Gundogan has been included on the list of released players submitted to the Premier League despite ongoing talks over a new deal because his current contract expires this month.
With no decision reached by this point, the 32-year-old has to appear on the released list even if there is still a chance he could stay.
City made a belated push to keep Gundogan as he hit top form in April and May, and the German midfielder is weighing up his future while on international duty with Germany this week.
Barcelona and Arsenal are interested in signing him on a free transfer, although the chances of him staying at the Etihad have risen since a longer deal was offered.
Benjamin Mendy is another high-profile player on the list to be released.
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