The NCAA’s 5-Year Eligibility Rule: Recent Updates

ABA Antitrust Law Section, Trade, Sports & Professional Associations Committee

12.12.2025

Tensions between athletes and the NCAA have escalated in the wake of recent litigation regarding athlete compensation and eligibility rules. Student-athletes are bringing lawsuits against the NCAA, claiming that eligibility rules impede their ability to compete in the marketplace for name, image, and likeness (“NIL”) funding. This article summarizes litigation surrounding eligibility rules and the payment of athletes and illustrates the economic arguments used in each.

In the 2021 case NCAA v. Alston, the Supreme Court ruled that Sherman Act Violations prevented student athletes from receiving education-related benefits.¹ Since then, rulings and settlements have paved the way for a new era of student-athlete compensation.² Athletes can now be compensated for their NIL’s, however they are still subject to the NCAA eligibility rules.³ These rules give college athletes five years to graduate and four seasons to compete following their full-time enrollment.⁴ Three recent cases have challenged these rules. In these cases, student-athletes allege they were harmed by NCAA eligibility rules which restrict their ability to participate in the labor market for sports and compete for NIL funding, constituting an antitrust violation. All three cases are at different stages of litigation. Below are some recent case updates.

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CITATIONS

1. Law360, “High Court Says NCAA Can’t Limit Athlete Education Pay”, available at https://www.law360.com/articles/1373231/high-court-says-ncaa-can-t-limit-athlete-educationpay; Supreme Court of the United States, National Collegiate Athletic Association v. Alston et al., available at https://www.supremecourt.gov/opinions/20pdf/20-512_gfbh.pdf; Law360, “Judge Rules NCAA Rules Are Commercial, Grants Injunction,” September 19, 2025, available at https://www.law360.com/articles/2390373

2. NCSL, “What the NCAA Settlement Means for Colleges and State Legislatures,” June 9, 2025, available at ncsl.org/state-legislatures-news/details/what-the-ncaa-settlement-means-forcolleges-and-state-legislatures; See also, ESPN, “Judge OK’s $2.8B settlement, paving way for colleges to pay athletes,” June 6, 2025, available at https://www.espn.com/collegesports/story/_/id/45467505/judge-grants-final-approval-house-v-ncaa-settlement.

3. New York Times, “College Athletes Can Now Be Paid. But Not All of Them are Seeing Money. Is That Fair?” February 6, 2023, available at https://www.nytimes.com/2023/02/06/learning/college-athletes-can-now-be-paid-but-not-all-ofthem-are-seeing-money-is-that-fair.html.

4. There are also additional requirements like GPA and credit-hour restrictions. See NCAA, “Stay ing on Track to Graduate,” available at https://www.ncaa.org/sports/2021/2/10/studentathletes-current-staying-track-graduate.aspx. There have also been exceptions to these requirements at certain times, such as the redshirt rule (permitting athletes to practice but sit out of competitions, typically used for injury) and exemptions related to the COVID-19 pandemic. See, USA Today, “What is a redshirt?”, available at https://www.usatoday.com/story/sports/ncaaf/2025/11/12/what-is-redshirt-college-footballeligibility-rules-years/87234264007/.