There have been a number of occasions in the past when clubs have successfully claimed compensation from other clubs.
West Ham United paid Sheffield United £20m in an out-of-court settlement in 2009.
The Hammers had signed Argentine duo Carlos Tevez and Javier Mascherano but broke third-party ownership rules in the process.
Sheffield United, who were relegated after a final-day loss to Wigan, took West Ham to a tribunal before the settlement was reached.
In 2022, Derby County and Middlesbrough reached a “resolution”, which the BBC believes to be £2m, over the compensation claim brought against the Rams by their fellow Championship side.
Middlesbrough had launched legal proceedings, claiming Derby’s financial breaches cost them a play-off place in 2018-19.
But the Everton case is a new chapter, with a club taking action over sporting loss directly to a league commission.
“This is a significant moment for football governance,” Jan Levinson, partner in the Manchester office of law firm Foot Anstey, told BBC Sport.
“It shows that breaches of financial rules are not simply a matter between a club and the league.
“Where another club can show it has suffered a real commercial loss as a result, there may now be a route to substantial compensation.
“Burnley‘s argument appears to have been that Everton‘s PSR breach gave them a sporting and financial advantage in a season where relegation margins were extremely tight.
“If that link is accepted, the consequences are potentially very serious for clubs, because the cost of a breach may go far beyond a points deduction or regulatory fine.”
The ruling could have implications for Chelsea, who were not given a points deduction but were fined £10m after admitting making £47m in secret payments to unregistered agents and third parties over transfers between 2011 and 2018.
Elsewhere, clubs could seek compensation if Manchester City are found guilty of the 115 charges related to alleged financial rule breaches between 2009 and 2018. City deny all of the charges.
Other Premier League clubs could argue their chances of success in the Premier League were affected by the rule breaches.
“It raises the stakes for clubs under investigation,” Levinson said. “PSR compliance is no longer just a regulatory risk and it may become a direct litigation risk.”
