On 16 March 2026, the Premier League published its Sanction Agreement with Chelsea. There have been many questions about Sanction Agreements largely because we have not seen the recent significant Premier League cases dealt with using them.
In essence, they are settlement agreements and the Premier League argues they can’t be applied to PSR cases. That’s right, “obvious and deliberate breaches of the rules, [that] involved deception and concealment in relation to financial matters” canbe settled co-operatively, but any PSR casesmust go to full independent commission hearings. Apparently.
How they work
Under Rule W.6.7, the Premier League Board can conclude a written agreement with a club in which that club accepts a sanction proposed by the Board. That agreement must be ratified by three members of the Independent Disciplinary Panel, whose sole ground for rejection under Rule W.17 is that the proposed sanction is “unduly lenient.” Once ratified, it takes immediate effect. Once executed, it is published. Simple enough.
The 4 month mystery delay
Notably, the Chelsea agreement was ratified on 26 November 2025, broadly Day 1 of Chelsea’s FA charges hearing, but wasn’t executed and published until 16 March 2026. That nearly four-month gap is highly unusual. Were the parties waiting to see how the FA proceedings concluded before pulling the trigger? The document itself gives no answer. I have asked the Premier League if there was any reason.
You can’t appeal a settlement - it is the whole point
Many people have asked why can’t it be appealed despite its apparent leniency. It is because there is no mechanism to do so and it is the whole point in settlement via a Sanction Agreement - to draw a line for all parties. Once those three panellists sign off - here Sioban Healy KC, Dr Leanne O’Leary, and Robert Glancy KC - the agreement is ratified as acceptable. No club, third party, or rival can challenge it.
Contradictions
The Sanction Agreement is candid on one point - the Premier League acknowledges that had Chelsea not co-operated and admitted the breaches, certain aspects of the conduct*"may have been difficult to establish, to the relevant standard"before a Commission. The FA who, I am told, have no process akin to a Sanction Agreement, took a different view and went ahead with a full hearing regardless. The Premier League state in the Sanction Agreement that the FA are"likely to impose a significant sanction upon the Club"*which must mean the board considered it likely the FA will prove their case or that Chelsea will admit the breaches. In other words, the Premier League did not really believe it's own doubts about its ability to "put to proof" the case against Chelsea.
We also do not know whether this Sanction Agreement is the product of revisions following an initial rejection by the Disciplinary Panel as unduly lenient, or whether it was accepted at the very first review. This is open to a Disciplinary Panel but is not addressed in the document itself.
Which brings us to the uncomfortable other contradiction of the historic approach to PSR and other cases and, in particular, Nottingham Forest. We know more of the background to that case through its costs decision. The Premier League argued there that, under then Rule E.49, a PSR breach had to go to a full Commission and that no Sanction Agreement was available. Forest’s legal team told that same Commission something different: that the rulesdid allow for a Sanction Agreement even after a breach was established, and that Forest had actively sought to engage in those discussions but the Premier League declined. The point was never decided so remains open.
Without fear or favour almost always
And then there is Richard Masters and his public stance on legal matters. In August 2025, asked by the BBC’s Dan Roan whether the mounting legal costs of enforcement were a concern, the Premier League’s Chief Executive was unequivocal:“There’s no happy alternative to enforcing the rules - it goes to the integrity of the competition...I don’t think that principle should be defrayed in any way by being too difficult, too complex or too costly.”
The principle Masters articulated couldn’t be clearer - cases can’t be settled via a Sanction Agreement just because the circumstances were too difficult or too complex. The Premier League told a Commission while seeking over £1.4 million in costs from Forest, that a Sanction Agreement was impossible even where Forest was happy to engage in co-operation similar to that of Chelsea.
Months later the Premier League has settled a case involving far more serious admitted conduct, with no full hearing and no cross-examination of facts. And they haven’t changed the apparent PSR rule either.
One rule for one...
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