On July 29, 2026, Nebraska’s athletic director announced that the College Sports Commission (CSC) had approved a restructured set of NIL deals for the same 18 Nebraska football players whose deals were arbitrated, totaling $7.5 million — the same dollar amount as the agreements the CSC previously denied. As discussed in our prior post, “The Great Divide Post-House: CSC Enforcement and the Power Four Conferences,” Arbitrator Andrew M. Strongin issued a binding May 11, 2026, ruling upholding the CSC’s denial of $7.5 million in NIL deals structured through Nebraska’s exclusive multimedia rights (MMR) partner.

According to its athletic director, Nebraska restructured and resubmitted the agreements through its MMR after exhausting the arbitration process. Reports confirm that the CSC approved the revised agreements, and that payment to the 18 athletes will be made once they complete the specific deliverables required under the newly restructured terms.

The original deals were rejected because they lacked what the CSC described as a “valid business purpose.” Nebraska’s revised agreements appear to address that issue directly by identifying concrete deliverables — including media appearances, content shoots, and social media posts — tied to payment milestones. In other words, the reworked structure is designed to show that each athlete’s NIL rights are being used, not merely stockpiled.

The resolution of the Nebraska matter is significant for several reasons that extend well beyond Nebraska football.

First, the resolution validates the CSC’s enforcement model, but on terms that favor restructuring over continued impasse. The CSC’s arbitration win was important. But a prolonged standoff in which 18 college athletes were denied millions of dollars in asserted NIL value would have created significant public relations and legal pressure for the post-House governance structure. Nebraska’s ability to secure approval for the same total dollar amount — by adding specific deliverables — suggests that the CSC’s concern was not necessarily the size of the payments, but the form and substance of the transactions.

Second, the resolution offers a practical model for schools and MMRs facing similar scrutiny. As we noted in our June post, the CSC’s recent enforcement actions have blocked or delayed hundreds of millions of dollars in third-party NIL commitments across the Power Four. The Nebraska outcome signals that deals structured through MMRs may still pass muster if they include genuine commercial deliverables and are not simply vehicles for routing additional revenue-share dollars to athletes above the $20.5 million annual cap. Schools, MMRs, and their counsel should view the Nebraska restructure as a useful compliance reference point. They should not, however, treat it as a categorical green light for all MMR-funded NIL activity.

Third, the associated-entity question remains contested. The arbitration ruling found that Nebraska’s exclusive MMR partner was an associated entity in the specific context of its relationship with the school — including embedded employees, use of the “Huskers Athletic Partners” trade name, and a financial structure that redirected the school’s own media rights revenue back to student-athletes. But Jeffrey Kessler, lead counsel for the House settlement plaintiffs, has made clear that he intends to argue in a separate proceeding that MMRs are categorically not associated entities. We addressed that dispute in a prior post, “MMRs and Third-Party Sponsors Are Associated Entities Under the House Settlement.” Nebraska’s decision to restructure, rather than continue litigating, does not resolve that broader issue. The scope of the CSC’s enforcement authority over MMRs — and whether that authority is consistent with the House settlement itself — remains very much alive.

Fourth, the state-law threat has not gone away. Nebraska Attorney General (AG) Mike Hilgers previously indicated that his office would file suit under Nebraska Revised Statute Section 48-3603 if the CSC prevailed in arbitration. The parties’ practical resolution may reduce the immediate pressure for AG intervention, but it does not moot the underlying issue. As we noted in our prior post, Nebraska is not the only state with statutes limiting an association’s ability to penalize student-athletes for engaging in NIL activity. Schools in California, Florida, Texas, Tennessee, Virginia, Georgia, Alabama, Mississippi, Missouri, and New Jersey operate under similar state-law protections. Future CSC enforcement action in those states could quickly move beyond arbitration and into state-court litigation or AG enforcement.

Key Takeaways for Practitioners and Programs

For athletic departments, MMR partners, and their legal counsel, the Nebraska resolution offers several practical takeaways:

• Deliverables are not optional. Any NIL deal structured through an entity with a close commercial relationship to a school — regardless of whether that entity is formally designated an associated entity — should include specific, current deliverables tied to payment. Generic future-use arrangements remain the clearest path to CSC rejection and a potential warehousing designation.
• Restructuring is a viable path, but not a guaranteed one. Nebraska’s ability to secure approval for the same dollar amount through reworked agreements is encouraging. But the CSC reviews each deal on its own facts, and approval in Nebraska’s case does not mean similar restructures will succeed elsewhere. The overall relationship between the school and the third-party entity will remain central to the analysis.
• Associated-entity status is fact-intensive. Arbitrator Strongin’s finding in the Nebraska case rested on a combination of factors specific to Nebraska’s MMR relationship. Schools and MMRs with different commercial structures may face different outcomes. Counsel should carefully review the relationship between any MMR and its partner school before submitting deals for CSC review.
• Monitor the House settlement proceedings closely. We offer a guide to the settlement proceedings. The broader question of whether MMRs are categorically subject to CSC oversight — the issue Jeffrey Kessler has preserved for further litigation — could significantly reshape the enforcement landscape. A ruling in favor of the plaintiffs on that issue could call into question a substantial body of CSC enforcement activity to date.

Looking Ahead

The Nebraska case began as a test of whether the CSC’s enforcement framework had teeth. The arbitration ruling showed that it does. The subsequent restructuring and approval showed that the framework also has some flexibility when athletes, schools, and their commercial partners are willing to work within it.

What remains to be seen is whether that flexibility will survive the next wave of challenges: the pending House settlement proceedings on MMR classification, the potential for state AG intervention, and the likelihood of further arbitration disputes as schools continue testing the boundaries of third-party NIL structuring in the post-House era.

For more information on NIL compliance, CSC enforcement, and the evolving college athletics landscape, please contact Callan G. Stein, Michael S. Lowe, or Christopher M. Brolley, or visit Troutman Pepper Locke’s NIL Revolution blog.