NCAA Compliance: Changes to Agreed-Upon Procedures Impact Finance Reporting

Higher education institutions may need to rethink how they track, categorize, and report college sports revenue — and it could mean big changes for athletic department finance teams.

As collegiate athletics continue to evolve amid legal, financial, and cultural shifts, the National Collegiate Athletic Association (NCAA) has responded with targeted revisions of its financial reporting framework.

What NCAA financial reporting is required?

Higher education institutions with intercollegiate athletic programs must submit annual reports to the NCAA with financial data that details their operating revenue and expenses related to those programs. 

In addition to submitting this report, Division I schools must also complete agreed-upon procedures (AUPs) annually, while Division II schools must complete them every three years. The AUPs must be performed by a qualified, independent accountant.

New NCAA compliance guidance around agreed-upon procedures 

As collegiate athletics continues to evolve amid legal, financial, and cultural shifts, the NCAA has once again updated its Agreed-Upon Procedures (AUP) Guide.

The 2026 edition introduces a series of targeted revisions to bylaw references, terminology, and procedure scope designed to keep pace with the rapidly changing landscape of college sports, particularly in the wake of the House settlement and the expanding role of NIL collectives. 

For higher education institutions and their independent accountants, these updates carry important implications for Statements of Work, Representation Letters, and AUP reports.

For your higher education institution, these updates are more than just procedural — they represent a strategic opportunity to align your financial reporting with the current realities of collegiate athletics.

New and revised NCAA categories for college sports revenue reporting

Key 2026 NCAA AUP Guide changes include:

Bylaw reference update

The governing NCAA Bylaw for Division I schools requiring the annual submission of financial data has shifted from bylaw 20.2.4.18 to bylaw 20.2.4.17 (and 20.2.4.17.1). 

While the substance of the requirement remains, institutions must verify all engagement documents — including the Statement of Work, Representation Letter, and Agreed-Upon Procedures report — reflect the updated bylaw citations. This is a straightforward but critical update to avoid inconsistencies in your deliverables.

Affiliated and outside organizations — Terminology and scope changes

The definition of “affiliated and outside organization” has been revised on page 7 of the guide. Notably, the term “outside” has been formally added to the title and definition, while the prior definition of “supporting organization” has been removed. 

This change aligns the terminology with the required procedures over these organizations found on page 16 of the guide, creating consistency between the definitions and the procedures that reference them.

Collectives and affiliated/outside organization procedures

In a significant addition, the guide now explicitly recognizes a collective organization could qualify as an “affiliated or outside organization,” thereby bringing it within the scope of required procedures. A newly added Q&A section provides further guidance on when collectives should be included:

• If the collective is under the institution's control (uncommon, but potentially more relevant in the post-House environment), or
• If the collective is being used for institutional NIL purposes, then the collective may be in scope and subject to the affiliated/outside organization procedures. Institutions should carefully evaluate their relationships with collectives to determine applicability.

Minimum agreed-upon procedure #44 — Institutional revenue share expense

While procedure #44 over institutional revenue share expense was technically introduced in the prior year (FY25) guide, this may be the first year many engagement teams will need to actively test this procedure — particularly at larger institutions where revenue-sharing arrangements are now in effect. 

Teams should plan accordingly and incorporate this step into your testing plans for the current engagement.

Steps 19 and 20 — Post-season football expense reimbursements

The title for steps 19 and 20 has been updated from “football bowl revenues” to “post-season football expense reimbursements,” and the word “bowl” has been removed throughout. Additionally, the referenced bylaw has been updated from bylaw 20.02.10 to bylaw 20.02.11. 

Institutions and their engagement teams should update SOWs and AUP reports to reflect both the revised title and bylaw reference.

Additional agreed-upon procedures — Grants-in-Aid

The additional AUP over Grants-in-Aid now includes the words “revenue distribution” before “equivalency calculations.” This subtle but important wording change should be reflected in the Statement of Work and AUP report to align with the current guide language.

Additional AUP — Institutional Endowment

The additional AUP over Institutional Endowments has been updated to add the phrase “at the end of the reporting year” after “institutional endowments,” clarifying the timing of the measurement. Update your SOW and report language accordingly.

What these reporting changes mean for your college or university

The 2026 AUP updates may appear incremental on the surface, but they reflect the NCAA's ongoing effort to align its financial reporting framework with the evolving realities of collegiate athletics — from the growing influence of NIL collectives to the post-House revenue-sharing landscape. 

The key takeaway for institutions is clear: Review and update all engagement documents — including Statements of Work, Representation Letters, and AUP reports — to reflect the revised bylaw references, updated terminology, and expanded procedure scope.

How CLA can help with NCAA compliance

For institutions evaluating these updates, CLA is here to help. Whether you need assistance updating your engagement documents, evaluating the applicability of collective organization procedures, or planning your approach to testing Procedure #44, our team is ready to support a smooth and compliant engagement season.

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