On December 19, 2025, the NCAA released the first batch of data from its new NIL disclosure platform, CSC NIL Go. The numbers were striking?but not for the reason the NCAA hoped. Schools reported just $87.5 million in name, image and likeness deals for the 2024-2025 academic year. Industry analysts estimate the actual market is closer to $500 million. That means 83% of NIL activity is either going unreported or being reported incorrectly.
This is not a rounding error. This is a compliance crisis. And with the House v. NCAA settlement set to bring revenue-sharing caps and stricter enforcement in 2025-2026, the schools and collectives failing to report now are setting themselves up for serious consequences later.
What CSC NIL Go Is Supposed to Do
The NCAA launched CSC NIL Go in partnership with CSC, a corporate compliance provider, to create a centralized database of NIL transactions. The system is designed to track deals across all NCAA sports, giving the organization visibility into who is earning what, from whom and whether those deals comply with NCAA rules.
Schools are required to report NIL deals athletes disclose to them. Athletes are supposed to disclose deals within a set timeframe, usually 30 days of signing. Collectives?the donor-funded organizations that broker many NIL deals?are expected to work with schools to ensure transactions are logged.
The goal is transparency. The NCAA wants to prevent pay-for-play disguised as NIL, ensure athletes are not being exploited by predatory agreements and build a data foundation for future NIL regulations. In theory, CSC NIL Go should provide a real-time snapshot of the NIL economy.
In practice, it shows less than one-fifth of the market.
The Numbers Do Not Add Up
Let us break down what was reported versus what the industry knows exists. CSC NIL Go logged $87.5 million for the 2024-2025 academic year. That covers deals from July 2024 through June 2025, with data reported through mid-December.
Meanwhile, industry tracker Opendorse estimated in 2024 that college NIL deals totaled $1.67 billion across all athletes since NIL rules changed in 2021. Basketball alone, according to On3's NIL valuation tool, represents a $500 million annual market. If CSC NIL Go captured even half of the basketball market, it would show $250 million, not $87.5 million total across all sports.
The NCAA's own estimates, shared in settlement discussions for House v. NCAA, projected schools would pay out $20.5 million annually per institution once revenue-sharing begins. That is just direct school payments, not collective deals. If even 100 schools participate in revenue-sharing, that is $2 billion annually?twenty-three times what CSC NIL Go currently shows.
The gap is not explained by timing. The system has been live since fall 2024. The gap is not explained by small deals falling through the cracks. Major collective transactions involving six-figure payouts to star athletes are missing. The gap is explained by non-compliance.
Why Schools Are Not Reporting
There are three main reasons schools and athletes are not fully reporting NIL activity and none of them are good.
First, athletes are not disclosing deals. Many athletes do not understand they are required to report NIL agreements to their school's compliance office. Some fear reporting will trigger tax implications or jeopardize future deals. Others sign deals through intermediaries and assume someone else handles reporting. The result is that schools cannot report what they do not know about.
Second, collectives are operating in a gray zone. Some collectives structure deals as independent contractor agreements, sponsor appearances, or content creation gigs?categories they argue are private business transactions, not NIL deals subject to NCAA reporting. Others simply do not share deal information with schools, viewing themselves as separate entities not bound by NCAA rules.
Third, schools lack enforcement mechanisms. What happens if an athlete does not report a deal? In most cases, nothing. Schools can threaten eligibility suspensions, but that is a nuclear option they rarely use. Compliance offices are understaffed and monitoring hundreds of athletes across dozens of sports is logistically difficult without cooperation from athletes and collectives.
The incentive structure is broken. Athletes benefit from keeping deals private. Collectives benefit from operating without oversight. Schools benefit from plausible deniability. The only party that benefits from full disclosure is the NCAA?and it has limited tools to force compliance.
The House Settlement Changes Everything
The House v. NCAA antitrust settlement, pending final approval in April 2025, will fundamentally alter NIL economics. The settlement allows schools to directly pay athletes up to $20.5 million annually starting in the 2025-2026 academic year. That cap is indexed to broadcast revenue and will rise over time.
Here is the critical part: schools that exceed the cap face severe penalties, including postseason bans, scholarship reductions and financial sanctions. To enforce the cap, the NCAA will audit school payments and third-party NIL deals. If a collective is paying athletes on a school's behalf, those payments count against the cap.
That means the NIL deals currently going unreported in CSC NIL Go will matter a great deal once the settlement takes effect. A school claiming it is paying $15 million under the cap while its collective funnels another $10 million in undisclosed NIL deals is violating the settlement. The NCAA will have legal authority to investigate and schools found in violation will face consequences that dwarf previous compliance penalties.
The 83% of unreported NIL activity is not just a data gap. It is evidence of systemic non-compliance that will become a legal liability the moment the House settlement is finalized.
What Enforcement Will Look Like
The NCAA has historically struggled with enforcement. It lacks subpoena power and its investigative resources are limited. But the House settlement includes provisions that change the enforcement equation.
Under the settlement, schools agree to regular financial audits conducted by third-party firms. Those audits will review direct payments to athletes, collective transactions and NIL agreements. Schools must provide documentation proving they are under the $20.5 million cap. If the audit finds unreported deals, the school is in breach.
Collectives will face new scrutiny. The settlement establishes rules distinguishing legitimate NIL deals from pay-for-play disguised as endorsements. A collective paying an athlete $100,000 for a single social media post will need to justify that valuation. If the deal has no legitimate commercial purpose and exists solely to funnel money to an athlete, it counts as compensation under the cap.
The enforcement mechanism is financial. Schools caught exceeding the cap forfeit revenue-sharing privileges, face postseason bans and may be required to repay improperly distributed funds. For a major program, losing postseason eligibility costs millions in ticket sales, sponsorships and broadcast revenue. That is a penalty schools will take seriously.
Athletes who fail to disclose deals may face eligibility consequences. If a school discovers an athlete received undisclosed compensation, the school must self-report to avoid being penalized for the athlete's non-compliance. That creates an incentive for schools to enforce disclosure requirements aggressively.
The Compliance Gap Is Not Sustainable
Right now, NIL operates on an honor system with no real consequences for non-disclosure. That system produced an 83% reporting gap. Once the House settlement takes effect, the honor system ends.
Schools will need to know every dollar flowing to athletes, whether from the school, a collective, or an independent sponsor. They will need documentation proving every NIL deal is legitimate and fairly valued. They will need audit trails showing they are under the revenue-sharing cap. Schools that cannot provide that documentation will face penalties designed to hurt.
Athletes will need to disclose every deal, every payment, every quid-pro-quo arrangement. The days of signing a six-figure collective agreement and not telling the compliance office are over. Undisclosed income is a liability, not just for the athlete but for the school.
Collectives will need to operate transparently or risk triggering investigations that could cost schools postseason eligibility. The gray zone they currently occupy?independent but school-adjacent, paying athletes but not technically employing them?will not survive the House settlement's enforcement regime.
The 83% reporting gap represents deals that will need to be disclosed, valued and documented within the next six months. That is a monumental compliance lift for schools already struggling to track NIL activity. Some will not make it.
Who Wins and Who Loses
Schools with strong compliance infrastructure and transparent collective relationships will benefit. They can report NIL activity accurately, stay under the cap and avoid penalties. Schools like Ohio State, which has centralized NIL deal management and required athlete disclosure since 2021, are well-positioned.
Schools with opaque collective relationships and weak reporting systems will struggle. If they do not know what their collectives are paying athletes, they cannot prove they are under the cap. If they cannot prove compliance, they face audits, investigations and penalties. Smaller programs without dedicated NIL compliance staff are particularly vulnerable.
Athletes at well-managed programs will have clarity. They will know what they can earn, what they must disclose and what happens if they do not comply. Athletes at poorly managed programs will face uncertainty and potential eligibility issues if undisclosed deals surface during audits.
Collectives that adapt to the new rules will continue operating. Those that rely on opacity and lax enforcement will either reform or be forced out. The House settlement does not ban collectives, but it removes the regulatory vacuum they have exploited since 2021.
What Happens Next
The House settlement awaits final approval in April 2025. If approved, revenue-sharing begins in the 2025-2026 academic year, which starts in July 2025. That gives schools roughly six months to get their NIL compliance houses in order.
Expect a wave of deal disclosures as athletes and collectives scramble to get on the record before audits begin. Expect schools to implement stricter reporting requirements, backed by eligibility penalties for non-compliance. Expect some collectives to dissolve rather than operate under increased scrutiny.
The NCAA will release updated CSC NIL Go data quarterly. Watch the numbers. If the next report still shows $87.5 million while the market operates at $500 million, that is evidence schools are not preparing for the settlement. If the numbers jump significantly, that is evidence of a compliance scramble.
For athletes, this is a moment to disclose everything. Work with your school's compliance office. Document every deal. Understand that undisclosed income is not a secret?it is a liability waiting to surface in an audit.
For schools, this is a moment to enforce. Build systems to track NIL deals. Require athlete disclosure. Audit collective payments. The penalty for non-compliance is not a warning letter anymore. It is postseason bans and revenue forfeiture.
The Reality Check
The 83% NIL reporting gap is not sustainable once the House settlement takes effect. Schools cannot comply with a revenue-sharing cap if they do not know what athletes are earning. Athletes cannot avoid eligibility issues if they do not disclose deals. Collectives cannot operate in secrecy if their payments count against school caps.
The current system worked when NIL was unregulated and enforcement was minimal. That era is ending. The House settlement brings caps, audits and penalties. Schools that treat NIL compliance as optional are setting themselves up for catastrophic consequences.
The question is not whether the 83% gap will close. The question is whether it closes proactively through voluntary compliance or reactively through enforcement actions and penalties. One path is orderly. The other is chaos. We will know which path the industry chose by the end of 2026.
