The English Football League has said the punishment will apply this season if the 2013 FA Cup winners avoid finishing in the bottom three of the second tier of English football.
Wigan, placed in administration on July 1, are 16th in the Championship, six points above the relegation zone with five games left to play.
Local MP Lisa Nandy has called for a full inquiry into the circumstances surrounding the placing of the club in administration and claims it is the victim of a “major global scandal”.
Wigan were put in administration on July 1, four weeks after they were sold from one Hong Kong-based company to another, both of which were until recently majority-owned by professional poker player Dr Choi Chiu Fai Stanley.
“The only grounds we have for this (appeal) is ‘force majeure’,” said administrator Gerald Krasner, in comments reported by BBC Sport.
“This situation was totally unexpected, so we believe in the case of Wigan this case applies.”
Force majeure refers to unexpected circumstances such as wars and earthquakes.
Krasner said 75 support staff at the club were made redundant on Monday and that senior club executives had agreed to work for nothing until the situation was resolved.
He said the first-team squad were receiving 20 percent of their salaries.
Krasner said he had sent out 50 non-disclosure agreements, indicating a high level of interest in buying the club.
Ian Lenagan, the owner of rugby league club Wigan Warriors, is now leading a bid to buy the football club.
“We strongly believe that Wigan Athletic is better being locally owned… sustainability and ownership of the stadium is equally important to both clubs,” a statement read.
“Wigan Warriors and Wigan Athletic are both local sporting institutions and it is our belief that this is a unique opportunity here to bring the ownership of these two great clubs together under one roof, each operating independently as before, but under a Wigan Sporting Partnership banner,” it added.
Adding to the nebulous situation surrounding the club’s Hong Kong ownership, British media reports claim English Football League chairman Rick Parry was secretly filmed telling a fan that Wigan’s dire financial problems were connected to “a bet in the Philippines on them being relegated”.
Download our app and read this and other great stories on the move. Available for Android and iOS.