If Manchester City Lose a Premier League Title, Who Would Be Champion?
A commission has found the charges against Manchester City proven. City are appealing and no punishment has been set. Before anyone redraws the honours board, there's a more basic question: do the Premier League's rules, or any comparable case, actually hand a stripped title to the runner-up?
What Happens If Manchester City Are Stripped of a Premier League Title?
Where the case stands
On 29 September an independent commission published its core findings, after a 42-day hearing that finished in December 2024. It found City guilty of the financial charges covering nine seasons, 2009/10 to 2017/18, and of most of the charges about cooperating with the league's investigation. Put simply, the commission concluded City dressed up owner money as sponsorship income, understated some costs and filed misstated accounts. On honest figures, it said, the club would have broken Premier League and UEFA spending limits "by a very substantial amount". It also found that some witnesses City called gave evidence they knew was untrue.
City denies it. The club says the ruling contains "clear material errors of law, principle and fact" and lodged its appeal at 7pm on 1 October. League rules say the hearing should happen within 12 weeks of filing, with a decision due within 30 days of it ending. Sanctions go to a separate, private hearing, and it hasn't been made clear whether punishment can land before the appeal is decided.
City are expected to argue that the money came from the Abu Dhabi government rather than their owner, and British media say a High Court challenge to the process is possible, because the Court of Arbitration for Sport isn't available.
The league opened its investigation in December 2018 and issued charges in February 2023. The commission admitted its decision took far longer than it wanted, with around 7,000 pages of witness transcripts to get through.
What the rulebook allows
The commission's sanctions rule, numbered W.64 in the current handbook according to Football365, lets it reprimand a club, fine it without limit, suspend it, deduct "points scored or to be scored", recommend a replay or an expulsion, order compensation, cancel player registrations, combine any of those, and make whatever other order it thinks fit. The league calls the list non-exhaustive.
Stripping a title isn't on it. Neither is giving one to somebody else. The BBC's reading is that the catch-all could theoretically stretch to retrospective points deductions or title removal.
The BBC was told there's little appetite inside the league or among clubs to take titles away, with a points deduction, huge fine or even expulsion seen as likelier. The Athletic says any deduction could be applied now or retrospectively. Nothing has been decided. For scale, Everton's deduction was cut from a record ten points to six, and Nottingham Forest lost four, for a single three-year overspend. City's breaches span nine seasons.
Stripped isn't the same as awarded
In the handbook text I could read, the champion is the club top of the table at the end of the season, and the current handbook keeps a section headed The League Championship. I couldn't find a rule that moves a title down the table. If titles were touched, there are three possible routes.
The first is to vacate it. Marseille lost the 1993 French title over a fixed match and it was never reassigned, because runners-up PSG refused it. Juventus's 2004/05 Serie A title was also left blank.
The second is to recalculate it. This is my reading, not a ruling: if a commission deducted points from a past season, the table itself would pick the new champion and nobody would be "awarded" anything. The BBC notes there's no Premier League precedent for any of this.
The third is to expunge City's results. Sky points out this would shift other clubs' points too, though it says United and Liverpool would still replace City as champions across 2009/10 to 2017/18.
The sharpest legal line comes from Turkey. Trabzonspor finished second to Fenerbahçe in 2010/11 and argued for years that match-fixing by Fenerbahçe officials made the title theirs. In 2019 CAS found no provision letting a runner-up be "automatically declared champion". Different rulebook, same logic, and nothing I've found in the Premier League's points the other way.
The future of Manchester City’s titles now depends on the outcome of the club’s appeal and any sanctions that may follow.
Would Liverpool, Manchester United or Arsenal Inherit City’s Titles?
The eight titles
Only three of City's eight titles fall inside the period the commission examined: 2011/12, 2013/14 and 2017/18. The other five came later. The non-cooperation charges ran from December 2018 to February 2023, but they concern conduct towards investigators, not spending, and nothing official suggests they'd reach back into title races.
Using the final league-table figures, and my own arithmetic assuming only City's total changes, the margins look like this:
2011/12: City and United both on 89, City ahead on goal difference. One point would flip it.
2013/14: City 86, Liverpool 84. Three points.
2017/18: City 100, United 81. Twenty points.
2018/19: City 98, Liverpool 97. Two points.
2020/21: City 86, United 74. Thirteen points.
2021/22: City 93, Liverpool 92. Two points.
2022/23: City 89, Arsenal 84. Six points.
2023/24: City 91, Arsenal 89. Three points.
The league breaks ties on goal difference, then goals scored, and City would win every tie.
Five of the eight flip with three points or fewer. 2017/18 would take twenty. Nobody has proposed a deduction like that, but it shows how arbitrary a recalculated table would be: the champion would depend on a number a commission had to choose.
The Liverpool question
Liverpool were runners-up to City three times. In 2013/14 it was two points, the season of Steven Gerrard's slip. In 2018/19 their 97 points is the most any non-champion has recorded, and City answered with 14 straight league wins. In 2021/22, City came from 2-0 down against Aston Villa on the last day to win 3-2, while Liverpool beat Wolves 3-1. It finished 93 points to 92.
Only 2013/14 sits inside the financial findings. For the other two, a commission would have to reach beyond what it examined, and nothing official suggests it will. Even for 2013/14 the rules give Liverpool no automatic route: they'd arrive via a recalculated table or an explicit decision naming them. Neither exists.
Arsenal, United and the rest
Arsenal's two second places, 2022/23 and 2023/24, are outside the period, and they've since won the 2025/26 title with 85 points. United's seconds in 2011/12 and 2017/18 are inside it; 2020/21 isn't. The other honours in the window, the 2011 FA Cup, three League Cups and a Community Shield, belong to the FA and the EFL rather than the Premier League. The FA says it's weighing the decision and will act where appropriate.
How Previous Football Cases Changed League Titles
Has it happened before?
Juventus (Calciopoli) is the closest case of titles actually being removed. Italian sports justice found Juventus ran an illicit system influencing games in 2004/05, and relegated them to Serie B with a points penalty. The 2004/05 title was left unassigned. The 2005/06 title also went to Inter, who had finished third but were the highest-placed club once points were docked. It was the federation's extraordinary commissioner, Guido Rossi, who awarded it. His successor argued it should have stayed unassigned. Juventus lost their challenges and still count both titles.
It isn't directly comparable: the offence was manipulating referee selection, which goes straight to match outcomes, and the award came from an emergency official rather than a rule. City's case is about accounts and spending limits.
Rangers is the nearest match in type, with the opposite result. A Scottish commission found the club failed to disclose player payments, fined the old company £250,000, and ruled Rangers "did not gain any unfair competitive advantage", so titles stayed. That's the question likely to matter here: how far did the breaches change results? The commission found City would have broken spending limits by a very large margin, but I haven't seen a finding on points in the published core decision, and the appendices aren't out yet.
Elsewhere, there are Marseille and Fenerbahçe, above, and Elgin City, who lost the 1992/93 Highland League title for fielding ineligible players. None involved a spending-limit breach.
What Happens to Manchester City’s Titles, Records and Medals?
Record books, medals and players
I found no rule or league statement covering honours lists, medals, individual awards, or whether goals and appearances would stay official. Sky frames the choice as vacant or expunged. Juventus's case suggests even formal removal leaves the argument running.
Players are the human problem. The BBC notes many will see it as unfair for players and fans unconnected to any breach to lose titles, and former City midfielder Rodri said "everything was deserved". Guardiola said before the verdict that "No-one can remove it". Martin Lipton argued stripping 2012 would mean Agüero's 94th-minute goal never happened: "You can't rewrite history to that extent." Mourinho joked in 2024 that United should "give me the medal" for 2018.
Can you rewrite a season?
Reactions split along predictable lines. Jamie Carragher has called for titles to be stripped. Jürgen Klopp joked he'd host a party in Mallorca. Tony Pulis doesn't expect trophies to change hands but says he still feels "cheated". Shaun Wright-Phillips argued in 2023 that rivals wouldn't want trophies they hadn't won on the pitch.
The more likely correction is financial. Everton were ordered to pay Burnley more than £35m after Burnley argued they'd have stayed up in 2021/22 had Everton been punished that season. Other clubs have sought legal advice on compensation. A lawyer told the BBC the list of possible claimants is potentially endless.
What Happens Next in Manchester City’s Appeal?
What to watch
The appeal hearing should come within 12 weeks of 1 October, so by roughly Christmas, with a ruling within a month of it ending. The sanction hearing has no date. Until both have spoken, the honest answer to the headline question is that the rulebook doesn't say.
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