Jeremiah Smith can't enter the NFL draft yet because the league's contract with its players' union bars a player from the draft until three NFL regular seasons have started and finished since he left high school. Smith's first college season was 2024, so 2026 is his third. That makes the 2027 draft the first one he can declare for.
This is why one of the best receivers in college football is still playing on Saturdays. Ohio State teammate Carnell Tate was in the 2026 draft, and Smith would potentially have been the top receiver in it if he had been allowed in. He had played only two seasons.
What does the rule actually say?
Most explainers sum it up as "three years out of high school." The actual text is in Article 6, Section 2(b) of the NFL–NFLPA collective bargaining agreement (CBA). It says no player can apply for "special eligibility," or otherwise be draft-eligible, until three NFL regular seasons have begun and ended after his high school graduation, or after his entering class's graduation, whichever is earlier.
The same section sets a few other ground rules. The draft has seven rounds and must be held between February 14 and June 2, on a date the commissioner picks.
How are the three years counted?
The rule counts NFL seasons, not birthdays or calendar years. Each of the three seasons has to start and end after the player graduates.
Graduating early doesn't speed things up. The CBA gives its own example: a player who graduated in December 2020 isn't eligible until the 2024 draft. The 2020 season was already underway when he graduated, so it doesn't count. His three seasons are 2021, 2022 and 2023.
For Smith, the count comes out the same whether he finished high school early or in the spring of 2024. The seasons that count are 2024, 2025 and 2026, so the 2027 draft is the first he can enter. (We couldn't confirm his exact graduation date from a primary source, but the result doesn't change.)
Age has nothing to do with it. Smith's birthday is Nov. 29. What matters is how many seasons have passed, not how old he is.
Is this a rule the NFL made up on its own?
No, and that difference has mattered in court. The rule is a term negotiated with the players' union, not a policy the league handed down by itself.
Ohio State has tested it before. Running back Maurice Clarett graduated from high school on Dec. 11, 2001 and was a season short of eligibility. He sued in September 2003, arguing that the rule violated the Sherman Act, the main federal antitrust law. In February 2004 a federal district judge ruled him eligible for that year's draft.
In May 2004 the Second Circuit Court of Appeals reversed that ruling. It held that the eligibility rules are protected by the "non-statutory labor exemption." Put simply, courts generally don't let antitrust law override terms that come out of collective bargaining between a league and its union. Clarett was eventually drafted in 2005, in the third round, 101st overall.
That 2004 decision is still the controlling appeals ruling. Whether a new challenge could succeed now that college players earn NIL money is an open question, and commentators disagree about whether the rule is fair.
Has the waiting period always been three years?
No. For much of NFL history, a player had to be at least four football seasons out of high school to be drafted. The league relaxed that to three in 1990.
The change didn't start out as a contract term. It came in a Feb. 16, 1990 commissioner's memo that limited special-eligibility applications to college players with three full college seasons behind them. When Clarett sued, the eligibility rules were in the NFL's constitution and bylaws, not in the CBA's text. Today the rule is written into Article 6 of the CBA.
What does a player have to do once he's eligible?
Becoming eligible doesn't put a player in the draft automatically. An underclassman has to petition the league for special eligibility, and he gives up his remaining college eligibility when he applies.
The deadlines come in January. For the 2026 draft, the NFL set an early deadline of Jan. 5, a standard deadline of Jan. 14, and a Jan. 23 deadline only for players on teams in the national championship game. That draft was held April 23–25 in Pittsburgh. The 2027 deadlines hadn't been confirmed in the sources we reviewed.
Plenty of players use this route. The NFL granted special eligibility to 54 players for the 2024 draft, including 20 who filed after the Jan. 5 deadline.
Has this happened to other Ohio State stars?
Yes, more than once. In 2023, receiver Marvin Harrison Jr. worked out at Ohio State's pro day but couldn't enter that draft because of the three-year rule. He was coming off a season with 77 catches, 1,263 yards and 14 touchdowns, and he became eligible in 2024.
Smith's wait looks a lot like Harrison's. Smith out-gained Emeka Egbuka, a first-round receiver, in yards and touchdowns as a freshman. Through Ohio State's first five games of 2026, he had 44 catches for 823 yards and nine touchdowns. PFF has projected him as a top-five pick in 2027 and credits him with just four career drops.
What has the wait meant for Smith off the field?
Because he couldn't go pro, college programs had another year to compete for him, and that came with real money. On3 valued Smith's Ohio State NIL deal at $5 million, fifth among college athletes.
At Big Ten Media Days, Smith confirmed he had been offered a reported $10 million to enter the transfer portal. He said leaving Ohio State "would be dumb." Michael Irvin said the reported offer came from Miami, near Smith's hometown of Miami Gardens.
Will he definitely be in the 2027 draft?
He hasn't committed to it yet. At Big Ten Media Days, Smith described 2026 as presumably his final college season, but he can't file a special-eligibility petition until the January deadline window. Until he does, staying is technically still possible.
Could the NFL change the rule?
Only through bargaining. The rule is part of the 2020 CBA, so the league would need to negotiate a change with the NFLPA. We didn't find any current proposal to do that.
The league also reads the eligibility rules strictly. In 2026 it declined to let quarterback Brendan Sorsby into the supplemental draft. ProFootballTalk argued that decision conflicts with Article 6, Section 2(c), which allows players who become eligible after the draft to be picked in a supplemental draft if the league holds one. Neither that provision nor anything else in the CBA gives a player a way around the three-season wait.