The Manchester City cheating scandal could escalate into a criminal investigation, it has been claimed.

The Premier League club were found guilty of more than 100 charges of financial manipulation between over a nine-year period between 2009 and 2018.

The report from an independent Commission, published yesterday, said Manchester City were guilty of hiding more than £900m in cash they received from owners Abu Dhabi United Group (ADUG) via “sham” sponsorship deals.

The cheating coincided with a period of unprecedented success for Manchester City on the pitch as the club won numerous Premier League titles and cup competitions.

Manchester City continue to strenuously deny any wrongdoing, claiming they have “irrefutable” evidence of their innocence, which they say the Commission ignored, and they have promised to appeal the decision.

Manchester City would have to file any appeal by Friday, the league said.

The Commission’s report was damning, however, and the question now turns to what punishment Manchester City should face.

Should there be a police investigation?

In terms of the Premier League, there are calls for Manchester City to be deducted points on a scale so significant it could make relegation inevitable, and perhaps sanctions that continue into future seasons.

Off the pitch, there are suggestions that Manchester City as a corporate entity and its directors, including the chief executive of City Football Group Ferran Soriano, should face action. Speaking on Tuesday, Soriano said the guilty verdicts against the club for breaches of financial rules are based on “a single false accusation” and a “Premier League conspiracy theory”.

Lord Peter Cruddas, a Tory peer and founder of CMC Markets, which sponsors Everton football club, suggested there should be a criminal investigation.

“Surely the Man City findings are now a police matter,” Cruddas told .

“If accounts have been falsified and auditors have been misled, then it is potentially a criminal matter. The auditors will call in the police, directors are personally libel [sic] for any fraud of a UK company, even if it is foreign-owned.”

Tax expert Dan Neidle has also said he believes there are “civil and criminal tax implications” to what he called “the Manchester City shenanigans”.

HMRC declined to comment, citing taxpayer confidentiality.

What is the law?

The law around corporate crime in sport changed significantly in 2023 with The Economic Crime and Corporate Transparency Act.

It was intended to make it easier to prosecute commercial organisations.

Sports law expert Jim Sturman KC wrote in a blog post at the time that “for decades the authorities have been convinced that bribery and tax fraud has been rife in sport” and that he believes that “the Serious Fraud Office (SFO), the National Crime Agency and the Crown Prosecution Service would see a high-profile prosecution of a Club as a momentous prosecution.”

Offences under the new law include cheating public revenue, conspiracy to defraud and false accounting.

Individuals convicted can face up to two years in prison, an unlimited fine or both.

A company can also be subject to an unlimited fine and confiscation of related profits.

Sturman suggested a scenario where the directors of a club colluded with an accountant or sponsor to “massage the books” or make a false statement about the level of sponsorship to get around financial fair play rules; a prosecution for false accounting of the directors under the Theft Act might be brought.

He also wrote that inflating the value of a transaction above fair market value “could plainly amount to false accounting and potentially render the Club liable to criminal prosecution under the new act”.

False accounting is also an offence under the Theft Act 1968 and comes with a maximum penalty of seven years’ imprisonment.

Football regulator’s biggest test

The Manchester City scandal also presents a huge test for the newly created Independent Football Regulator (IFR), which was only set up last year.

The regulator has the power to assess the suitability of football club owners and take action such as banning people from being directors or even forcing a sale.

IFR Chair David Kogan released a statement on Wednesday saying he would not be getting involved until the Premier League process is complete.

Manchester City have until Friday, 2 October, to exercise their right to an appeal.

“The independent commission’s decision raises serious issues,” said Kogan.

“The IFR has powers to assess the suitability of owners, directors and executives and we will use these powers where appropriate, in the interests of protecting the sustainability, honesty and integrity of English football where there is clear evidence of wrongdoing by individuals.

“This includes taking account of findings made by the Leagues. However, as the proceedings remain ongoing between Manchester City and the Premier League, we will await further developments.

“We hope it can be resolved quickly for the sake of fans. For now, we have no further comment.”