On January 9, 2026, the College Sports Commission (CSC) issued a notice to 20 NCAA Division I schools expressing concerns about third-party NIL (name, image, and likeness) deals being presented to football student-athletes that may violate rules from the House settlement. These deals seek to induce athletes to transfer to or remain at particular schools, and any school with a strong athletic program should be prepared to receive a similar notice in the coming weeks.
All third-party NIL contracts valued at $600 or more must be reported to NIL Go within five days of execution, with exceptions allowing up to 14 days for high-school athletes enrolling in college and incoming Division I transfer student-athletes. Contracts between student-athletes and multimedia rights (MMR) partners must be reported regardless of how the partner plans to fund the NIL. There are also activation requirements that obligate both parties.
The CSC stated that it is progressing with investigations into unreported third-party NIL deals, with some schools expected to be contacted shortly. The CSC will provide additional rules reminders in coming weeks and encourages reporting of potential violations through direct or anonymous channels. Barclay Damon is prepared to assist higher education institutions with navigating these rules and responding to any CSC investigation inquiries.
If you have any questions regarding the content of this alert, please contact Pei Pei Cheng de Castro, partner, at pdecastro@barclaydamon.com, or another member of the firm’s Higher Education Team or White Collar & Government Investigations Practice Area.