Massachusetts transitioning from “legislative silence” (2021-2024) to codified regulation via House Bill 1930 (proposed effective July 1, 2027). “Fair Share Amendment” = 4% surtax on income >$1M (9% effective rate) creates “Massachusetts Premium” competitive disadvantage. Boston College: “Max Cap” $20.5M commitment; “Friends of the Heights” raised $2.4M in 3 weeks; GM hire (Kenyatta Watson). UMass: MAC transition; merged collectives; $1-2M budget. Harvard/Ivy League: Opted OUT of revenue sharing. MIAA Rule 47.1.3 (Aug 2022) permits high school NIL with IP Ban. Here’s the complete guide.
Massachusetts’s NIL Evolution
Massachusetts’s “legislative silence” era (2021-2024) is ending. H.1930 moving through committees. “Fair Share Amendment” creates unique economic headwind—”Taxachusetts” critique.
“Legislative Silence” Era (2021-2024):
- No specific NIL legislation while 30+ states enacted laws
- Strategic deferral to NCAA interim policies
- Provided institutions maximum flexibility
- No “safe harbor” provision—calculated risk
- Eventually exposed vulnerabilities: No agent certification, no disclosure requirements
House Bill 1930 (2025) — “An Act empowering student-athletes”:
- First comprehensive attempt to codify NIL rights
- Sponsored by Rep. Francisco E. Paulino
- Prohibits institutions from preventing NIL compensation
- Mandates: Scholarship cannot be reduced for NIL earnings
- 72-hour disclosure requirement (or before next athletic event)
- Agent regulation: Statutory definitions, professional standards
- Privacy: NIL agreements EXEMPT from public records
- Status: Reported favorably Dec 2025; Senate Ways and Means
- Proposed effective date: July 1, 2027
“Fair Share Amendment” — The Tax Headwind:
- Constitutional amendment (approved 2022)
- 4% surtax on annual income exceeding $1 million
- Base rate: 5.0% + Surtax: 4.0% = 9.0% effective on income >$1M
- Disadvantage vs. zero-tax states (FL, TX, TN, NV)
- $2M offer: ~$140,000 state tax liability (vs. $0 in Florida)
- Creates “Massachusetts Premium” collectives must pay to match offers
“Brain Drain” Examples:
- Grant Williams (Celtics → Mavericks): Cited Fair Share Amendment
- Williams: “$54M contract in Dallas = $58M in Boston” (tax differential)
- Bill Belichick: “Taxachusetts” critique (harder to recruit free agents)
- Jeff Hafley (BC → Green Bay): Economic lens on departure
Boston College — “Max Cap” Power 4 Strategy:
- Only “Autonomy Four” (Power 4) institution in New England
- December 2025: Committed to FULL ~$20.5M revenue share cap
- AD Blake James: Essential to align with ACC peers
- “Friends of the Heights” (FOH): Centralized collective for all sports
- “Heights of Giving” campaign: $1M goal → raised $2.4M in 3 weeks
- Kenyatta Watson hired as GM (roster management, NIL valuation)
- $50M challenge gift campaign for sustainable funding
UMass Amherst — Group of Five Consolidation:
- Joining Mid-American Conference (MAC) 2025-26
- “Tier 1 G5” spending model: $1-2M annually (vs. BC’s $20.5M)
- Collective merger: “The Midnight Ride” absorbed into “The Massachusetts Collective”
- Eliminated “ask fatigue” among donors
- “Double Penalty”: $400-500K annual NCAA distribution loss
- Pays settlement tax but doesn’t benefit from revenue sharing upside
Harvard / Ivy League — Philosophical Opt-Out:
- January 2025: Ivy League Council of Presidents opted OUT of revenue sharing
- Continues prohibition on athletic scholarships
- “Modernized amateurism” model
- Still liable for back damages settlement (funds Power 5 practices)
- Uses “Influencer” platform for third-party NIL opportunities
- Recruiting disadvantage vs. revenue-share schools
Why Massachusetts Matters:
Massachusetts illustrates “Fair Share Amendment” as structural competitive disadvantage (9% effective rate on >$1M). Three-tier system: BC “Max Cap” ($20.5M), UMass “Tier 1 G5” ($1-2M), Harvard “Opt-Out” (zero revenue share). H.1930 ending “legislative silence” era. “Friends of the Heights” raised $2.4M in 3 weeks. Kenyatta Watson GM hire = NFL-style professionalization. UMass “Double Penalty” = settlement cost without upside. MIAA Rule 47.1.3 permits HS NIL with IP Ban.
Massachusetts College NIL Rules
Currently governed by NCAA rules and House settlement terms. H.1930 (proposed effective July 2027) will codify disclosure, agent regulation, and privacy protections.
What H.1930 Will Provide (Proposed):
- Codified NIL compensation rights (cannot affect scholarship)
- 72-hour mandatory disclosure to compliance
- Agent regulation (statutory definitions, standards)
- Privacy: NIL agreements exempt from public records
- Revenue sharing permitted ($20.5M cap)
BC Infrastructure (“Max Cap”):
- “Friends of the Heights” (FOH): Centralized collective
- Full $20.5M revenue share commitment
- GM Kenyatta Watson (roster management, NIL valuation)
- $50M challenge gift campaign
UMass Infrastructure (“Tier 1 G5”):
- “The Massachusetts Collective” (merged from Midnight Ride)
- $1-2M annual NIL/revenue share budget
- Planning to hire “Internal NIL Person”
Harvard Infrastructure (“Opt-Out”):
NO revenue sharing (Ivy League opt-out)
“Influencer” platform for third-party opportunities
Commercial endorsements, coaching clinics permitted
Massachusetts High School NIL Rules
MIAA Rule 47.1.3 (August 2022) made Massachusetts the 16th state to permit high school NIL—with “bright line” prohibitions protecting school integrity.
Key Facts:
- Governing Body: Massachusetts Interscholastic Athletic Association (MIAA)
- Status: Permitted with restrictions (August 2022)
- 16th state to permit high school NIL
MIAA Rule 47.1.3 Permissions:
Allows: Commercial endorsements, social media influencing, providing private lessons. Creates pipeline of “NIL-literate” recruits entering college with brand experience.
“Bright Line” Prohibitions:
Intellectual Property Ban: Cannot use school name, logo, uniform, or mascot in NIL activity (no jersey in car dealership commercial). Vice Industry Bans: Alcohol, tobacco, cannabis, prescription pharmaceuticals, gambling, weapons, adult entertainment. No “Pay-for-Play”: Collective-style payments contingent on enrollment or performance are forbidden. Compensation must be for work performed (autographs, content) at fair market value.
College vs. High School: Key Differences
| Feature | College (H.1930 Proposed) | High School (MIAA) |
|---|---|---|
| NIL Status | Legal (H.1930 pending) | Permitted (Aug 2022) |
| State Statute | H.1930 (proposed July 2027) | MIAA Rule 47.1.3 |
| Institutional Pay | Permitted ($20.5M cap) | Prohibited |
| School Logos/Uniforms | Allowed | Strictly prohibited (IP Ban) |
| Disclosure | 72-hour mandatory (proposed) | N/A |
| Vice Industries | Prohibited (NCAA) | Explicitly banned |
| Pay-for-Play | N/A (revenue sharing) | Forbidden |
| Fair Share" Tax Impact | 9% on >$1M ("MA Premium") | N/A |
The Key Distinction: Massachusetts transitioning from “legislative silence” to H.1930 codification. “Fair Share Amendment” (9% on >$1M) creates structural “Massachusetts Premium” disadvantage. Three-tier college system: BC “Max Cap” ($20.5M), UMass “Tier 1 G5” ($1-2M), Harvard “Opt-Out.” MIAA Rule 47.1.3 (Aug 2022) permits HS NIL with IP Ban and vice restrictions. Creates pipeline of “NIL-literate” recruits.
What Massachusetts Athletes Can Do
College Athletes:
Earn NIL compensation; Receive revenue sharing (BC: $20.5M, UMass: $1-2M, Harvard: $0); Work with “Friends of the Heights” (BC) or “The Massachusetts Collective” (UMass); Use “Influencer” platform (Harvard); Sign endorsement deals with brands; Monetize social media accounts; Earn from camps, clinics, and appearances; Receive fan support through platforms like RallyFuel.
High School Athletes:
Sign commercial endorsements (no school affiliation); Social media influencing (no school branding); Provide private lessons; Build personal brand for college recruitment (“NIL-literate” pipeline).
What Massachusetts Athletes Cannot Do
College Athletes:
Cannot endorse: gambling, tobacco, adult entertainment, controlled substances (NCAA rules); International students (F-1 visa): Cannot engage in active NIL on U.S. soil; Note: “Fair Share Amendment” creates tax inefficiency on >$1M earnings.
High School Athletes:
Cannot use school name, logo, uniform, or mascot; Cannot endorse: alcohol, tobacco, cannabis, pharmaceuticals, gambling, weapons, adult entertainment; Cannot accept pay-for-play (enrollment/performance contingent); Must be for work performed at fair market value.
Both:
Must pay taxes (MA 5% base + 4% surtax on >$1M + federal + self-employment); Must maintain academic eligibility.
Compliance Requirements
For College Athletes:
Work with FOH (BC), Massachusetts Collective (UMass), or Influencer platform (Harvard); Report deals per NCAA requirements (H.1930 will mandate 72-hour disclosure); Disclose conflicts with institutional sponsors; Avoid prohibited categories per NCAA rules; Plan for “Fair Share Amendment” tax impact if earnings >$1M.
For High School Athletes:
NEVER use school name, logo, uniform, or mascot; NEVER endorse vice industries; NEVER accept pay-for-play (enrollment/performance contingent); Compensation = work performed at fair market value.
For Parents:
For college: H.1930 pending (proposed July 2027 effective date); “Fair Share Amendment” = 9% effective tax on >$1M (vs. 0% in FL, TX, TN); Three tiers: BC ($20.5M), UMass ($1-2M), Harvard ($0 revenue share); BC’s GM hire signals NFL-style professionalization. For high school: MIAA Rule 47.1.3 (Aug 2022) permits NIL; IP Ban = no school branding; Vice industry bans explicit; Pay-for-play forbidden; “NIL-literate” experience valuable for college recruitment.
How Fans Support Massachusetts Athletes
Massachusetts has passionate Eagles, Minutemen, and Crimson fans—and now they can directly support athletes through NIL.
College Athletes:
Platforms like RallyFuel enable Massachusetts fans to support athletes at:
- Boston College – ACC (Power 4)
- UMass Amherst – MAC (Group of 5)
- Harvard University – Ivy League (Opt-Out)
- All sports—Football, Basketball, Hockey, and more
Massachusetts NIL Infrastructure:
BC “Friends of the Heights” (FOH): Centralized collective for all sports. “Heights of Giving” campaign ($2.4M in 3 weeks). GM Kenyatta Watson. $50M challenge gift campaign. UMass “The Massachusetts Collective”: Merged from “The Midnight Ride.” $1-2M annual budget. Hiring “Internal NIL Person.” Harvard “Influencer” Platform: Third-party opportunities only. No revenue sharing (Ivy League opt-out).
How It Works:
1. Create an account on RallyFuel.com or the mobile app
2. Select your Massachusetts school affiliation
3. Browse verified athletes currently on your program’s roster
4. Fuel athletes you want to support
5. Track your support through your fan dashboard
How It Works: When you purchase Fan Fuel, you’re purchasing Conditional NIL Engagement Rights (CNERs). If conditions are met, RallyFuel or its affiliate offers an NIL Agreement to the athlete. If conditions aren’t met—for example, if an athlete transfers—you receive an automatic refund.
Conditional Protection: RallyFuel’s conditional model protects Fan Fuel with automatic refunds if athletes transfer or conditions aren’t met. Massachusetts fans can support players without financial risk.
Important: Fan support through RallyFuel is voluntary and conditional. Fuel purchases are not charitable donations. RallyFuel is not a guarantor that any athlete will accept an NIL Agreement. Purchasing Fan Fuel does not guarantee athletic performance, playing time, or any specific outcome.
High School Athletes:
Massachusetts high school athletes may pursue NIL opportunities under MIAA Rule 47.1.3 (effective August 2022) provided they have NO affiliation with their school in any NIL activity and avoid all vice industries. Creates “NIL-literate” recruits for college programs.
Learn More About the NIL Landscape
Name, Image, and Likeness plays an increasing role in college sports, and understanding how it works often requires more than individual articles or news updates.
RallyFuel is a platform focused on NIL-related topics across college athletics. It brings together information about athletes, NIL activity, and the broader structure behind modern college sports, helping readers explore the topic in more depth.
Frequently Asked Questions
Can Massachusetts high school athletes do NIL?
Yes. MIAA Rule 47.1.3 (August 2022) permits NIL—Massachusetts was 16th state. Allowed: Commercial endorsements, social media influencing, private lessons. Prohibited: School name, logo, uniform, mascot; alcohol, tobacco, cannabis, pharmaceuticals, gambling, weapons, adult entertainment; pay-for-play (enrollment/performance contingent). Creates “NIL-literate” pipeline for college recruitment.
What is House Bill 1930?
First comprehensive state NIL legislation. Sponsored by Rep. Francisco E. Paulino. Key provisions: Codifies NIL rights (scholarship cannot be reduced for NIL); 72-hour mandatory disclosure; Agent regulation (statutory definitions, standards); Privacy (NIL agreements exempt from public records). Status: Reported favorably Dec 2025; Senate Ways and Means. Proposed effective date: July 1, 2027.
What is the “Massachusetts Premium”?
“Fair Share Amendment” (2022): 4% surtax on income >$1M. Base rate 5% + surtax 4% = 9% effective on >$1M. $2M offer = ~$140,000 state tax (vs. $0 in FL, TX, TN, NV). Collectives must pay extra to match zero-tax state offers. “Brain drain” examples: Grant Williams (“$54M in Dallas = $58M in Boston”), Bill Belichick (“Taxachusetts”), Jeff Hafley departure.
Why did Harvard/Ivy League opt out of revenue sharing?
January 2025: Ivy League Council of Presidents opted OUT. Continues prohibition on athletic scholarships. “Modernized amateurism” model. Still liable for back damages settlement (subsidizes Power 5 practices). Uses “Influencer” platform for third-party opportunities. Recruiting disadvantage vs. revenue-share schools. Philosophical commitment to educational mission over professionalization.
What is UMass’s “Double Penalty”?
As Group of 5 (MAC) school: Benefits less from revenue-sharing upside ($1-2M vs. BC’s $20.5M). BUT: Still subject to NCAA distribution withholding for back damages settlement. Projects $400-500K annual NCAA revenue loss over next decade. Effectively “taxed” to fund settlement driven by Power 5 practices. Compounds challenge of competing in new era.
What happens if an athlete I supported transfers?
If an athlete transfers or selects a different school during the conditional period, you receive an automatic refund to your original payment method. No manual request is required.
Massachusetts: Tax Headwinds and Three-Tier Stratification
Massachusetts transitioning from “legislative silence” (2021-2024) to codified regulation via House Bill 1930 (proposed effective July 1, 2027). “Fair Share Amendment” = 4% surtax on income >$1M (9% effective rate) creates “Massachusetts Premium”—$140,000 extra on $2M offer vs. zero-tax states. Boston College: “Max Cap” $20.5M commitment; “Friends of the Heights” raised $2.4M in 3 weeks; GM Kenyatta Watson hire signals NFL-style professionalization; $50M challenge gift campaign. UMass: MAC transition; merged collectives into “The Massachusetts Collective”; $1-2M “Tier 1 G5” budget; “Double Penalty” of settlement cost without upside. Harvard/Ivy League: Opted OUT of revenue sharing (Jan 2025); “Influencer” platform for third-party deals. MIAA Rule 47.1.3 (Aug 2022) permits high school NIL with IP Ban—creates “NIL-literate” pipeline.
For college athletes ready to maximize their NIL potential, RallyFuel provides fan-powered support with conditional protection. Explore verified Massachusetts athletes and start fueling today.


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