Enforcing After House: The College Sports Commission and the Future of NIL Regulation

The College Sports Commission (CSC) was established to oversee compliance with and enforcement of collegiate Name, Image, and Likeness (NIL) rules following the House settlement. In this capacity, the CSC supervises two primary platforms: NIL Go, the central clearinghouse for collegiate NIL deals, and the College Athlete Payment System (CAPS), the reporting portal for schools opting into the settlement’s revenue-sharing framework. As the designated enforcement arm, the CSC is empowered to monitor post-settlement activity and ensure adherence to the new regulatory landscape.

Despite that framework, recent developments have only reinforced the perception that college athletics remains something of a “wild west.” Transfer-portal movement, tampering allegations, and reports of significant sums being offered to induce athletes to change schools continue to dominate headlines. Against that backdrop, on January 9, 2026, the CSC issued a letter to member institutions warning of its “serious concerns” regarding NIL and revenue-sharing arrangements reportedly being offered to student-athletes, as well as the potential consequences for the parties involved. The CSC cautioned that “making promises of third-party NIL money now and figuring out how to honor those promises later leaves student-athletes vulnerable to deals not being cleared... and eligibility being placed at risk.”

Key Reporting Requirements

The letter served as a reminder of current compliance mandates:

• Reporting Threshold - All third-party NIL agreements valued at $600 or more must be reported to NIL Go within five days of execution.
• MMR Partnerships - A contract between a student-athlete and a school’s multimedia rights (MMR) partner “is an NIL contract and must be reported,” even where the MMR partner intends to locate sponsors later to fund or activate the deal.
• Disclosure Labeling - If an entity is compensating a student-athlete for the use of their NIL, the agreement must be disclosed regardless of how it is labeled.
• Direct Activation - NIL agreements with an associated entity must include direct activation of the student-athlete’s NIL rights; arrangements in which an MMR partner pays an athlete without identifying who will ultimately use the NIL are likely non-compliant.

Enforcement and the Participation Agreement

In addition, the CSC warned that investigations into unreported third-party NIL agreements are already underway and that certain institutions should expect to hear from the commission. While these statements signal an intent to enforce the rules, significant questions remain about the CSC’s practical ability to do so.

Those concerns are intertwined with the University Participation Agreement, which is required for schools seeking to opt into and be bound by the post-settlement enforcement structure. On January 14, 2026, the presidents of the University of Arizona, the University of Georgia, Virginia Tech, and the University of Washington issued a joint statement urging institutions to support and execute the University Participation Agreement. Acknowledging that the agreement is not without flaws, the statement nonetheless concluded that it “provides a viable mechanism to turn the [House] settlement from principle into practice and represents a meaningful step forward that the higher education community can collectively embrace.”

Looking Ahead

Whether that optimism proves warranted remains to be seen. Any meaningful enforcement action by the CSC is likely to be met with resistance and almost certainly litigation. The central question is not whether rules exist, but whether the NCAA and the CSC can impose and sustain penalties in an environment defined by state NIL laws, antitrust scrutiny, and ongoing judicial oversight.

With federal legislation such as the SCORE Act stalled and collective bargaining gaining little traction, many of these disputes may ultimately be resolved in federal courts rather than conference offices. In the meantime, institutions would be well-served to prepare for multiple potential outcomes. This includes operating within the evolving rules while remaining competitive, understanding the risks associated with aggressive NIL strategies, and ensuring that internal processes align with current reporting and disclosure requirements.