUDY

On Friday 25 September, The Athletic reported that an independent commission had found Manchester City guilty on 114 of the 115 charges the Premier League brought in February 2023, most of them covering the nine seasons from 2009-10 to 2017-18. Reuters, ESPN and CNN followed. City did not comment on the reported finding beyond saying that significant elements of the process remain; the league declined to comment. The written decision is unpublished, no sanction has been set, and City are expected to appeal. Discussion so far has centred on trophies. The financial weight sits in league places.

01 What the titles paid

City won eight trophies in the charge period: three Premier League titles, the 2011 FA Cup, three League Cups and the 2012 Community Shield. Their direct prize value was about £81.7m, and £78.4m of that was Premier League merit money.

Merit money rises by one equal step per league place within a season, so a title is worth exactly one step more than second. That step was £755,062 in 2012, £1.24m in 2014 and £1.93m in 2018: £3.9m across all three titles. The cups add little. The FA Cup run paid £2.9m, each League Cup £100,000 and the Community Shield nothing.

If titles were ever reassigned, the prize-money effect would therefore be small. The premium for first place was modest; the larger value lay in what a top-four finish unlocked.

FIGURE 1 The title premium City's Premier League merit payment in each title season, £m Paid for finishing second Extra for finishing first 2011-12 £15.1m · first-place step £0.76m 2013-14 £24.7m · step £1.24m 2017-18 £38.6m · step £1.93m Source: Premier League central payments, via Sporting Intelligence. Merit money = 20 steps for first, 19 for second. [Disclosed]
Figure 1 · Three titles earned £78.4m in merit money; finishing first rather than second accounted for £3.9m of it. [Disclosed — Premier League payments]

02 The seats that moved

A simple way to size what other clubs could argue they lost is to remove City from each final table from 2010-11 to 2017-18 and move every club below them up one place. On that basis three titles change hands: Manchester United’s in 2012 and 2018, Liverpool’s in 2014. Eight Champions League places move too, four of them to Tottenham. The recount is mechanical, not a legal finding. It ignores the points City took from other clubs and assumes the fifth-placed club would have taken the place.

FIGURE 2 The seats that moved Club promoted into the Champions League places if City are removed from each final table Tottenham Other clubs Table 2010-11 Tottenham UCL 2011-12 Table 2011-12* Tottenham UCL 2012-13 Table 2012-13 Tottenham UCL 2013-14 Table 2013-14 Everton UCL 2014-15 Table 2014-15 Tottenham UCL 2015-16 Table 2015-16 Man Utd UCL 2016-17 Table 2016-17 Arsenal UCL 2017-18 Table 2017-18 Chelsea UCL 2018-19 Source: final Premier League tables. *In 2011-12 Chelsea took fourth-placed Tottenham's spot by winning the Champions League; with City removed, Spurs finish third. [Derived]
Figure 2 · Eight places move across eight seasons on a mechanical recount, and half of them go to one club. [Derived — final league tables]

UEFA’s own distribution reports allow each place to be priced. A lost season is valued as the lowest payment to any English club in that season’s Champions League, minus what the displaced club actually earned in the Europa League. On that basis the difference in UEFA money comes to about €177m. Tottenham account for €101.9m, Chelsea €46.9m and Everton €26.1m. Arsenal’s figure is €2.6m after a Europa League semi-final. United’s is nil: they won the 2017 Europa League, which paid about €44.5m and brought them into the next Champions League.

These are lower-bound estimates. Extra home matchdays and sponsor bonuses would add to each figure, and those amounts are not public. For context, City earned about €337m from UEFA in the five seasons to 2018-19 alone, on Swiss Ramble’s count — nearly double the €177m at stake across all eight moved places.

03 Nine seasons, priced

The recount can be taken further — across every club, every season. Each club that finished below City gains one league place, and one league place has a precise price: that season’s merit step. Because the steps are equal, the ladder pays every club below City the same amount. Liverpool’s near-miss in 2014 and Stoke’s ninth place that year are each worth £1.24m. Run across all nine charged seasons, the full bill is about £188m in league merit money, spread across 35 clubs.

Three clubs finished below City in every one of the nine seasons — Liverpool, Everton and Stoke — and each would be owed the maximum: £10.7m. No club’s league-place money exceeds that. Set against the European money, the shape of the case becomes clear. League money is broad and thin; European money is narrow and thick. Liverpool’s nine seasons of displacement are worth £10.7m. Tottenham’s four lost Champions League seasons are worth €101.9m.

FIGURE 3 Nine seasons, priced per club City removed from every final table, 2009-10 to 2017-18 — what each club would have gained LEAGUE MERIT MONEY, £M CHAMPIONS LEAGUE ACCESS, €M Tottenham £6.7m €101.9m · 4 seasons Chelsea £5.9m €46.9m Everton £10.7m €26.1m Arsenal £8.6m €2.6m Man Utd £8.3m nil · won the 2017 Europa League Liverpool £10.7m nil · kept its Champions League places Stoke £10.7m no Champions League seat moved West Ham £9.9m no Champions League seat moved League money is broad and thin — 35 clubs share £188m, none above £10.7m. European money is narrow and thick. One merit step gained per season finished below City (Premier League central payments); UEFA gap = lowest English Champions League payment that season minus the club's Europa League earnings. 27 further clubs share the remaining £117m of league money. [Derived]
Figure 3 · The full recount: every club below City gains one identical merit step per season, so Liverpool, Everton and Stoke — below City in all nine seasons — top the league column at £10.7m each. The money that separates clubs is on the right. [Derived — Ledger model on Premier League central payments and UEFA distribution reports]

This is what makes the titles debate a distraction in financial terms. Moving from second to first pays the same step as moving from fifteenth to fourteenth. The money sits at the competition boundaries, not in the order between them — and the recount crosses two of them. Fourth place is one. The other is eighteenth.

04 The relegation flip

The recount has a consequence nobody in the titles debate mentions. If every club below City moves up one place, then in each of the nine seasons the club that finished 18th — the last relegation spot — finishes 17th instead, and stays up. Burnley in 2010, Birmingham in 2011, Bolton, Wigan, Norwich, Hull twice, Newcastle, Swansea: nine relegations, overturned by the same arithmetic that hands Tottenham four Champions League seasons.

Survival is the most valuable single line in English football, and it can be priced the same conservative way: what the bottom club earned in Premier League central payments the following season, minus the year-one parachute the relegated club actually received. That delta runs from about £23m for Bolton in 2012, under the old TV deal and £16m parachutes, to about £54m for Swansea in 2018. Across all nine seasons it comes to roughly £350m — more than the £188m merit pot and the €177m Champions League pot combined.

FIGURE 4 The relegation flip What one season of survival was worth to each 18th-placed club the recount keeps up, £m Within two points of safety Other seasons 2009-10 · Burnley £24m* gap 5 · took 1 pt off City 2010-11 · Birmingham £23m gap 1 · took 2 pts off City 2011-12 · Bolton £24m gap 1 · took 0 pts off City 2012-13 · Wigan £38m* gap 3 · took 0 pts off City 2013-14 · Norwich £40m* gap 3 · took 1 pt off City 2014-15 · Hull £41m gap 3 · took 1 pt off City 2015-16 · Newcastle £53m gap 2 · took 1 pt off City 2016-17 · Hull £53m gap 6 · took 0 pts off City 2017-18 · Swansea £54m gap 3 · took 0 pts off City Nine flipped relegations, roughly £350m — more than the merit pot and the UEFA pot combined. And the weakest causation of all. Survival delta = next season's bottom-club Premier League central payment minus the year-one parachute received (*approximate rows). One-year values, before Championship broadcast income. Sources: PL central payments via Sporting Intelligence; parachute schedules as reported. [Derived]
Figure 4 · The recount's biggest money is at the bottom of the table: every season, the 18th-placed club survives. It is also the hardest claim to win — the nine clubs took six points off City in eighteen games. [Derived — Ledger model; approximate rows starred]

It is also the weakest claim in the case, and the two facts belong together. The nine relegated clubs took six points off City in eighteen fixtures: no wins, six draws, twelve defeats. Their argument cannot be that City’s absence would have saved them — remove City’s fixtures and most of them lose points too. It would have to be the Burnley argument: that a compliantly financed City would have dropped more points to everyone, shifting the whole table. The strongest single case on the numbers is Birmingham in 2010-11 — relegated one point from safety, having drawn both games against City. The weakest is almost everyone else.

↓  Financial model details on financial impact of charges (top down estimates)

05 The precedent

There is now a precedent for how such claims are assessed. On 10 June 2026 a Premier League commission ordered Everton to pay Burnley £26m plus £9.1m in interest, finding that Everton’s 2021-22 breach of profit and sustainability rules caused Burnley’s relegation. With interest accruing at 11.81% a year, the sum is now close to £40m. Everton are appealing, with a hearing due in January 2027. The test was demanding: Burnley had to show that the overspend affected results and that those results decided the table.

City’s case would be harder to fit to that test. It concerns the accuracy of financial reporting across nine seasons, not a single season’s overspend. Any causation argument would be strongest in the close title races — 2012 on goal difference, 2014 by two points — and weakest in 2018, won by nineteen. City have denied wrongdoing throughout, successfully appealed a UEFA ban at the Court of Arbitration for Sport in 2020, and are expected to contest both any sanction and any compensation claim. The scale of any claim is therefore likely to depend less on titles than on whether a tribunal accepts that City’s spending determined who finished fourth.

06 The contrarian read

Coverage has centred on Liverpool’s 2014 title and on Rio Ferdinand’s social-media post about a 2012 medal. Arsenal, Liverpool, Manchester United and Tottenham lodged legal notices in November 2024 — first reported by The Times — to preserve potential claims within the six-year limitation period. But the loudest grievances carry the smallest sums. On the UEFA figures, United and Liverpool show no shortfall in European money at all, and the direct merit difference for Liverpool’s 2014 title was £1.24m. Chelsea and Everton, with the second- and third-largest European figures, were not among the four.

If the findings stand, the recount ranks the money in reverse order of the noise. The titles are worth £3.9m. The league places beneath them are worth £188m, spread so thin no club clears £11m. Champions League access is worth €177m, half of it Tottenham’s. And the nine relegations the recount overturns are worth roughly £350m — the biggest sum in the case, attached to the weakest causation. If the reported findings survive appeal, the sums most likely to be paid sit in the middle of that ranking: arbitration over Champions League places, where the money is large and the counterfactual is narrow.

The question for Tottenham’s board is whether to pursue a claim for four Champions League seasons now, or wait for Everton’s appeal in January 2027 to settle the causation test — and with it, the value of every claim against City.