Athlete Revenue Share: Risk Management Considerations Post-House Settlement

The collegiate athletics environment is changing, and fast. With the House v. NCAA settlement paving the way for direct revenue-sharing with student-athletes, colleges and universities are facing new compliance and operational challenges under a rapidly evolving governance structure. As these changes unfold, it’s essential for internal audit and enterprise risk management (ERM) leaders to step in early, helping their institutions manage risks, monitor compliance and maintain financial integrity.

Navigating in-house athlete revenue share payments means more than just processing funds. It involves building systems that stay distinct from NIL arrangements and uphold internal controls, institutional policies and the expectations of higher education oversight. These developments present a clear opportunity to revisit and reinforce ERM and internal audit frameworks to ensure emerging risks are captured, compliance is maintained and institutional values remain central.

Institutions should also be aware of the College Sports Commission (CSC), a new oversight body established under the House settlement to help guide, regulate and eventually enforce standards for athlete compensation and compliance. While the CSC is expected to provide overarching guidance and enforcement, conferences will continue to play a critical role in implementation, coordination and interpretation — creating an overlapping structure where institutional policies must align with both regulatory and competitive frameworks.

While the CSC’s role is still taking shape, institutions should prepare for potential shifts in compliance obligations as CSC regulations diverge from or supplement NCAA guidance.

Integrating Athlete Revenue Share Into ERM Frameworks

Now is the time to embed athlete revenue share into your broader risk framework and position your institution to lead with clarity, control and confidence. These payments introduce cross-functional implications for various risk areas, making coordinated risk assessment and oversight essential.

• Compliance risks: Navigating oversight from Title IX, CSC and NCAA, meeting tax reporting requirements and maintaining financial aid eligibility.
• Operational risks: Systems and processes for payment administration, cap tracking, roster management and data accuracy.
• Financial risks: Addressing budgetary impacts, identifying sustainable funding sources and evaluating long-term financial commitments.
• Reputational risks: Managing public perception, donor expectations and institutional credibility.
• Competitive risks: Responding to disparities in institutional funding, retaining athletic talent and preserving long-term positioning within conferences.

These risks should be clearly documented, assessed for likelihood and impact, and linked to mitigation strategies.

Governance, Culture and Strategy

Revenue sharing calls for strong governance structures and a commitment to ethical culture. Institutions should:

• Reaffirm board and leadership involvement in compensation-related oversight.
• Define roles and responsibilities for general managers, finance, legal and compliance.
• Ensure coordination between departments managing revenue share and those supporting NIL activities.

Institutions should also consider how athlete revenue share aligns with the broader mission and financial goals. From an ERM standpoint:

• Evaluate how athlete compensation aligns with institutional values, risk appetite and long-term planning.
• Document the rationale behind revenue share structures to support defensibility with regulators, donors and stakeholders.
• Consider sustainability and equity when setting compensation policies to avoid unintended reputational or legal risks.

This strategic alignment helps ensure revenue share programs enhance (rather than conflict with) institutional objectives.

ERM leaders can serve as neutral facilitators in policy development and decision-making discussions, helping ensure these structures promote accountability and transparency.

Strengthening Internal Controls and Monitoring

As with any financial process, robust internal controls are key to supporting athlete revenue share payments. Internal audit teams can play a role in evaluating several areas.

• Payment authorization and accuracy: Are controls in place to prevent overpayments, underpayments or fraud? Are payments in accordance with contract terms?
• Cap management/compliance: Are revenue share payments being reported and monitored in the LBi College Athlete Payment System (CAPS)? Is academic integrity compliance evaluated before payments are distributed? Are roster limits and designated student-athletes (DSAs) being tracked in compliance systems?
• Separation from NIL deal structures: Are third-party NIL transactions clearly distinct from institutional payments? Are duties appropriately segregated? Are agreements over $600 being submitted to NIL Go?
• Technology and data integrity: Are ERP and payment systems properly configured with role-based access controls, audit logging and data validation? Are interfaces between systems secure and reconciled regularly? Is use of sensitive athlete information in compliance with institutional policy and federal privacy laws?

Regular control testing, particularly in the first year of implementation, can help identify gaps and inform policy refinements.

Continuous Review and Adaptation

Given the evolving nature of collegiate athletics regulation, it’s important to revisit policies, risks and controls regularly. ERM teams should:

• Build athlete revenue share into the annual risk assessment process.
• Stay up to date on CSC, conference, NCAA, state and federal developments that could affect implementation.
• Perform periodic internal audits of the revenue share process ensuring long-term effectiveness and alignment with institutional policies and regulatory requirements.
• Educate stakeholders (athletes, coaches, boosters, campus partners) on athlete revenue share policies, reporting responsibilities and compliance expectations.
• Create internal collaboration channels between athletics, risk management, finance and internal audit to share updates and flag emerging concerns.
• Partner with subject matter experts to reassess exposure as court decisions, legislation or policy changes unfold.

Athlete compensation is here to stay. While that brings new complexity, it also offers institutions a chance to strengthen oversight, transparency and risk alignment. For internal audit and ERM professionals, this is a pivotal opportunity to lead the way in helping institutions manage the transition. By embedding athlete compensation into ERM frameworks and internal audit plans, colleges and universities can meet this moment of change with the same rigor they apply to any other major operational or financial initiative.

Looking for guidance on how to implement these changes at your institution?

Connect with James Moore’s collegiate athletics advisors to assess your current risk posture, refine your internal controls and design a compliance strategy that aligns with both institutional goals and emerging regulatory expectations. We’re here to help you lead confidently through this next era of college sports.

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