Manchester City has reportedly been found guilty of 114 of the 115 charges brought against it by the Premier League. The finding moves personal liability for football directors, and the D&O cover that sits behind them, firmly onto brokers' agendas.
The verdict, first reported by The Athletic, follows an independent commission hearing that concluded in December 2024. The Premier League has not officially confirmed it, City is expected to appeal, and the club continues to deny wrongdoing, maintaining that its position is supported by "a comprehensive body of irrefutable evidence."
For brokers, the most significant charges are those tied to documents that individuals sign. The charge sheet includes 54 counts relating to the accuracy of financial information provided to the league and 14 concerning the accuracy of player and manager remuneration details, covering the period from 2009 to 2018.
Financial submissions pass through finance directors, company secretaries and board members. A finding that inaccurate information was supplied over nine seasons inevitably raises the question of who approved it, and whether they knew, or should have known, that it was wrong.
The Premier League's disciplinary process punishes the club through fines, points deductions or, at the extreme, expulsion. It does not create a civil claim against individuals, and no such claim arising from the City case has been reported. If the finding survives appeal, however, any future claimant would have an adjudicated set of facts to point to rather than having to build that case from scratch. That claimant could be a rival club, a shareholder or another party with standing.
Football has already seen a regulatory breach turn into a compensation bill. On June 10, 2026, a Premier League commission ordered Everton to pay Burnley more than £35 million in compensation and interest. It found that Everton's breach of the Profitability and Sustainability Rules in 2021-22 gave it a sporting advantage that caused Burnley's relegation. Everton has appealed. That claim ran club against club, not against any Everton director personally, and whether the same logic can reach individuals remains an open legal question.
Directors' and officers' liability cover is built to respond to this kind of personal exposure. Its key limitation is the conduct exclusion, which typically removes cover for dishonest or fraudulent acts only once they are established by a final, non-appealable adjudication. Until then, most policies continue to advance defence costs.
A first-instance commission finding with an appeal outstanding does not meet that threshold. Any director named in a future claim would therefore expect defence costs to keep flowing through the appeal and any civil proceedings that follow.
The harder question for brokers is who that cover actually protects. The charges span 2009 to 2018, and many of the directors and officers involved have since moved on. D&O is written on a claims-made basis, so a claim brought today would fall to the policy in force now, not the one in place when the submissions were signed. Former directors are therefore relying on how the current programme treats past insureds, on its limits, and on any run-off arrangements, often with no say in how that programme is structured.
That makes the City case a live renewal conversation for brokers with football and wider sports clients. Several areas are likely to come under closer scrutiny: conduct exclusion wording, severability between insureds, the adequacy of Side A limits for individuals, and cover for regulatory investigations. Boards will be asking what protects them, while underwriters reassess a class largely priced around club-level sanctions and employment disputes.
None of that depends on how City's appeal ends. The verdict has already made it more likely that someone will test whether individual accountability can follow a regulatory finding, and D&O placements across the sport will be judged against that possibility.
