NIL Compliance Tightens: What the NCAA's New Rules Mean for Institutions and Sponsors

Introduction

On October 28, 2025, the NCAA Division I Board of Directors adopted amendments to the Name, Image, and Likeness (NIL) bylaws established under the House v. NCAA settlement (the House Settlement). The amendments expand NIL reporting obligations for both student-athletes and institutions and introduce consequences for noncompliance. Earlier in October, the College Sports Commission (CSC)—created pursuant to the House Settlement to oversee NIL compliance and enforcement—launched a confidential NIL tip line, enabling the anonymous reporting of potential violations. Together with the CSC's recent appointment of former federal prosecutor Katie Medearis as Deputy General Counsel, these actions reflect a coordinated effort by the NCAA and CSC to strengthen NIL oversight and enforcement of NCAA bylaws.

The House V. NCAA Settlement and the Creation of the CSC

As discussed in Steptoe’s prior NIL update, House v. NCAA, Case No. 4:20-cv-03919-CW (N.D. Cal.), was a consolidated class action brought by current and former student-athletes against the NCAA and the five major athletic conferences—the ACC, Big Ten, Big 12, Pac-12, and SEC (collectively, the "Conferences"). On June 6, 2025, Judge Claudia Wilken of the US District Court for the Northern District of California approved the landmark settlement, which, in part, permits institutions to share certain revenues directly with their student-athletes.^1,2

Following Judge Wilken's approval of the House Settlement on June 6, 2025, the NCAA and the Conferences appointed the CSC to be an independent clearinghouse responsible for collecting and reporting Division I NIL activity, monitoring compliance, and enforcing the NIL-related bylaws adopted under the Settlement. Under those June 2025 bylaws, Division I student-athletes are required to report all non-institutional NIL contracts valued at more than $600 to the CSC within five business days of execution.³

October 2025 NCAA and CCS Actions Strengthen NIL Compliance and Enforcement

On October 8, 2025, the CSC announced the launch of a confidential NIL reporting tip line, developed in partnership with RealResponse—a provider of secure, two-way communication platforms for collegiate athletics—to encourage individuals to anonymously report potential NIL violations.⁴According to RealResponse Founder and CEO David Chadwick, the tip line was established to "ensure there is a safe, trusted channel to report potential rules violations" and helps the CSC "protect fairness, maintain a level playing field, and give every stakeholder the confidence to speak up when rules are at risk of being broken." CSC CEO Bryan Seeley emphasized that the organization "is committed to robust enforcement of the rules while protecting those who come forward with useful information."

Shortly after the tip line's implementation, on October 28, 2025, the NCAA Division I Board of Directors adopted a series of amendments expanding NIL reporting and enforcement obligations. These changes broaden the House Settlement framework beyond student-athletes at Conference institutions and underscore the NCAA's ongoing commitment to accountability and transparency in NIL activities.

Expanded Reporting Obligations

The June 6, 2025 bylaws required student-athletes to report certain third-party NIL agreements within five business days of execution As amended, the bylaws now explicitly impose this reporting obligation on all Division I student-athletes—not just those at institutions affiliated with the Conferences named in the House litigation.⁵In addition, new and specific reporting obligations apply to high-school, junior-college, and prospective transfer student-athletes.⁶These individuals must be prepared to disclose all third-party NIL agreements valued at $600 or more to the CSC within 14 days of enrollment at a Division I institution, or prior to their first athletic event, whichever occurs later. Notably, this obligation extends to NIL agreements executed before enrollment—potentially years prior.

Consequences for Failure to Report

The amended bylaws also authorize the CSC to impose disciplinary action when a Division I student-athlete fails to report qualifying NIL contracts within the five-day deadline, including declaring the athlete ineligible for practice and competition.⁷Institutions now bear direct oversight responsibilities as well. If an institution discovers that a payment or contract involving one of its student-athletes has not been reported, it must conduct a review within two business days to determine whether a violation occurred and, if so, notify the CSC.⁸ If the athlete still fails to report the NIL arrangement by the end of that period, the CSC is required to immediately render the athlete ineligible until the deal is appropriately reported.

Leadership Announcement 

On October 29, 2025, the CSC announced the appointment of Katie Medearis as its head of investigations and deputy general counsel. Medearis, a former Criminal Division chief in the US Attorney’s Office for the Western District of Virginia and associate Deputy Attorney General at the US Department of Justice, will oversee the CSC's investigative and enforcement operations, and ensure rigorous oversight of compliance with the House Settlement, including revenue-sharing rules and NIL disclosures. Seeley described Medearis's appointment as "instrumental" in building a fair and accountable enforcement framework for college sports.⁹

Enforcement Outlook

The NCAA's October 2025 amendments—together with the CSC's strengthened enforcement infrastructure—reflect a coordinated effort to adhere to the House Settlement and preserve the integrity of the NIL regulatory landscape. The expanded bylaws broaden the scope of reporting obligations, reaching beyond Division I student-athletes to high-school prospects, junior-college transfers, and other pre-enrollment participants, while heightening institutional accountability for unreported NIL activity.

These developments signal a pivotal shift toward proactive, data-driven NIL oversight centralized under the CSC's authority. Institutions should assess their compliance frameworks to avoid potential penalties under the amended bylaws, and may consider taking the following actions:

• Review and Update NIL Disclosure Protocols. Ensure existing NIL reporting systems capture all qualifying agreements—including those executed by incoming transfers, high-school recruits, and other pre-enrollment athletes—within the applicable reporting periods.
• Strengthen Education and Onboarding. Update training and orientation resources for student-athletes, coaches, and staff to include the new reporting requirements and timelines. Early education is especially critical for incoming and transfer athletes, who may be unaware of the pre-enrollment disclosure obligations and associated eligibility risks.
• Establish Compliance Teams. Because institutions must conduct internal reviews within two business days of discovering potential noncompliance, schools should identify a standing compliance response team—including counsel—to investigate and address violations swiftly. These teams are especially critical given the CSC’s launch of a confidential tip line, which allows athletes, staff, and third parties to report potential violations directly, increasing the likelihood that issues will arise unexpectedly and demand an immediate institutional response.
• Audit Third-Party Relationships. Given the CSC’s broadened enforcement powers, institutions may consider conducting periodic audits of student-athlete relationships with agencies and corporate sponsors to confirm compliance with NCAA and institutional policies. NCAA Division I institutions should also develop processes for verifying NIL disclosures involving recruits and transfer students, including coordination with non-member institutions to ensure pre-enrollment NIL agreements are accurately captured. Documenting outreach and review processes will help demonstrate good-faith oversight if a potential violation arises.
• Proactively Engage Counsel. Institutions and those working with student-athletes, including third-party sponsors and agencies, should seek guidance from experienced counsel to design, refine, or review NIL compliance systems. Counsel can assist in mitigating risk exposure, ensuring procedural compliance, and preserving athlete eligibility in the event of a CSC inquiry.

To stay ahead of the rapidly evolving NIL regulatory landscape, institutions, conferences, collectives, and third-party sponsors should act now to evaluate and strengthen their compliance frameworks. The NCAA's expanded bylaws—combined with the CSC's enhanced enforcement authority—introduce new risks and heightened expectations for transparency, timely reporting, and institutional accountability.

Steptoe's multidisciplinary team is uniquely positioned to advise on NIL disclosure protocols, CSC enforcement procedures, and risk mitigation strategies tailored to your organization's structure and exposure. Whether navigating pre-enrollment disclosures, responding to tip line inquiries, or auditing third-party relationships, we are ready to help you stay compliant—and competitive.

¹  Second Amended Injunctive Relief Settlement, Art. 3 Sec. 1(a).

²  Case No. 4:20-CV-03919 Document 980-2 filed June 6, 2025.

³  NCAA, Proposed Rule Changes Contingent on House Settlement Final Approval, NCAA.org, arts. 22.2.2 & 22.2.2.2 (made effective July 1, 2025), https://www.ncaa.org/sports/2025/4/6/proposed-rule-changes-contingent-on-house-settlement-final-approval.aspx.

⁴  College Sports Commission, College Sports Commission Strengthens Enforcement Efforts by Launching Anonymous Reporting Tipline (Oct. 8, 2025), available at https://www.collegesportscommission.org/news.

⁵  NCAA, NCAA Division I Manual, art. 22.2.2 (effective July 1, 2025, as amended October 28, 2025), https://web3.ncaa.org/lsdbi/search/bylawView?id=145338 ("A student-athlete (including a student-athlete who attends an institution that is not a member of a defendant conference in the House settlement or does not provide additional benefits contemplated by the settlement) shall report all noninstitutional name, image and likeness contracts or payment terms, including those involving associated entities or individuals, with a total value of $600 or more to the designated name, image and likeness clearinghouse for review.") (emphasis added).

⁶  College Sports Commission, Rules Resulting from House Settlement Finalized and Enforced by College Sports Commission (Oct. 30, 2025), available at https://www.collegesportscommission.org/news.

⁷  NCAA, NCAA Division I Manual, art. 22.2.2.2 (effective July 1, 2025, amended October 28, 2025), https://web3.ncaa.org/lsdbi/search/bylawView?id=145367#result.

⁸  NCAA, NCAA Division I Manual, art. 22.2.2.2.1 (adopted October 28, 2025), https://web3.ncaa.org/lsdbi/search/bylawView?id=145367#result.

⁹  Ralph Russo, College Sports Commission Hires Former Federal Prosecutor as Head of Enforcement, The Athletic (Oct. 29, 2025), https://www.nytimes.com/athletic/6759995/2025/10/29/college-sports-commission-katie-medearis/.