An open letter yet to be lodged…..
Introduction
This complaint concerns a group of Premier League clubs—Arsenal, Liverpool, Manchester United, and Tottenham Hotspur—acting as a cartel to maintain dominance in English football at the expense of fair competition. Their undue influence has distorted financial regulations, led to preferential treatment, and undermined competition law principles. We request that the CMA formally investigates these clubs and their influence over Premier League governance.
1. Coordinated Activity
The cartel clubs have engaged in coordinated efforts to shape Premier League rules to their advantage:
- Arsenal Headed Letter – These clubs demanded the Premier League adopt Financial Fair Play (FFP)-style rules to prevent challenges from clubs like Manchester City. (See Appendix 1)
- The “Hateful Eight” Incident – A coordinated attempt to influence Manchester City’s appeal to the Court of Arbitration for Sport (CAS). The four cartel clubs were signatories to a petition against City. (See Appendix 2)
- Legal Threats Against Manchester City – On 5 November 2024, all four cartel clubs registered their intention to sue Manchester City for damages if the club loses its Profit and Sustainability Rules (PSR) case. (See Appendix 3)
- Project Big Picture – Devised by Liverpool and Manchester United, with support from Arsenal and Tottenham, this plan sought to grant long-term control of the Premier League to six clubs, with a smaller group of four wielding even greater power. (See Appendix 4)
2. Preferential Treatment and Arbitrary Enforcement of Prejudicial Rules
Premier League rules have been applied inconsistently, benefitting cartel clubs while punishing competitors:
- Manchester City’s APT Rules Challenge – The Premier League unfairly restricted Manchester City’s sponsorship revenue under Associated Party Transaction (APT) rules, leading to financial disadvantages. (See Appendix 5)
- Nottingham Forest PSR Sanctions – Despite being allowed a lower loss threshold due to their recent promotion, Forest were still sanctioned for breaching PSR. Had they been given the same allowances as other clubs, they would not have breached the limit. (See Appendix 6)
- Manchester United’s PSR Breach (2024) – Manchester United exceeded the PSR limit, yet faced no sanction, in contrast to Everton and Nottingham Forest, who were punished for similar breaches in 2023. (See Appendix 7)
- Manchester United’s Additional Loss Allowance – Manchester United was permitted £75m in additional losses, an allowance denied to Everton, Newcastle, Manchester City and Chelsea. (See Appendix 8)
- Cost of PSR Legal Cases – The Premier League has spent over £100m on PSR enforcement, diverting funds from clubs and creating financial instability. (See Appendix 9)
3. PSR Rules Breach Competition Law
The PSR and APT rules have been applied unfairly and in a manner that violates competition law:
- Manchester City’s Legal Challenge on Revised APT Rules (2025) – The Premier League has not honoured a legally binding arbitration ruling on APT, forcing Manchester City to launch further legal action in January 2025. (See Appendix 10)
- Unlawful APT Rules – Introduced in 2018, APT rules were declared unlawful, yet clubs like Arsenal and Liverpool, who benefitted from preferential shareholder loans, have not been penalised. (See Appendix 11)
- Failure to Repeal Unlawful Rules – The Premier League has refused to void previous punishments under the now-illegal APT rules, maintaining an imbalance that protects cartel clubs. (See Appendix 12)
4. Undue Influence and Power of the Cartel
- Journalist Allegations of Veto Power – Martin Samuel alleges Liverpool and Manchester United have a veto over the appointment of the Premier League CEO. (See Appendix 13)
- Allegations Against Tottenham’s Daniel Levy – Martin Samuel also alleges that Levy ordered the Premier League to charge Manchester City with PSR breaches before the investigation was completed. (See Appendix 14)
- Leak of Charges to Media – Journalist Martin Ziegler was informed of Manchester City’s charges before the club itself, indicating bias within Premier League governance. (See Appendix 15)
5. Commercial Danger and Risk to the Premier League
- Financial Burden of PSR Cases – The ongoing legal disputes have already cost over £100m, with more cases expected. (See Appendix 16)
- Risk of League Collapse – If the Premier League continues down this path, financial instability may lead to its collapse, paving the way for cartel clubs to push for a breakaway European Super League. (See Appendix 17)
- Impact on UK Economy – A collapse of the Premier League would damage local economies, businesses, and employment across the country. (See Appendix 18)
- PFA Threatens Legal Action Over Squad Cost Rules (SCR) and Top-to-Bottom Anchoring (TBA) – The PFA opposes the introduction of TBA, which would cap spending at five times the lowest-earning club’s revenue. Players have threatened to strike if imposed. (See Appendix 19)
Conclusion
The evidence outlined above demonstrates that the Premier League is being manipulated by a small cartel of clubs, leading to anti-competitive behaviour, inconsistent rule enforcement, and financial mismanagement that threatens the integrity of English football. We formally request that the CMA investigates this matter urgently and takes appropriate action to restore fair competition in the Premier League.
Appendices
Appendix 1 – Arsenal Headed Letter on Financial Regulations
Appendix 2 – Coordination of “Hateful Eight” Petition Against Manchester City
This image was taken from the CAS Summmary of the FFP Case involving Manchester City:
Appendix 3 – Legal Threats by Cartel Clubs Against Manchester City
https://www.football365.com/news/man-city-ffp-forced-pay-european-clubs-compensation
Appendix 4 – Project Big Picture and Its Impact on Premier League Governance
https://www.bbc.co.uk/sport/football/54531760
Appendix 5 – Manchester City’s APT Rules Challenge and Sponsorship Impact
Appendix 6 – Nottingham Forest’s PSR Sanctions Compared to Other Clubs
Appendix 7 – Manchester United’s 2024 PSR Breach Without Sanction
Appendix 8 – Manchester United’s £75m Additional Loss Allowance
Watch from 3mins and 7 seconds to 5 mins – to see what these are.
Watch from 6 mins and 55 seconds to 11 mins 37 seconds – to see how Everton were denied allowances which Manchester United were given
Appendix 9 – Total Cost of PSR Legal Cases to Premier League Clubs
https://www.bbc.co.uk/sport/football/articles/c3wpdqlqjq4o
Appendix 10 – Manchester City’s 2025 Legal Challenge Against APT Rules
https://www.sportbusiness.com/news/man-city-launches-new-challenge-over-apt-rules
Appendix 11 – The Unlawful Nature of APT Rules and Their Impact
https://talksport.com/football/2122869/manchester-city-premier-league-commercial-deals
Appendix 12 – Premier League’s Failure to Repeal Unlawful APT Rules
Appendix 13 – Journalist Claims Regarding CEO Veto Power
Appendix 14 – Allegations Against Daniel Levy’s Influence Over PSR Charges
Appendix 15 – Leak of Manchester City’s Charges to the Media
https://www.thetimes.com/article/man-city-premier-league-charges-explained-glwhldk58
Appendix 16 – Financial Impact of PSR Legal Battles
Appendix 17 – Risk of Premier League Collapse and European Super League Formation
Appendix 18 – Economic Impact of Premier League Instability on UK Businesses
Instability in the Premier League can significantly impact UK businesses, particularly those directly linked to the sport through sponsorships, hospitality, tourism, and local retail, by causing a decline in revenue due to reduced fan engagement, lower merchandise sales, and decreased interest from potential sponsors, potentially leading to job losses and a ripple effect through the local economy, especially in cities with Premier League clubs; furthermore, a turbulent league could damage the UK’s international image associated with the sport, impacting tourism and global brand perception.
The economic impact of a large employer closing down is often cited as having a ripple effect of 20 times its turnover in the local economy. As the Premier League turns over £8 Billion a year this could amount to a £160 Billion impact across England.
https://www.premierleague.com/news/3884417