However, none will face disciplinary proceedings because they have all left the police service.
The Independent Office for Police Conduct (IOPC) said it had upheld complaints against some former South Yorkshire police officers, and some who were serving at the West Midlands force, for misconduct during its original investigation into the disaster.
In letters sent to bereaved family members this week, the IOPC deputy director general, Kathie Cashell, said almost 100 people had made a total of 354 complaints of misconduct, the investigations into some of which were still being finalised.
"However, to date just over half of complainants have had at least one complaint upheld, or in our opinion there would have been a case to answer for misconduct for one or more officers, had they remained serving," she wrote. "I understand that for many it will be disappointing that this number is not higher."
On 15 April 1989, 97 men, women and children, aged from 10 to 67, were killed in the lethal crush at Sheffield Wednesday's Hillsborough stadium at an FA Cup semi-final between Liverpool and Nottingham Forest.
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