Testing this theory on the legal eagles on here: the Premier League has deliberately framed the charges under Section W as regulatory and disciplinary breaches rather than borderline civil or criminal fraud, drawing on the lessons from the CAS proceedings, where fraud-type allegations proved extremely difficult to establish.
As a result, there are no allegations of dishonesty, the Ivey test does not apply, and the panel is not being asked to make moral judgments about intent. The case is about compliance, reporting, and cooperation — in other words, whether City followed the rules. That makes the charges objectively justiciable and far easier to determine on a technical basis.
This approach helps the Premier League when it comes to establishing liability, but it also limits how severe any punishment can realistically be. Once you stay within a purely regulatory framework, the focus at the sanction stage has to be proportionality rather than condemnation. You are no longer in “fraud” territory; you are in “regulatory breach” territory.
That also explains why relegation or expulsion would be very difficult to justify. Those kinds of sanctions normally require findings of fraud or bad faith, which the Premier League has chosen not to allege here. Even if City are found guilty on multiple charges, the likely outcomes are points deductions and fines rather than existential punishment. A deduction somewhere around 6–12 points is a reasonable expectation, not an extreme one. And because this is a regulatory case involving long delays and older issues, any sanction is particularly open to being reduced on appeal without overturning the findings themselves.
In short, the Premier League has maximised its chances of winning the case, but in doing so it has also narrowed the range of sanctions available at the end. This is also why City appear relatively relaxed — relegation was never realistically on the table.
It also significantly reduces the risk of knock-on legal action from other clubs. By keeping the case within a purely regulatory Section W framework and avoiding any findings of fraud, dishonesty, or bad faith, the Premier League has removed the legal foundation that most civil claims would depend on. Without those findings, it becomes extremely difficult for rival clubs to establish causation, loss, and intent in a damages claim against either the league or City. While the risk of litigation can never be reduced to zero, this approach makes follow-on lawsuits far less attractive, far more expensive, and far less likely to succeed in practice.