Playing a game right now... 14 minutes in, the CPU has 2 fouls already.
Some non-editing things that help create fouls: 1. Raise USER speed and accel sliders slightly higher than CPU sliders. The game reads that the CPU can't quite catch you, and will then do desperate things like recklessly slide tackle, or grab and pull you down and foul you from behind; 2. The default line sliders create too much open space. Tweak line sliders to bung up the midfield with bodies; the more bodies, the more chance of player interaction leading to fouls. My current line sliders: USER 0h 20l 25w; CPU 100h 20l 40w
EDIT:
-15:32, another CPU foul.
-17:14, another CPU foul.
-22:24, CPU foul and yellow card. I'm playing 20 minute halfs. So that's 5 CPU fouls and 1 card, and I still have 30 minutes of real-time football to play. Typically though the CPU settles down as the game goes on, becomes less aggressive.
-24:52, another CPU foul and yellow. That's 6 fouls and 2 cards.
-26:18, CPU foul, second yellow, and red card.
-32:27, another CPU foul. That's 8 fouls, 3 yellows and 1 red. But you see it's now slowing down some, that was 8 minutes since the last foul.
-36:23, CPU foul and yellow card.
-38:11, CPU foul, second yellow, and red card.
That's 10 fouls, 5 yellows and 2 red cards, and it's not half time yet. So edits and sliders do work. Is it ideal? That's the individual question. It's ideal for me because I enjoy being able to edit the game and produce game-fix results like this. For people who are looking for EA to fix the various game issues, or who play career mode and can't edit players without ruining career mode, obviously not ideal for them.