The NCAA’s June 13 release of the Implementation Guidance Q&A for the House settlement has provided long-awaited clarity for institutions navigating the complex, multi-billion-dollar legal deal that’s reshaping the future of college sports. While the settlement itself made headlines when it was approved June 6, the new 36 page document reveals several key rules, exceptions, and enforcement mechanisms that were previously unclear.
Inside the Fine Print: Surprising Details from the NCAA’s Latest Q&A
The guidance, prepared jointly by the NCAA and the five defendant conferences (ACC, Big Ten, Big 12, Pac-12, and SEC) answers critical questions for compliance officers, athletic directors, and athletes alike, especially those in schools not originally part of the lawsuit.
Opt-In Rules and a Surprising All-or-Nothing Clause
Perhaps the most striking revelation in the updated Q&A is that schools cannot “partially” opt into the settlement. Any Division I school choosing to provide additional benefits or direct NIL payments to athletes beyond those allowed before October 7, 2024,must opt in entirely and apply the rules across all NCAA-sponsored sports at that school. This includes adhering to roster limits, new enforcement guidelines, and benefits caps
In other words, there’s no cherry-picking by sport. This could be a significant deterrent for smaller programs hoping to boost recruiting in football or men’s basketball without taking on the administrative and financial burden in Olympic sports.
Multidivisional institutions (e.g., a Division II school with a Division I hockey program) can opt in for just their D-I programs. However, even then, the decision applies to all D-I sports, not selectively
$20.5 Million Cap and How It’s Calculated
The document also introduces the long-speculated “benefits cap”, a dollar limit on the total value of direct payments and benefits a participating school can provide to student-athletes in a year. For 2025–26, that number is $20.5 million, calculated based on revenues reported in eight key categories (e.g., ticket sales, bowl distributions, sponsorships) from the five major conferences and Notre Dame
Notably, the first $2.5 million in Alston awards and new incremental scholarships count against the cap, but anything beyond that threshold in either category does not. This creates an unusual incentive structure where larger schools may freely exceed old scholarship limits without cap penalties, provided they clear the $2.5 million line
This new approach effectively eliminates financial aid limits in the NCAA Manual, replacing them with school-wide caps and tracking responsibilities which is a significant departure from decades of NCAA scholarship rules.
Roster Limits Introduced — With a Twist
Another major component is the mandatory roster limits for participating schools, a rule that was largely overlooked in early discussions but now appears central to the NCAA’s compliance framework.
For example, football rosters at participating institutions will be capped at 105 players, though exemptions exist for so-called “Designated Student-Athletes” — players who would have been cut due to the new cap but had previously been on squad lists or recruited with a reasonable expectation of inclusion
These Designated Student-Athletes don’t count against the roster limit but must be declared by July 6, 2025. Schools that don’t opt in for 2025–26 lose the ability to name such athletes in the future, effectively locking them out of an important transitional benefit.
Further, replacements on submitted rosters are extremely limited. A school cannot replace a player who gets injured after the roster deadline, even in-season, unless the injury occurs before the first game that counts toward postseason qualification
This creates potential risk for schools trying to maintain depth in long seasons like baseball, football, or basketball.
NIL Reporting and Oversight Tightens
The new NIL Go platform, developed with Deloitte, is set to become the central reporting system for all third-party NIL deals over $600. Every Division I student-athlete — regardless of whether their school opts into the settlement — must disclose such deals
For schools that do opt in, a second platform, CAPS, will track all direct payments, including NIL contracts, scholarships, and additional benefits that count against the benefits cap. This includes any agreements with institutional multimedia rights holders acting as pass-through entities, a move likely designed to prevent creative accounting workarounds
Notably, schools must upload every payment agreement to CAPS, with attestation forms signed by the president, AD, and head coach submitted annually by September 1. This level of documentation and transparency far exceeds any past NCAA oversight.
Institutional Discretion — With Strings Attached
Institutions have broad discretion to structure NIL contracts, include academic or behavioral clauses (language such as “compliance with written institutional policies” would reasonably include codes of conduct, behavioral standards, or disciplinary criteria that schools already enforce), and negotiate terms with athletes. However, they must be careful not to exceed caps or guarantee payments not entered into CAPS. Any deal must be fully executed and tracked to remain compliant.
If a player transfers mid-contract, buyout payments (e.g., to recoup a signing bonus) count against the receiving school’s cap, a noteworthy detail for compliance officers managing multiyear NIL deals
Another surprise: former student-athletes can be paid for NIL activities post-eligibility, but schools cannot defer current payments until after an athlete’s career ends. The compensation must follow the timeline in the signed agreement.
Enforcement and the College Sports Commission
Enforcement will now fall under the College Sports Commission, which holds investigatory power and will audit institutions for benefits cap compliance. Schools must give unencumbered access to third-party auditors, and violations may be subject to penalties under a new enforcement model
This marks a move toward independent oversight, a core component of the broader shift in governance as the NCAA attempts to modernize and decentralize its regulatory structures.
What’s Next for Schools?
Non-defendant schools that want to opt in must declare their intent by June 30, 2025, using links sent to their athletic directors earlier this year. They’ll be bound by all provisions for the 2025–26 academic year if they choose to join.
The bottom line? The new Q&A confirms that this isn’t a “pay-if-you-want” model, it’s a binary choice between the old model and a new compliance-heavy framework that will fundamentally alter recruiting, scholarship management, and budgeting at every level of Division I athletics.
For many schools, especially outside the Power Five, the decision over the next two weeks may have long-term consequences for how they compete, operate, and build rosters.
For further reading, view the full House Settlement Implementation Q&A or visit CollegeAthleteCompensation.com for student-athlete resources.
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