Who this article is for:

• Current and former professional footballers.

• Premier League and EFL clubs.

• Football agents and agencies.

• Players who may have lost bonuses, earnings or career opportunities.

• Clubs considering potential financial losses arising from sporting outcomes.

The findings against Manchester City have prompted significant debate about potential compensation claims by rival clubs. But the consequences may extend further.

Since the Commission's decision, I have received enquiries from former Premier League players asking whether they may have claims for financial losses arising from sporting outcomes during the relevant period.

Others are considering the same question. Press reports indicate that Premier League players and their agents have spoken to lawyers about potential compensation claims, including lost bonus payments.

For individual footballers, the potential losses may extend beyond bonuses. Relegation, failure to qualify for European competition or another sporting outcome can affect remuneration and, potentially, subsequent playing and career opportunities.

The issue therefore raises an increasingly important question:

If breaches of financial rules are ultimately upheld and found to have created a sporting advantage, could rival clubs, current players and former players who suffered financial loss as a consequence claim compensation?

What Did the Commission Decide in the Manchester City Case?

The proceedings concerned more than 100 alleged breaches of the Premier League Rules and followed a lengthy investigation and hearing.

An independent Commission found Manchester City guilty of serious breaches of the Premier League's financial rules relating to the period from 2009/10 to 2017/18, as well as the majority of charges concerning failures to cooperate with the investigation.

Manchester City emphatically denies wrongdoing. The club maintains that it is innocent and that the Commission's decision contains material errors of law, principle and fact and is unsafe. The club lodged its appeal on 1 October 2026.

That procedural position is critical.

The findings are being challenged, and the outcome of the appeal may have significant consequences for any potential compensation claims.

What Happens Next in Manchester City's Appeal?

The appeal will be heard by an independent Appeal Board and the proceedings will remain private and confidential until publication of the outcome is permitted.

There is therefore a range of possible outcomes.

Manchester City may succeed in overturning findings central to the Commission's decision. Its appeal could succeed in part, leaving other material findings intact. Alternatively, the appeal could be dismissed.

It would be premature to predict the outcome.

For potential compensation claims, however, the nature and extent of any findings that survive the appeal may prove as important as the regulatory or sporting sanction ultimately imposed.

If substantial findings remain intact, greater attention is likely to turn to whether other participants can establish that they suffered identifiable financial loss as a consequence.

Burnley v Everton: Why Compensation Is a Live Issue

The wider significance of the Manchester City proceedings can also be considered against the separate compensation proceedings involving Burnley and Everton.

The important distinction is between regulatory sanction and compensation.

A points deduction, fine or other sporting sanction addresses a regulatory breach. It does not necessarily determine whether another participant has suffered recoverable financial loss because of that breach.

The key question for any compensation claim is likely to involve the counterfactual:

What would probably have happened if the breach had not occurred?

That type of analysis may become highly significant in any future claims arising from breaches of football's financial regulations.

Could Rival Clubs Claim Compensation from Manchester City?

Potential claims by rival clubs are one possible consequence if material findings against Manchester City survive the appeal.

A club might argue that, but for another club obtaining an impermissible sporting advantage, it would have achieved a different competitive outcome.

Depending on the circumstances, that might involve:

• Winning a competition or finishing in a higher league position;

• Qualifying for the UEFA Champions League or another European competition;

• Avoiding relegation;

• Progressing further in a cup competition; or

• Earning additional broadcasting, prize or other football related revenue.

Establishing a regulatory breach would not, however, automatically establish an entitlement to compensation.

A claimant would also need to identify a proper legal or regulatory route to recovery and establish the necessary causal connection between the breach, the relevant sporting outcome and the financial loss claimed.

Football results are affected by numerous variables. Establishing that a club would probably have achieved a different result or league position is potentially much more difficult than demonstrating that another club breached the rules.

Each potential claim will turn on its own facts, the applicable legal and regulatory framework, the available evidence and the nature of the loss alleged.

Could Individual Footballers Claim Compensation?

Potential claims are not necessarily confined to clubs.

This issue has moved beyond legal theory. Current reporting indicates that Premier League players and their agents are exploring potential compensation claims if the findings against Manchester City are upheld.

The position of each player will depend upon the individual's own circumstances.

Relegation, failure to qualify for European competition or another adverse league outcome can have direct financial consequences for professional footballers.

Depending on the terms of the playing contract, potential losses might include:

• Bonuses dependent upon Premier League survival;

• Bonuses linked to league position or European qualification;

• Appearance or performance payments contingent upon sporting outcomes;

• Reductions in salary following relegation; or

• Other contingent contractual payments.

Where a player can identify a specific contractual payment which would have become payable had the club achieved the relevant sporting outcome, the amount of the alleged loss may be relatively straightforward to calculate.

Establishing an entitlement to recover that loss is a separate issue.

A player would still need to establish a viable legal or regulatory basis for the claim and the necessary connection between the breach, any resulting sporting advantage, the club's competitive outcome and the player's personal financial loss.

The fact that a player's club suffered a competitive disadvantage would not, without more, mean that every member of the playing squad has a claim.

What Losses Could a Footballer Potentially Claim?

Potential player claims may broadly fall into two categories.

Specific Contractual Losses

The first concerns payments capable of being identified from the player's contract.

For example, a footballer may have been entitled to a bonus if the club:

• Avoided relegation;

• Achieved a specified league position;

• Qualified for European competition;

• Won a trophy; or

• Achieved another specified sporting objective.

The contractual terms, conditions attached to the payment and the player's own eligibility would all require examination.

Where the relevant conditions would have been satisfied under the proposed counterfactual, the amount of the alleged contractual loss may be identifiable.

The player must nevertheless establish the necessary legal basis for recovering that loss.

Lost Career Opportunities and Future Earnings

The second category is considerably more complex.

A current or former footballer might argue that relegation or another adverse sporting outcome affected the subsequent course of their career.

For example, a player might contend that, but for relegation, there would have been an opportunity to:

• Continue playing at Premier League level;

• Negotiate a more valuable playing contract;

• Earn enhanced salary or bonuses;

• Secure a transfer on more favourable terms; or

• Obtain greater subsequent career earnings.

A claim of this nature could require an assessment of a hypothetical career path and what would probably have happened had the sporting outcome been different.

Potentially relevant evidence could include:

• Age and contractual position at the relevant time;

• Appearance and performance record;

• Position within the squad;

• Salary and bonus history;

• Transfer history;

• Contemporaneous interest from other clubs;

• Injury history;

• Subsequent playing career; and

• Actual earnings.

Expert evidence may also become relevant when assessing career trajectory and the value of an allegedly lost opportunity.

A career based claim is therefore likely to present more complex evidential and causation questions than a claim concerning a fixed contractual bonus. Its potential value may, however, also be considerably greater.

Causation: What Would Have Happened But for the Breach?

Causation is likely to be at the heart of any claim by a rival club or individual player.

It would not ordinarily be sufficient merely to establish that a financial rule was breached and that the claimant suffered financial loss during the same period.

The claimant must connect the two.

For a footballer, that may involve establishing that:

1. The regulatory breach conferred a sporting advantage;

2. That advantage affected the relevant competitive outcome;

3. The different outcome prevented a contractual payment or opportunity from arising; and

4. The player consequently suffered identifiable financial loss.

The further the claim moves from a fixed contractual payment towards a hypothetical future career, the more complex that causal analysis is likely to become.

How Might a Football Compensation Claim Apply in Practice?

The 2010/11 Premier League season provides a useful illustration of the type of issue which might arise.

Blackpool finished 19th with 39 points, one point behind Wolverhampton Wanderers in 17th place. Blackpool also lost both of its Premier League fixtures against Manchester City that season.

Those facts do not establish that Manchester City's conduct caused Blackpool's relegation or that Blackpool or any individual player has a viable compensation claim.

They do, however, illustrate the type of counterfactual question that may arise if relevant findings against Manchester City are ultimately upheld.

Where a historic league outcome was decided by fine margins, an affected club might consider whether an established breach can properly be connected to its relegation or final league position.

An individual footballer then faces a further question:

If the club would probably have achieved a different outcome, what contractual payments or professional opportunities did that player lose personally?

That requires detailed legal and evidential analysis. A regulatory finding does not automatically create an entitlement to compensation for either a club or its players.

Historic Football Claims and Limitation

Many of the events underlying the Manchester City proceedings occurred a considerable time ago.

Any potential historic compensation claim will therefore require careful consideration of limitation.

The position may depend upon:

• The legal or regulatory basis of the proposed claim;

• The relevant contractual framework;

• The identity and status of the claimant;

• The forum in which the claim must be pursued;

• When the relevant cause of action accrued; and

• Any applicable provisions affecting the running of time.

Players and clubs should not assume from the age of the underlying events that a potential claim is necessarily time barred.

Equally, publication of the Commission's findings should not be assumed automatically to create a new limitation period.

The position must be analysed by reference to the facts and legal basis of the particular claim.

Early advice may also be important to ensure that playing contracts, financial information, correspondence, appearance records and other relevant evidence are identified and preserved.

The Wider Regulatory Context

The Manchester City proceedings are also taking place during a significant period of change in the regulation and financial oversight of English football.

The key issue for a footballer or club considering a compensation claim remains the outcome of the appeal, the findings that ultimately survive and whether the prospective claimant can establish actionable loss.

The broader regulatory debate provides context, but it does not determine whether any individual player or club has a claim.

My View: Football's Financial Rules May Have Consequences Beyond Sporting Sanctions

Public attention will understandably remain focused on Manchester City's appeal and the regulatory and sporting consequences which may follow if material findings are upheld.

The potentially more enduring legal significance may concern what happens afterwards.

There can be no assumption that the proceedings will result in successful compensation claims, or that every club or footballer affected by a historic sporting outcome will have a claim.

What is significant is that the issue is already extending beyond clubs. Current reporting indicates that players and their representatives are exploring potential individual compensation claims.

For clubs, potential losses may involve league positions, relegation, European qualification and lost revenue.

For footballers, the position is more personal. It may involve contractual bonuses and remuneration, together with potentially more complex questions concerning playing opportunities, subsequent contracts and future career earnings.

The answer in any individual case will turn on the facts and the applicable legal and regulatory framework.

What is increasingly clear is that the consequences of financial regulation in professional football may extend beyond the relationship between a club and its regulator.

Need Advice?

Barrington Atkins advises professional footballers, football agents and agencies, clubs and sports organisations on complex disputes, contractual claims, regulatory matters and high value financial claims arising within professional football.

If you are a player, agent or club considering whether a Premier League regulatory breach may have caused financial loss, advice can be provided on the potential merits and value of a claim, including causation, limitation, jurisdiction and the evidence required.