An independent Commission has recommended that an immediate six-point deduction be imposed on Leicester City FC in the Championship, having found them to be in breach of the EFL Profit and Sustainability Rules (P&S Rules) for Season 2023/24.
Upon Leicester City’s promotion to the Premier League in 2024, the EFL’s investigation into the club’s alleged breaches of the P&S Rules transferred to the Premier League. Following an Arbitration Tribunal’s decision in March 2025 that confirmed the Premier League had jurisdiction, Leicester City were referred to an independent Commission in May 2025.
During a week-long hearing in November 2025, Leicester City raised a range of legal challenges regarding the applicability of the relevant Rules and the Commission’s ability to impose a sanction on the club, all of which were rejected. These included a claim that the relevant rules were in breach of competition law. Â
The Commission accepted the club’s submissions as to the length of the relevant assessment period and that a particular accounting policy relating to player costs should apply to reduce the club’s losses in its 2022 annual accounts. Having done so, it determined that the club had breached the relevant P&S threshold by £20.8million over the three-year assessment period (2022-2024).
The Commission found that the club’s refusal to provide its annual accounts to the Premier League by the relevant deadline was a breach of Premier League Rules. It also dismissed a claim by the club that it had demonstrated exceptional cooperation throughout the proceedings. Following agreement by the parties, and consistent with the relevant guidelines, the Commission agreed that the club’s improving financial position over the relevant assessment period was a mitigating factor.
Under EFL Regulations, as Leicester City is currently a Championship club, the EFL Board today ratified the Commission’s recommendation of an immediate points deduction.
Click here to read the independent Commission’s full written reasons. A summary of the decision can be found here.
Commissions are independent of the Premier League and member clubs. The members of the Commission were appointed by the independent Chair of the Premier League Judicial Panel. Â
Notes
EFL P&S Rules (see EFL handbook) and Premier League PSRs (see Premier League Handbook Section E)
– All EFL Championship clubs are assessed for their compliance with the Profit & Sustainability Rules (P&S Rules) each year. The P&S Rules are substantively similar to the League’s Profitability and Sustainability Rules (PSRs), which apply to all Premier League Clubs up until the end of the 2025/26 season. A new set of financial rules will come into effect from the start of the 2026/27 season.
– Under the EFL Regulations, when a Championship club is promoted to the Premier League, the EFL can transfer jurisdiction for any ongoing investigation into breaches of the P&S Rules to the Premier League
– Where a Commission selected from the Premier League’s independent Judicial Panel recommends the imposition of a points deduction in the Championship, Regulation 87.7 of the EFL Regulations applies.
– Compliance with the P&S Rules is assessed by reference to the club’s P&S Calculation, which is the aggregate of its Adjusted Earnings Before Tax for the relevant assessment period.
– The relevant three-year assessment period is measured by reference to a club’s annual accounts, which normally cover a 36-month period. When a club extends its accounting year-end, the annual accounts will, taken together, cover an extended period. As it was permitted to do, Leicester City extended its accounting year end in 2023, meaning the period covered by the club’s annual accounts in this assessment period was 37 months. The Commission accepted that a literal interpretation of the P&S Rules would normally result in a 37-month period applying, but decided that, in the particular circumstances of this case, the applicable assessment period was 36 months.
– A club’s Adjusted Earnings Before Tax figure for each season takes account of its profit or loss after depreciation and interest, but before tax, and then applies a series of “add backs”.
– These “add backs” are costs that the EFL, the Premier League and their clubs recognise to be in the general interest of the club and football. Examples include, investment in infrastructure, community, women’s football, youth development and depreciation of tangible fixed assets.
– A club will be in breach of the P&S Rules if its P&S Calculation over the relevant period results in a loss in excess of £39 million (with that threshold increased by £22million for each season that a club has been in the Premier League during the relevant period).
– Leicester City’s loss threshold under the P&S Rules was £83million.
– The EFL commenced an investigation into Leicester City for the club’s alleged breaches of the P&S Rules for the three-year assessment period ending in the club’s 2024 financial year. Upon Leicester City’s promotion at the end of Season 2023/24, on 6 June 2024, the EFL’s investigation into these matters transferred to the Premier League.
– Premier League clubs that recorded a loss across the previous two financial years were required to submit their audited annual accounts by the following 31 December. This requirement has been amended slightly with effect from the 2025/26 season so that each club (including each promoted club) must now, as a matter of course, submit by 31 December each year its annual accounts for the previous financial year.
Premier League investigations and independent Commissions 
– The Premier League Board has the power to investigate any suspected or alleged breach of Premier League Rules. Rule E.77 of the 2024/25 Rules (now Rule E.83) provides that where a Promoted Club, at the point at which it becomes a member of the Premier League is the subject of an investigation by the EFL for alleged breaches of any aligned provisions within the EFL Regulations, responsibility for that investigation will pass to the Board.
– There are a number of options available to the Board where it suspects or alleges a breach of the Rules. For PSR/P&S cases, the matter will be handed to an independent Commission to determine whether there is a breach and, if so, what the sanction should be.
– Significant disciplinary matters, such as PSR/P&S complaints are dealt with by an independent Judicial Panel, comprising a number of legal, financial and other experts. Members of the Judicial Panel are appointed, in accordance with Premier League Rules W.19, W.20 and W.26, by its independent Chair, The Rt. Hon. Sir Gary Hickinbottom, an experienced former Court of Appeal judge. It is the Chair who selects members of the Judicial Panel to sit on Commissions, which are independent of the Premier League and its clubs.
– All proceedings before an independent Commission are confidential and heard in private.
– There are a range of sanctions available to the independent Commission which include fines, points deductions and other sporting sanctions.
– Under Premier League Rule W.83.3, at the conclusion of proceedings, an independent Commission’s final decision will be made public via the Premier League’s website.
– A party to the proceedings that wishes to challenge a decision of the independent Commission may do so under Section W of the Premier League Rules.