Manchester City were found guilty of almost all of the charges brought against them following a four-year investigation, while the club has maintained that it will appeal the findings.
Possible sanctions could include a points deduction, fines, expulsion from the Premier League and other sporting penalties.
Bernstein, who previously served as City's chairman, believes a financial penalty on its own would not have enough impact.
“I would first of all say that financial penalties will not be enough,” Bernstein told talkSPORT.
“We're talking about a club with limitless pockets – money doesn't mean very much as we saw in the last transfer window.”
Bernstein argued that even a substantial fine would not necessarily provide a meaningful sporting consequence.
“Whether it's a fine of £100million, £200m, that would not be sufficient,” he said.
Instead, Bernstein believes any punishment should affect City's league position.
“Unfortunately – I say all of these things with great sorrow, I really do, as a fan – I think there has to be something that will affect their league status,” he said.
Bernstein then offered his own calculation for the size of a points deduction that he believes would be required to make relegation unavoidable if a sanction were imposed early in the season.
“And if it was a points deduction, it depends on timing,” he explained.
“If it was today, with the season just a few games in, and the points deduction had to be something that was terminal as far as their Premier League status was concerned, I worked out you'd have to have something like 80 points deducted, which would mean the club could not recover this season and would go down.”
Bernstein stressed that the timing of any eventual punishment would be crucial.
“If this happens at the end of the season, because of the appeals and so on, it's a different kettle of fish,” he said.
“Then you may be talking about an automatic relegation – to which division I don't know. I think it does depend partly on the timing.”
Manchester City have continued to deny wrongdoing and intend to appeal the findings.
The club's chairman Khaldoon Al Mubarak has maintained that City expect to be cleared, meaning the final consequences of the case remain dependent on the appeals process and any subsequent sanctions.
Bernstein's comments therefore represent his own view of what would constitute an effective sporting punishment, rather than an announcement of any sanction against City.