NCAA Compliance: Changes to Agreed Upon Procedures Impact Finance Reporting

  • Policy and regulation
  • 8/25/2025
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Key insights

  • Higher education institutions have new NCAA compliance rules for how they must report college sports revenue.
  • New categories make it easier to understand athlete compensation, and post-season expenses are now broken down by sport, with separate categories for football and non-football sports.
  • Schools need to update how they track and report their sports finances — and taking a look at your agreed upon procedures is an important first step.

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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 a significant overhaul 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 

The 2025 edition of the NCAA Agreed-Upon Procedures (AUP) Guide introduces a series of updates designed to reflect the growing complexity of athletic department revenues and expenses. 

It’s a pivotal moment in collegiate athletics, driven in part by the House v. NCAA settlement, which introduced institutional name, image, and likeness (NIL) revenue sharing caps as a new financial reality and brought NIL tax implications for NCAA student athletes. These AUP Guide changes aim to enhance transparency, improve comparability across institutions, and enable compliance with new legal and financial realities — particularly in the wake of the House settlement and National Collegiate Athletic Association v. Alston decision.

For your higher education institution, these updates are more than just procedural — they represent a strategic opportunity to align your financial reporting with the modern landscape of college sports.

New and revised NCAA categories for college sports revenue reporting

Key updates aim to improve transparency and comparability across institutions

  • Separate reporting for NIL Revenue Sharing (Category 44) and Alston-Related Educational Benefits (Category 43), enhancing clarity around athlete compensation
  • Post-season expenses must now be reported by sport, with new categories for football (41B) and non-football sports (42, 42A, 42B)
  • The corresponding category definitions for Coaching Compensation (22 and 23), Team Travel (28), Sports, Equipment, Uniforms, and Supplies (29), Game Expenses (30), and Spirit Groups (33) were updated to note that any expenses related to NCAA championships should be reported in categories 41 (football) or 42 (non-football).
  • NCAA distributions (Category 12) are split into subcategories for grants (12A), host settlements (12B), and reimbursements (12C), while Facilities Maintenance (35A) is now tracked separately from general overhead. 

Summary of NCAA agreed upon procedure changes

To support the new reporting categories, the NCAA has updated and introduced several procedures.

Updated procedures

  • Procedure #12 now covers the three new NCAA distribution subcategories 12A, 12B, and 12C.
  • Procedure #35A includes both direct overhead (category 35) and facilities maintenance (category 35A).
  • Procedure #41 was expanded to include all football-related post-season expenses in subcategories 41, 41A, and 41B. 

New procedures

  • Procedure #42A addresses post-season expenses for other (non-football) sports in categories 42, 42A, and 42B.
  • Procedure #43A covers Alston-related educational benefits in category 43.
  • Procedure #44A focuses on institutional NIL and revenue-sharing expenses in category 44.

Additionally, the NCAA bylaw governing annual financial data submission is now designated as Bylaw 20.2.4.18.

What these reporting changes mean for your college or university

These changes mean your higher education institution must rethink how to track, categorize, and report athletic department finances. With increased scrutiny on athlete compensation, post-season spending, and infrastructure costs, your reporting systems must remain accurate, transparent, and compliant. 

The enhanced detail can also support better benchmarking and accountability across programs.

How CLA can help with NCAA compliance

For higher education institutions navigating these updates, CLA is available as a trusted resource to provide guidance, answer questions, and support implementation efforts to transition smoothly under the new framework.

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