The Independent Office for Police Conduct (IOPC) said three West Mercia Police officers were interviewed twice under criminal caution and served with gross misconduct notices following Mr Atkinson’s death in August 2016.
The retired 48-year-old, who also played for Ipswich and Sheffield Wednesday, died after police used a Taser during an incident in the Trench area of Telford.
At the request of the CPS, an expert report from a further pathologist is being awaited to assist prosecutors with their consideration, an IOPC spokesman said.
The West Mercia force have also been sent the IOPC investigation report to determine whether or not disciplinary proceedings should follow.
The watchdog’s regional director, Derrick Campbell, said: “On the basis of the evidence gathered I have decided to refer the matter to the Crown Prosecution Service to consider any potential criminal charges over the interaction two police officers had with Dalian Atkinson.
“This has been a lengthy and complex investigation and I am grateful for the patience shown by all concerned.
“We have kept West Mercia Police, Dalian’s family, and HM Coroner informed during the course of the investigation.”
An IOPC spokesman said the actions of the third officer have not been referred.
Relatives said Mr Atkinson was suffering a number of health issues and had a weak heart when a Taser was deployed at about 1.30am.
He went into cardiac arrest in an ambulance on his way to hospital and medics were unable to save him.
At the time, West Mercia Police said officers were called amid concerns “for the safety of an individual”.
In its statement issued today, the IOPC said its investigation gathered evidence which indicates that police contact with Mr Atkinson involved the use of a Taser, followed by a period of restraint and other uses of force.
In a statement issued by Mr Atkinson’s siblings after his death, they said: “Dalian grew to be a kind, caring and protective brother, with a lively personality: he was funny and cheeky. He always brought life and energy to family gatherings – when Dalian turned up, we knew there would be laughter and banter.”