My understanding is that penalties can be avoided if club can demonstrate administration is directly linked to the pandemic.
Back in October '21 I went to the 'Fan Forum' at the Training Centre and Vaughan mentioned in the Q&A that the business was on to break even the year COVID hit. There's no detail around it nor was he asked to substantiate on it during the evening.
There was (another) hefty loss that year in the accounts.
It would be interesting to know whether by breakeven he meant not making a loss that year, or that part way through the year they were on track to be cashflow neutral/positive to have stemmed the losses and go onto the next year in a good place.
If the latter, then presumably it's demonstratable the impact that COVID had - especially when you consider a home SF for the Prem and Final at HQ (Not sure how income works for Clubs on that - do they get a top-up payment from ticket sales/tv coverage?).