Manchester City's financial-rule scandal represents a major test of the Premier League's credibility, according to two sports law specialists who have warned that an insufficient punishment could undermine confidence in English football's regulatory system.

An independent commission found Manchester City guilty of 114 of the 115 charges brought against them, including serious breaches of financial regulations covering nine seasons between 2009 and 2018.

The findings, published in September, detailed how the club used misleading commercial agreements to inflate revenue and concealed the true state of its finances from auditors and football authorities.

According to the commission, the arrangements enabled City to record approximately £830m in commercial income that did not accurately reflect the underlying financial transactions.

The club have consistently denied wrongdoing and lodged an appeal on October 1, arguing that the commission's conclusions contain significant errors of law, principle and fact.

No punishment has yet been determined, with the disciplinary process and appeal proceedings continuing.

However, the potential consequences have prompted questions about how the Premier League can impose a proportionate sanction in a case of unprecedented scale.

Brazilian publication Trivela interviewed sports law specialists Ana Mizutori and Andrei Kampff, both of whom hold master's degrees in the field, to examine the legal challenges facing the competition.

Their assessments suggest that the eventual punishment must reflect the nature and seriousness of the proven breaches, rather than simply follow the precedents established by other clubs.

Legal experts warn against inadequate Man City punishment

Mizutori believes the Manchester City case could have implications extending well beyond the Premier League.

"This is a test of governance for European football, of the ability of sporting bodies to ensure that economic power does not override the integrity of competitions," she told Trivela.

Her warning reflects concerns that an inadequate financial penalty could weaken the deterrent effect of regulations intended to maintain competitive fairness.

A fine that can be comfortably absorbed by a wealthy club, the specialists argue, risks creating the impression that breaching financial regulations is an acceptable commercial gamble.

However, determining an appropriate sanction is considerably more complicated than applying the punishments previously imposed on other Premier League clubs.

Everton received a 10-point deduction in November 2023 for breaching the league's Profitability and Sustainability Rules, subsequently reduced to six on appeal. They were later deducted a further two points for a separate breach.

Nottingham Forest also received a points deduction during the 2023-24 campaign, while Chelsea's more recent financial irregularities resulted in a different disciplinary outcome, including a substantial fine and a suspended transfer ban.

Kampff believes those cases offer useful guidance on disciplinary methods but cannot provide a straightforward formula for City's punishment.

The lawyer highlighted the importance of distinguishing between exceeding permitted losses and deliberately concealing financial information over an extended period.

"The comparison requires distinguishing excessive losses, deliberate concealment and the duration of the conduct," Kampff explained to Trivela.

"City have the aggravating factor of non-cooperation during the investigations. The unprecedented nature of the case leaves room for a decision that could surprise, but it needs to be well justified."

The commission found that City failed to cooperate with aspects of the Premier League's investigation, although the club continue to dispute the overall findings.

Mizutori stressed that the club must retain the full right to challenge the evidence and contest disciplinary decisions.

However, she argued that exercising the right to defend itself should be distinguished from failing to meet legitimate regulatory obligations.

"The right of defence must be fully preserved, but it cannot be confused with the right to prevent or obstruct legitimate sporting oversight," she added.

Premier League faces unprecedented challenge over sporting sanctions

The difficulty facing the Premier League extends beyond deciding whether City should receive a substantial points deduction, a financial penalty or an even more severe sporting sanction.

There is also the question of whether historical achievements should be reconsidered if the commission's findings survive the appeal process.

City won three Premier League titles between 2009 and 2018, alongside three League Cups and an FA Cup.

Removing historical titles could create further complications involving clubs that missed out on European qualification, prize money or commercial opportunities during the relevant seasons.

Mizutori explained that any rival seeking compensation would need to establish the damage suffered, demonstrate a legally sufficient causal link to the proven misconduct and address possible limitation periods.

Consequently, even if City's appeal fails, the outcome would not automatically entitle rival clubs to financial compensation or retrospective honours.

Kampff also believes that points deductions must carry meaningful sporting consequences if they are to deter serious breaches.

"Financial fair play needs to be an instrument that deters prohibited conduct," he told Trivela.

"Points deductions must have a concrete effect, including the eventual possibility of relegation."

His assessment does not amount to a prediction that City will be relegated, but underlines the importance of ensuring that any sanction has a genuine impact.

Both specialists argue that the disciplinary outcome should be independent, transparent and proportionate to the breaches, while fully respecting the club's legal rights.

The distinction is particularly significant because the appeals process could alter or overturn the commission's original findings.

City's appeal will be considered by an independent Appeal Board, with the Premier League confirming that proceedings will remain confidential until the outcome can be published.

For Mizutori, the wider issue is whether football's financial regulations can protect competitive equality rather than merely oversee clubs' accounts.

"Financial sustainability rules do not just protect clubs' accounting balance sheets," she explained. "They also aim to preserve equal competitive conditions, transparency and the integrity of the competition itself."

With no definitive sanction announced, the Premier League faces the challenge of reaching a decision that can withstand legal scrutiny while maintaining confidence in its ability to enforce its own regulations.