Sports
International College Athletes Remain in Limbo After House v. NCAA Decision


Takeaways
- International student-athletes on F-1 visas face significant legal barriers to participating in Name, Image, and Likeness (NIL) activities due to existing immigration laws prohibiting most forms of employment for F-1 visa holders.
- The House v. NCAA settlement agreement introduces revenue sharing to college athletics, but it raises unresolved legal questions about the kinds of compensation that international students can receive and the permissible NIL-related activities that international student-athletes can engage in while maintaining their F-1 visa status.
- Permissible NIL activities for F-1 students are limited to passive income (e.g., royalties, licensing) and activities performed entirely outside the United States; active or promotional work within the United States is prohibited posing significant compliance challenges for athletics departments seeking to provide economic benefits to international athletes similar to those their teammates can participate in and receive.
- Despite efforts from Congress to urge the Department of Homeland Security (DHS) to provide guidance permitting F-1 visa holders to receive revenue share payments and to participate in active NIL opportunities on United States soil, no federal guidance has been issued to date, leaving schools and collectives to navigate an uncertain legal landscape with severe consequences for noncompliance.
- Noncompliance carries serious consequences, including potential loss of visa status for students and civil or criminal penalties for institutions and athletic departments.
The Ongoing NIL Legal Challenges for International Student-Athletes Post House
In February 2023, we shared an update on the rapidly evolving landscape of student-athlete NIL rights following the emergence of new state-level NIL laws and the Supreme Court’s decision in NCAA v. Alston.
Since then, the legal and regulatory framework has continued to shift dramatically, with legislative hearings held in Washington, ongoing legal debates in Johnson v. NCAA and Schroeder v. Oregon, and updates to Title IX from the United States Department of Education. Most recently, the NIL landscape has shifted because of the landmark House v. NCAA settlement agreement. While these developments have opened new doors for student-athletes, they have also exposed a widening gap in protections and opportunities for international student-athletes—many of whom hold F-1 visas and face unique legal constraints.
The New Revenue-Sharing Era of College Sports Post House
On July 1, 2025, the NCAA entered a new era of college sports compensation following a $2.8 billion settlement in House v. NCAA, which provides retroactive and prospective NIL payments to student-athletes, allows direct payments from institutions to players, and establishes a 10-year revenue-sharing model. The agreement also allows for expanded roster and scholarship limits across several sports and establishes a new enforcement mechanism—“NIL GO”—a Deloitte-managed clearinghouse responsible for reviewing non-school NIL deals over $600 for fair market value. While the settlement agreement is widely viewed as a win for student athletes, it also highlights murky legal terrain for collectives and schools that may violate immigration law if they compensate international student-athletes.
In the absence of federal guidance, several questions remain:
- Can international student athletes legally participate in revenue sharing under current visa restrictions?
- What types of NIL activities are currently permissible for F-1 visa holders, and how can schools and collectives ensure compliance with immigration law?
- How should schools, collectives, or international student-athletes structure NIL deals that are compliant with F-1 visa restrictions?
The Overlap Between Immigration Policies, NIL Rules, and International Student-Athletes
Currently, more than 25,000 international student-athletes from countries around the world compete in NCAA sports. These athletes face a unique set of challenges when it comes to navigating the evolving NIL landscape. Moreover, the collectives and schools that serve these students must also work through a system that lacks clear federal guidance and presents significant legal risks. While recent reforms have expanded NIL opportunities for domestic student-athletes, including direct school payments, revenue-sharing, and broader endorsement rights, the NIL landscape has yet to fully address—nor has immigration policy resolved—the unique challenges facing international student-athletes.
Despite the sweeping changes since our last update in 2023, neither the DHS nor the Student and Exchange Visitor Program (SEVP) have issued guidance on how and whether international student-athletes can participate in NIL agreements without violating immigration law.
To be clear, student-athletes on F-1 visas must follow immigration rules that strictly limit the types of activities for which they can be paid. To understand what international student-athletes can do, it’s helpful to first look at the various F-1 restrictions and requirements:
- No off-campus employment without authorization
- F-1 students are generally prohibited from working off-campus unless specifically authorized through programs like Curricular Practical Training (CPT) or Optional Practical Training (OPT). See 8 C.F.R. § 214.2(f).
- Limited on-campus employment
- F-1 students are permitted to hold on-campus jobs, but only if it is directly affiliated with the school (e.g., bookstore, cafeteria). NIL-related activities typically do not qualify as on-campus employment. See 8 C.F.R. § 214.2(f).
- Self-employment prohibited
- F-1 students cannot operate a business or engage in self-employment, including NIL ventures run from a dorm room or personal brand monetization without authorization. See Handbook for Employers M-274.
- “Employment” is defined broadly
- In the immigration context, “employment” is defined as “any service or labor performed by an employee for an employer within the United States,” regardless of compensation. See 8 C.F.R. § 274a.1(h).
- Even unpaid NIL activities may be considered unauthorized employment if they benefit a third party.
- In Tenn. Coal, Iron & R.R. Co. v. Muscoda Local No. 123, the United States Supreme Court defined employment as the “physical or mental exertion (whether burdensome or not) controlled or required by the employer and pursued necessarily and primarily for the benefit of the employer and his business.” 321 U.S. 590, 598 (1944). This definition is used to assess whether an activity qualifies as employment under immigration regulations.
- In the immigration context, “employment” is defined as “any service or labor performed by an employee for an employer within the United States,” regardless of compensation. See 8 C.F.R. § 274a.1(h).
- NIL activity must be evaluated by location and nature
- Permissible: Passive income (e.g., royalties, copyright licenses, passive compensation) or NIL activities performed entirely outside the United States.
- Impermissible: Active NIL engagements (e.g., appearances, autograph signings, content creation) performed within the United States, even without compensation.
- Maintaining F-1 status
- Students must remain enrolled full-time and avoid any activity that could be interpreted as unauthorized employment, which could jeopardize their visa status and future immigration benefits.
- Legal consequences
- For schools/collectives: Civil and criminal penalties for knowingly employing unauthorized workers.
- For students: Loss of immigration status, ineligibility for future benefits, and potential removal proceedings.
What’s Permissible? NIL Activities That Don’t Violate F-1 Visa Rules
To help clarify what international student-athletes on F-1 visas can and cannot do under current immigration law, the chart below outlines common NIL-related activities in a side-by-side format. This comparison is designed to help schools, collectives, and student-athletes quickly identify compliant opportunities and avoid activities that could jeopardize visa status.
Special thanks to summer associate Gerry Regep for his contributions to this article. Gerry is not yet admitted to practice in any jurisdiction.
Sports
Men’s and Women’s Indoor Track and Field Open Season at GVSU Holiday Open
ALLENDALE, Mich. – The Kalamazoo College men’s and women’s track and field teams opened indoor season Friday at the GVSU Holiday Open. The competition marked the Hornets’ first track and field meet of any kind since 1980 for men’s, 1981 for women’s, and the first indoor competition since 1939 (men only).
Drew Abbott was the first competitor for Kalamazoo, finishing No. 10 overall and as the top Division III runner in the men’s one-mile run open field at 4:26.08.
In the men’s 400-meter dash, Bram Derksen posted a 53.87-second time, and Elliott Anderson ran his 400m in 55.33.
Allison Mayer became the Hornets’ first official women’s indoor track competitor by running a 10:54.84 3000m. Maya Alkema ran the 5000m in 18:37.56.
On the men’s side in the 5000m, Jack Schneider ran at a time of 15:56.47 and John Lonsway finished at 16:49.87.
Kalamazoo men’s and women’s indoor track and field will travel to Trine for the Sean Brady Invitational after the holiday break on Jan. 17, 2026.
Sports
Nebraska volleyball begins national title chase with win over LIU
Related coverage in the video aboveNebraska volleyball hosted LIU in the first round of the NCAA Tournament.Bergen Reilly to Andi Jackson and Nebraska was up 6-2.Jackson would later bump Nebraska’s lead to 15-9.A kill from Taylor Landfair ended set 1, giving Nebraska the 25-11 set victory.Rebekah Allick on the block, and it’s 3-0 Huskers in set 2.Allick and Jackson were leading the Huskers by the end of set 2. Nebraska defeated LIU 25-15 in the second set.A 4-0 run for the Huskers kicked things off in set 3.Nebraska was dominating LIU in set 3.Allick claimed match point for Nebraska.The Huskers got the 25-17 set win and the sweep over LIU.The Huskers will face Kansas State in the second round of the tournament on Saturday at 7 p.m.Make sure you can always see the latest news, weather, sports and more from KETV NewsWatch 7 on Google search.NAVIGATE: Home | Weather | Local News | National | Sports | Newscasts on demand |
Related coverage in the video above
Nebraska volleyball hosted LIU in the first round of the NCAA Tournament.
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Bergen Reilly to Andi Jackson and Nebraska was up 6-2.
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Jackson would later bump Nebraska’s lead to 15-9.
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A kill from Taylor Landfair ended set 1, giving Nebraska the 25-11 set victory.
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Rebekah Allick on the block, and it’s 3-0 Huskers in set 2.
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Allick and Jackson were leading the Huskers by the end of set 2. Nebraska defeated LIU 25-15 in the second set.
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A 4-0 run for the Huskers kicked things off in set 3.
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Nebraska was dominating LIU in set 3.
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Allick claimed match point for Nebraska.
The Huskers got the 25-17 set win and the sweep over LIU.
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The Huskers will face Kansas State in the second round of the tournament on Saturday at 7 p.m.
Make sure you can always see the latest news, weather, sports and more from KETV NewsWatch 7 on Google search.
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Sports
Track and Field Post Strong Performances at SVSU Holiday Invite
UNIVERSITY CENTER, Mich. – The Adrian College track and field team traveled to Saginaw Valley State University for the Holiday Invite, showcasing strong performances across the board.
On the men’s side, Joseph Sheridan set a personal best in the 400m dash with a time of 51.06, earning 23rd place. In the mile, both Jessie Strickland and Nick Doerr set personal records, with Strickland crossing the finish line in 5:06.00 for 21st place and Doerr finishing 22nd in 5:07.95. Brandon Berry soared to a fifth-place finish in the high jump, clearing 1.94m and cementing his place in the program’s top-10. In the long jump, Ian Chavis claimed 10th with a leap of 6.15m (20-2.25), while Forrest Schroeder posted a solid 12th-place mark at 6.09m (19-11.75).
The women’s team also had notable performances. Abigail Raftis ran the 400m dash in 1:06.36 for 26th place, and Alayna Paeth set a personal best in the 800m with a time of 2:38.94, earning 22nd place. In the high jump, Alysia Townsend cleared 1.57m (5-1.75) to finish sixth. The long jump saw Piper Pierce take 23rd with a mark of 4.63m (15-2.5) and Emily Peterson finish 26th at 4.30m (14-1.25).
Up Next: The Bulldogs are back in action on Saturday, January 17th where they will head back to Saginaw Valley State University. The meet is scheduled to kick-off at 10:00 AM.
Sports
Temple Begins Indoor Track & Field Season at UPenn This Weekend
Live Results
Previewing the Owls
- A total of 26 athletes will represent Temple across 11 events this weekend.
- Freshman Emilie Creighton, Aly Doyle, Kei-Mahri Hanna, Rian Johnson, Kenya Merritt, Kamryn Ohm, Janae Pettaway, Smilla Ranebro, and Adama Turay, will make their indoor track and field college debut this weekend.
- Nine Temple athletes will compete in the jumps: Emelie Beckman (pole vault), Doyle (long jump), Ohm (pole vault), Ranebro (high jump), Shalisha Robertson (long jump and triple jump), Reagan Schwartz (long jump and triple jump), Deja Scott (long jump), Inara Shell (long jump and triple jump), and Reece Sullivan (pole vault).
- For the sprints, Zayniah Ali, Pettaway, Turay, and Lila Ziegler will compete in the 60m dash. Also, racing in the 60m hurdles are: Ali, Doyle, and Turay.
- Competing in the 300m dash are Ali, Grace Hickman, Merritt, Pettaway, and Maliah Powell.
- Racing in the 600m are Jayla Green, Hanna, Mariah Jameson, Chole Smith, and Dicia Watkins.
- Laila Cottom and Maya Gomes will represent Temple in the 1,000m race. While, Creighton and Johnson will run the 3,000m race.
- To conclude the meet Temple will race three 4×400 meter relay teams.
Previewing the Field
Other schools that will be competing this weekend are Delaware, Georgetown, Hampton, Rider, St. Joseph’s, Penn, Princeton, Morgan State, and Villanova.
Up Next
Temple will return to the Ott Center to compete at the Penn Select hosted by Penn on Saturday, Jan. 10.
Sports
Women’s Track & Field Sees Positive Performances at SVSU Holiday Open
RESULTS
UNIVERSITY CENTER, Mich. –
Three top 10 performances in program history put the Albion track & field team in good spirits at the SVSU Holiday Open.
Performing inside the vast field house with a 300m track, Caragh Dwyer placed 14th in the 400m (1:02.92) that was good enough to earn a top 10 mark in team history.
Maggie Sorrelle leapt for a mark of 2.82m in the pole vault, which was the fourth-best in Albion history and highest since 2020.
In the throws, Morgan Hurd’s 14.81m toss in the weight throw was fourth-furthest in Albion history and tenth overall among the field.
Mia Czarnowski (8.31, PR), Sorrelle (27.66) and Brianna Bennett (1:05.70, PR) were the best finishers for the Britons in the 60m, 200m and 400m, respectively.
Czarnowski posted a 4.77m in the long jump, while Zoey Bennett leapt a 9.45m in the triple jump.
As for other throwers, Kaylee Kopulos notched 10.42m and 12.43m tosses in the shot put and weight throw, respectively.
Up Next
Albion will be back in action during next calendar year, as they will head to Heidelberg’s brand-new indoor track for the Larry Brown Invitational on Friday, January 16.
Sports
USC Women’s Volleyball Falls to Cal Poly in NCAA Second Round Bout
KEY PLAYERS
- Fr. OPP Abigail Mullen led all scorers with 21.5 points earned on a match-high 17 kills (7e, 39att, .256) to go with 10 digs for her eighth double-double. She also had five blocks and two service aces.
- Fr. S Reese Messer put up her 11th double-double with 46 assists and 11 digs. She also added six blocks (one solo) and had three kills on eight swings (.375).
- RS So. OH London Wijay had 10 kills (3e, 38att, .184) and 12 digs for her eighth double-double (17th career).
- RS So. MB Leah Ford had nine kills (1e) on 17 swings to hit .471 and led the team with seven blocks.
- So. MB Mia Tvrdy played just the last three sets but finished with eight kills on 10 swings (.800) and had two blocks, two digs and a two-handed jump-set assist on a kill by Mullen.
- Sr. MB Rylie McGinest had six kills (1e, 13att, .385) to go with one block.
- Fr. LIB Taylor Deckert led the team with 13 digs and added six assists. Sr. LIB Gala Trubint had four digs and a service ace.
- For the Mustangs, Emma Fredrick led with 17 kills and had 17 digs to lead all players. Kendall Beshear and Annabelle Thalken each had 12 kills. Beshear had 14 digs for the double-double and served a pair of aces. Emme Bullis put up 44 assists with 12 digs for a double-double.
HOW IT HAPPENED
- The Mustangs never trailed in the opening frame to grab a 25-19 win. Both teams registered 15.0 points, but the Mustangs committed fewer unforced errors to come out on top. The Trojans had 13 kills with five from McGinest but hit just .146 with seven errors on 41 swings. Cal Poly had just 11 kills but hit .258 and had a 3-1 edge in blocks. Both teams each served an ace, but the Trojans served six errors to the Mustangs’ two in the loss.
- The teams were tied 13 times and the lead changed hands five times before Cal Poly took a 2-0 lead with a 25-20 win in set two. Mullen had five kills to lead the Trojans, but USC totaled just 10 kills and hit .147 in the set. Both teams had three blocks apiece, but the Mustangs still hit .270 with 15 kills (5e) on 37 swings with five more kills from Beshear.
- USC secured a 25-20 set-three win on the second of two service aces from Dani Thomas-Nathan. Tvrdy came in and sparked the Trojans with the first kill of the frame and finished with five on just six swings. Mullen tallied six kills on 12 swings without an error and helped USC hit .326 (18k, 4e, 43att). The Trojans had four blocks to help hold the Mustangs to a .194 attack rate with 10 kills (4e) on 31 swings. USC never trailed and led by five twice before winning by five.
- Back-to-back Mustang errors broke the eighth and final tie of the fourth and put the Trojans in front, 11-9, en route to a 25-14 win. USC continued to push and moved in front by six, 17-11, on a block by Mullen and Ford. Back-to-back kills from Mullen put USC on top by seven, 19-12, and her tool kill made it a 10-point USC lead at 23-13. Mullen and Wijay each scored four kills in the fourth as the Trojans hit .448 (14k, 1e, 29att) and had three blocks to hold Cal Poly to a .081 hitting percentage with 12 kills (9e) on 37 attacks.
- Cal Poly broke a three-all tie in the fifth with a 6-0 run and was never threatened on the way to a 15-7 win to seal the 3-2 win. Beshear had a six-serve run that included a service ace to put the Mustangs on top by six, 10-4. The Trojans could get no closer than within five despite every effort. The Mustangs hit .316 with eight kills (2e) on 19 swings over USC’s .091 rate in the fifth with five kills (3e) on 22 attempts.
MATCH NOTES
- USC fell to 13-6 all-time against Cal Poly. The teams met for the first time since 2012.
- The Women of Troy fell to 15-4 at home this season and to 231-64 (.783) all-time at Galen Center, which includes a 21-5 mark in NCAA tournament matches.
- USC goes to 131-45 (.744) all-time in the postseason with an 85-38 (.691) mark in the NCAA tournament.
- The Trojans fell to 14-11 in the second round of the NCAA tournament.
For more information on the USC women’s volleyball team and a complete schedule and results, please visit USCTrojans.com/WVB. Fans of the Women of Troy can follow @USCWomensVolley on Facebook, X, TikTok, and Instagram.
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