The NIL Payment Disclosure Reference

What's public today, what's about to become public tomorrow

Payroll disclosure in college football does not run through a single channel. It runs through three, and each is on a different trajectory.

1. The private-collective vector. A 501(c)(3) NIL collective files an annual Form 990 with the IRS; the return is publicly available through ProPublica Nonprofit Explorer, IRS.gov, and third-party aggregators. Total revenue, program expenses, and (when separately reported) grants to individuals are visible on the return. Individual athlete-level payments are not itemized. LLC-structured collectives file no public financials at all. The result: aggregate 501(c)(3) collective spending is partially public with an 18-month reporting lag; individual athlete payments and all LLC-collective payments are private. The IRS Chief Counsel memorandum released in 2023 raised the risk that "pay-for-play" 501(c)(3) collectives may not qualify as tax-exempt, which has pushed a portion of the market to LLC structure, wound-down status, or university-branded successor entities such as Yea Alabama and Aggie NIL. The 990 dataset is therefore both incomplete and shrinking.

2. The House clearinghouse vector. Under the House v. NCAA settlement effective July 1, 2025, the Deloitte-administered NIL Go clearinghouse reviews every third-party NIL deal above $600 against a twelve-factor fair-market-value framework. The College Sports Commission is the settlement enforcement body; NIL Go is the review and reporting platform. As of the settlement's first year of operation, roughly 21,000 deals worth approximately $166.5M had been submitted for review (reported). Data flows through the clearinghouse at individual-athlete, individual-deal granularity. Public accessibility of that dataset is being litigated and negotiated. The 12 to 24 month window for resolution is the practitioner watch.

3. The revenue-share direct-payment vector. The approximately $20.5M per school per year revenue-share cap (year one, escalating roughly four percent annually) is paid directly by the athletic department to the athlete. Because the school is the payer, these payments flow through athletic-department accounts payable and, at public universities, potentially into the reach of state open-records law. State-by-state variance is significant. Since mid-2025, at least six states (North Carolina, South Carolina, Wisconsin, Louisiana, Colorado, Utah) have advanced or enacted statutes explicitly shielding revenue-share contracts from public disclosure, joining a prior cluster (Texas, Kentucky, Nebraska, Missouri, Connecticut) that had already exempted NIL agreements. This is a fundamentally new disclosure vector that did not exist under the pre-House collective structure.

Top P4 program NIL collectives and their filed 990 financials

Aggregate collective financials for the primary football-attributable NIL vehicle at each P4 program, ordered by conference. Where a collective is a 501(c)(3), we pull the most recent filed Form 990 revenue and expense from ProPublica Nonprofit Explorer or IRS.gov. Where the vehicle is LLC-structured, wound-down, or restructured into a university-branded successor entity, we mark the row accordingly. Multiple programs operate more than one collective; we list the primary football-attributable entity.

Form 990 data typically lags 12-18 months from calendar year-end; figures shown reflect the most recent filed 990 or reported disclosure and should be verified against ProPublica Nonprofit Explorer, the IRS Exempt Organizations database, and each entity's own filings before public deployment. LLC-structured collectives file no public financials — program-level aggregate spend for those programs is estimated by trade-press aggregation (On3, 247Sports, The Athletic, Sportico) and marked accordingly. Multiple programs operate more than one collective; this ledger lists the primary football-attributable entity. Where an entity has wound down or restructured (Classic City, 12th Man+, FUND), we mark the transition and note the successor vehicle.

The disclosed top of the athlete-level NIL market

The current On3 NIL Valuation top-of-the-board for college football, drawn from On3's public NIL rankings. As of July 1, 2026, On3 transitioned its methodology from an algorithm-based model to a deal-based valuation model that reflects current player contract value and tracks athlete compensation from schools and collectives. Rankings shift week-to-week as deals close, transfers move, and the season plays out. Quarterbacks and wide receivers dominate the top of the board; the top 25 is heavily concentrated at those two positions.

On3 NIL Valuations are estimates by On3 aggregating reported deals plus valuation methodology; they are not filed-source disclosures. Rankings shift week-to-week. The July 1, 2026 On3 transition to a deal-based valuation model brings the reported figures closer to actual contract value, but athletes and collectives remain free to withhold deal-level detail. Position rows below Rank 6 reflect the general shape of the top-30 board with valuations marked "reported est. as of publication" where On3's live figure has not been captured against a specific citation URL as of the date stamp above.

Which states require public-university disclosure, which shield it

State-by-state status of NIL and revenue-share payment disclosure obligations at public universities, as of publication. The landscape changed materially during 2024 and 2025 as state legislatures moved to shield NIL and revenue-share contracts from open-records disclosure. The regime is fluid; bills continue to advance. Reference against the current state legislative record before relying on any specific row.

State NIL legislation and open-records treatment continue to move; verify against current statute and legislative-record status before relying on any specific row. States hosting private P4 programs (Notre Dame at Indiana, Miami and Stanford as private institutions, USC at California, Vanderbilt at Tennessee, Duke and Wake Forest at North Carolina, Northwestern at Illinois, Boston College at Massachusetts) sit outside the state open-records regime as private universities. Public-records exemption legislation is being tracked live by Sportico, the Reporters Committee for Freedom of the Press, the Student Press Law Center, and the Drake Group.

NIL Go, Deloitte, and the 12-to-24-month window

What NIL Go is. Under the House v. NCAA settlement (final approval June 6, 2025; effective July 1, 2025), the College Sports Commission was established as the enforcement body for the settlement's third-party NIL oversight regime. The College Sports Commission engaged Deloitte to build and administer NIL Go, a review and reporting platform through which every third-party NIL deal above the $600 threshold is submitted for a fair-market-value determination. Deloitte's evaluation uses a twelve-factor framework: parties, deal purpose, athlete profile, market comparables, deliverables, deal term, payment structure, market rate benchmarks, deal source, athletic-department relationship, brand-fit alignment, and geography. Each deal receives a "cleared" or "not cleared" determination.

Timing and ramp. The platform went live in June 2025 ahead of the July 1 settlement effective date. Since launch, more than 21,000 deals worth approximately $166.5M in aggregate value have been submitted for review (reported). Deloitte separately disclosed at ACC spring meetings that approximately 70 percent of past booster-collective deals would have been denied under the twelve-factor framework, while approximately 90 percent of deals from public companies would have been approved. That gap is the operational content of the settlement: it shifts the market away from collective-underwritten pay-for-play and toward third-party endorsements at defensible fair-market rates.

What NIL Go sees. The platform holds individual-athlete-level data at deal granularity: contract terms, payment schedule, deliverable set, brand identity, deal length, and clearinghouse determination. Aggregate throughput numbers (deal count, aggregate value, approval rate) are being reported by Deloitte and the College Sports Commission at conference and NCAA governance meetings. Individual deal terms are not currently disclosed to the public.

Where it's headed. Three vectors will determine whether NIL Go data becomes publicly accessible over the next 12 to 24 months. (a) Litigation. Antitrust exposure of the twelve-factor framework itself is live; the National Association of College and University Attorneys and multiple state attorneys general have flagged concerns about the "reasonable range of compensation" standard. Discovery in any resulting suit could push individual-deal data into the record. (b) State legislation. Tennessee's SB 536 (May 2025) authorizes schools to directly facilitate NIL and challenges the clearinghouse's exclusive jurisdiction; other state legislatures are considering statutes that would compel disclosure of clearinghouse-reviewed deals above a threshold, or in the opposite direction, further shield them. (c) Trade-press FOIA analogs. Sportico, The Athletic, ESPN, and On3 are pursuing information requests to obtain clearinghouse metadata — deal counts, aggregate values, approval rates — even where individual deal terms remain shielded.

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