On June 23, the College Sports Commission (CSC) issued a memorandum to all Division I Institutions and Conferences updating its NIL deal review, enforcement policy, and agent agreements.

Updated Range of Compensation Analysis

Beginning July 1, 2026, the CSC is significantly expanding the thresholds that determine when NIL deals are subject to range of compensation (RoC) review. Under the updated policy, deals valued between $600 and $15,000 will generally avoid RoC scrutiny unless a student-athlete exceeds $50,000 in total “associated” deals during a single academic year.

This marks a notable shift from the prior framework, which had been in place since April 2026. Under that earlier policy, only deals up to $2,500 were exempt from review — and only until the student-athlete reached $15,000 in associated deals for the year. The new policy substantially raises both the per-deal and aggregate thresholds, giving student-athletes and partnering entities greater flexibility to structure mid-range NIL agreements without triggering immediate regulatory review:

When reviewing NIL deals, the CSC focuses on whether the compensation aligns with what similarly situated individuals receive — a concept it refers to as the RoC. The CSC evaluates each deal against three pillars: the institution’s market reach, the student-athlete’s social media presence, and the athlete’s on-field performance. If the compensation falls within the RoC for at least one of these pillars, the deal is generally deemed proportionate and compliant. If a deal does not align with the RoC under any of these benchmarks, the analysis does not automatically end there; instead, the CSC applies a more holistic review, considering the totality of the circumstances to determine whether the compensation can still be justified as consistent with what similarly situated individuals receive.

Within the policy change, the CSC reiterates that all associated deals, regardless of dollar amount, still must be “for a valid business purpose related to the promotion or endorsement of goods or services provided to the general public for profit,” pursuant to NCAA Bylaw 22.1.3.

According to the CSC, the updated policy allows for continued focus on higher-dollar deals.

Shift From Confidence Intervals to Prediction Intervals

The CSC has also announced a key methodological update to how it evaluates NIL compensation. Beginning in early July 2026, the RoC model will shift from using confidence intervals to prediction intervals. This shift is intended to better reflect real-world market variability and incorporate updated data.

Under this revised approach, prediction intervals will account for the natural range in compensation among similarly situated student-athletes. According to the CSC, this ostensibly makes the model more flexible and better suited to assessing whether a single deal falls within the bounds of what comparable athletes are actually receiving in the market.

Recognizing that this transition could affect pending deals, the CSC has indicated it will take a measured approach in the interim. Specifically, it plans to temporarily hold off on acting against deals that exceed the current RoC upper limit but are close enough that they could fall within range under the updated model.

Agent Agreements

The recent guidance highlights a growing concern in the NIL space: the use of so-called “consulting” agreements as a workaround for funneling compensation. In several reported instances, player agents — or other individuals acting on behalf of student-athletes — are entering into agreements with schools that are structured as NIL consulting arrangements.

According to the CSC, these agreements raise red flags as they may be used to indirectly route payments from schools to student-athletes or to offset traditional agent fees that would otherwise be paid by the athlete. In practice, this can blur the lines between legitimate NIL compensation and impermissible pay-for-play or recruiting inducements, creating compliance risks for all parties involved.

To tighten enforcement, upon learning of an institution-agent financial agreement, the CSC will review for violations of NCAA bylaws regardless of whether that agent is being paid by a student-athlete to represent the student. The CSC also asks that those with information about potential violations report it directly to the CSC.