Pay to Win
By Brandon Koo Sep. 23, 2026
In 2025, former University of Georgia quarterback Carson Beck transferred to the University of Miami after a name, image and likeness (NIL) deal reported at about $4 million, per Sports Illustrated. This amount is larger than the salaries of some NFL quarterbacks. The decision reflects how NIL has transformed college athletics and become another factor in college recruiting and transferring.
NIL allows college athletes to profit from their personal brands through sponsorships, endorsements, social media and other business opportunities. Prior to 2021, National Collegiate Athletic Association (NCAA) rules generally prevented athletes from earning money based on their platform and fame. The adoption of NIL rules marked a major shift by allowing athletes to benefit financially from their personal brands, shifting valuations toward social reach rather than athletic performance alone.
Because brands value personality, appearance and social media reach, popular athletes often command higher NIL valuations than more decorated teammates. For example, Louisiana State University gymnast Olivia Dunne leveraged more than 10 million followers into a $3.3 million On3 valuation, according to Gatorsports. By comparison, University of Florida gymnast Trinity Thomas, one of the most decorated gymnasts in NCAA history, had an estimated NIL valuation of roughly $110,000 using the same On3 data.
The rise of NIL followed years of legal challenges. A significant case was O’Bannon v. NCAA in 2009, which challenged NCAA restrictions on athlete compensation under federal antitrust laws, designed to prevent unfair restrictions on competition, per the Brooklyn Law Review.
In June 2021, the Supreme Court ruled unanimously in NCAA v. Alston that the NCAA could not restrict certain education-related benefits for athletes, further challenging its compensation rules. According to ESPN, a separate shift occurred in June 2025, when a federal judge approved the House v. NCAA settlement. The settlement included $2.8 billion in back pay to former Division I athletes and allowed schools to begin sharing revenue directly with current players, per Ropes & Gray.
The system has also potentially increased the advantage of wealthier programs. While recruiting used to focus on academics, facilities, coaching and playing opportunities, athletes now also consider financial opportunities. Major programs, such as the University of Alabama, can use larger athletic budgets and build stronger donor networks that may make it harder for smaller Division I schools to compete for recruits.
According to CBS Sports, the University of Colorado Boulder signed just seven high school players in its 2024 class while adding 24 transfers, a year after bringing in 51 transfers under coach Deion Sanders. This recruiting strategy emphasizes how experienced transfers can reduce the number of roster opportunities available to incoming high school athletes.
“Losing a roster spot to a college transfer is definitely something to think about, but as a swimmer the chances of that happening are pretty low. Whereas this might be a problem in football, swimming programs recruit for potential. I hope NIL will benefit a wider variety of athletes,” Senior Isaac Litwiller said.
According to Fox Sports, University of Texas quarterback Arch Manning had an estimated $6.8 million NIL valuation entering the 2025–26 academic year, while Ohio State University receiver Jeremiah Smith was valued at $4.2 million. For some athletes, earning significant money in college could make staying another year more attractive than entering professional sports. For high school athletes, NIL can also create pressure to build a personal brand before reaching college.
“NIL wasn't really the biggest factor. I cared a lot more about the overall fit of the school, academics, coaching, team culture and the opportunity to compete at a really high level. It definitely adds another thing to think about during a process that is already pretty stressful and complicated, especially because the NIL is still changing so much. But at the same time, it gives a lot of athletes opportunities that weren't there before,” Senior Christina Flynn said.
For athletes in college, NIL is no longer simply an opportunity to earn money. It has become another factor in decisions about where to play, whether to transfer and how long to remain in college.
About the Contributor
Brandon Koo
School News Editor
Brandon Koo is a junior at Leland High School and the School News Page Editor for The Charger Account. When not inside studying, you can find Brandon outside running, hiking, or playing tennis. He also enjoys spending time with friends and coaches tennis on the weekends.
Mira Reddy
Artist
Mira Reddy is a junior at Leland High School and an artist for The Charger Account. She loves swimming, watching romcoms and spending time with friends in her free time.
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