Manchester City’s historic 2022/23 treble has become part of a much bigger conversation surrounding the club’s financial affairs.
The Premier League announced on 29 September that an independent Commission had found City guilty of serious breaches of the league’s financial rules covering a nine-season period, as well as most of the charges relating to the club’s cooperation with the investigation.
With the findings now public, attention has inevitably turned towards what sanctions Manchester City could face and whether the club could ever be stripped of major honours won during Pep Guardiola’s era.
One trophy in particular has come under scrutiny: the 2023 UEFA Champions League.
How Manchester City Won the 2023 Champions League
Manchester City won the Champions League for the first time in their history in June 2023, beating Inter Milan 1-0 in the final in Istanbul.
Rodri scored the only goal of the game as City completed an historic treble, having already won the Premier League and FA Cup.
It remains one of the defining achievements of Guardiola’s time at the club.
However, the Premier League case has now placed fresh focus on City’s financial history, with the independent Commission finding breaches relating to the period between the 2009/10 and 2017/18 seasons.
That distinction is important when considering the Champions League title.
Why the 2023 Champions League Title Could Be Different
The Premier League Commission’s findings concern financial activity during a period that ended in 2018.
City’s Champions League triumph came five years later, in 2023.
That creates an important legal and regulatory question over whether UEFA could use the Premier League findings in any future action concerning a title won outside the period examined by the Commission.
The source material argues that this makes the 2023 Champions League particularly difficult to challenge.
UEFA’s current Disciplinary Regulations state that there is generally a five-year statute of limitations for prosecution, although procedural acts can interrupt that period and restart the clock. Match-fixing, fraud, bribery and corruption are treated differently and are not subject to that limitation
UEFA’s Club Financial Control Body rules also state that proceedings for breaches of its club licensing and financial sustainability regulations are generally barred after five years. (UEFA Documents)
That does not automatically settle the question of what UEFA could or could not do, but it shows why the timing of the alleged conduct is central to any discussion about sanctions.
Has UEFA Decided to Strip Manchester City of the 2023 Champions League Title?
At present, there is no UEFA decision stripping Manchester City of their 2023 Champions League title.
The Premier League finding is a domestic regulatory matter, while UEFA operates under its own statutes and disciplinary framework.
UEFA has previously taken action against Manchester City over financial regulations. In 2020, UEFA's Club Financial Control Body imposed a two-season exclusion from UEFA competitions over alleged breaches of its financial regulations. That decision was subsequently appealed to the Court of Arbitration for Sport, which reduced the sanction after finding that many of the alleged breaches were time-barred and that there was insufficient evidence to uphold all of UEFA’s conclusions. (UEFA.com)
That history shows that any future UEFA action would be subject to UEFA's own regulatory and appeal processes.
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What Happens Next in the Manchester City 115 Charges Case?
The latest Commission finding does not immediately determine Manchester City’s sanction.
The Premier League confirmed that the issue of sanctions will be dealt with separately in a further hearing before the independent Commission. The club also has the right to appeal the findings, with a deadline of 2 October 2026 to exercise that right.
That means the current findings are not necessarily the final word on the domestic case.
The Premier League said the Commission found City guilty of serious breaches involving financial reporting and spending limits, while also finding that the club breached its obligations to cooperate with the investigation.
City’s eventual sanction, and any subsequent appeals, will therefore be closely watched across European football.
Could Other Premier League Clubs Take Legal Action Against Manchester City?
The consequences may extend beyond formal sporting sanctions.
The original source also highlights the possibility of legal claims from other clubs that argue Manchester City’s financial breaches affected the competitive and economic environment of the Premier League.
However, the scale and outcome of any such claims cannot be established until the relevant proceedings are brought and decided.
For now, the immediate focus remains on the independent Commission’s forthcoming sanctions process and Manchester City’s potential appeal.
Could Manchester City Lose Their 2023 Champions League Title?
There is currently no decision saying Manchester City will lose their 2023 Champions League title.
The key issue is that the Premier League Commission’s findings concern alleged breaches between 2009/10 and 2017/18, while City’s Champions League victory came in 2023. UEFA also has its own limitation rules governing financial and disciplinary proceedings.
That makes the situation considerably more complicated than simply removing a trophy following the Premier League ruling.
Manchester City still face potentially significant consequences from the domestic case, but any action concerning their 2023 European title would involve UEFA's own regulatory framework and, if contested, potentially further appeals.
For now, Manchester City's 2023 Champions League title remains unaffected by the Premier League finding. What happens next will depend on the domestic sanctions process, any appeals and whether UEFA takes separate action.
