NFL (and CBA) Expansion

The NFL is set to host a record nine international games across four continents and seven countries during the 2026 season.[1] Recently, the League staged games in Melbourne, Australia, and Rio de Janeiro, Brazil, requiring the Los Angeles Rams and Dallas Cowboys to travel nearly 8,000 and 5,000 miles, respectively. These games now represent more than NFL expansion, as they materially alter the working conditions associated with an NFL season.

Where the Current CBA Stands on International Expansion
Although the current Collective Bargaining Agreement “CBA” anticipated some of the concerns associated with international travel, the NFL’s increasingly global schedule has introduced new challenges did not exist when the agreement was negotiated. Article 32, Section 5 expressly states that “[t]hrough the 2025 season, no more than ten regular season international games will be played each season unless a Club is displaced from its existing stadium due to damage, other force majeure events, construction or renovation.”[2] The CBA further requires the NFL and NFLPA to revisit whether the maximum number of international games in a single regular season should exceed ten beginning in 2025 or in subsequent seasons.[3] In May of 2026, NFL owners approved the full ten-game international allotment permitted under the CBA.[4] However, the NFL and the NFLPA have yet to have any substantive discussions about the possibility of scheduling more than ten international games.[5]

Beyond this restriction, the CBA acknowledges the broader consequences of international expansion. In determining whether to increase the number of international games, the agreement provides that “[s]uch decision may be based on underlying business justifications, including but not limited to growth in AR, club and player brand development, media and related opportunities, as well as player working conditions, health and safety, burdens on player families, insurance, housing, and/or tax-related issues.”[6] Current NFLPA Executive Director J.C. Tretter spoke directly to these concerns in September of 2026 after field conditions in Rio de Janeiro raised questions before the Cowboys-Ravens game. Tretter explained that the incident “reinforces one of our concerns about international expansion” and cautioned that, although the NFL has made clear its desire to continue growing the game internationally, “growth alone cannot be the goal.”[7] Rather, he emphasized that international expansion must occur while maintaining the standards players are entitled to expect.

What Else Needs to Be Considered Under the new CBA?
Fixing the number of permissible international games does not resolve whether the CBA is adequately protecting players from the burdens associated with those games, especially since Commissioner Roger Goodell has identified sixteen international games per season as the League’s long-term goal.[8] As NFL enters increasingly distant markets, the parties should consider not only how many international games may be played, but also where those games are played and the corresponding demands placed on players.

Let’s look at the NFL’s game in Melbourne, Australia on September 10, 2026. Both the 49ers and Rams faced roughly 15-16 hours of air travel, yet the teams adopted almost opposite approaches to preparing their players.[9] A similar situation is unfolding ahead of the Philadelphia Eagles’ matchup with the Jacksonville Jaguars in Tottenham, London on Sunday, October 11, 2026. Jacksonville will play back-to-back home games in London, remaining overseas for their October 18 matchup against the Houston Texans. Meanwhile, the Eagles and head coach Nick Sirianni plan to have the team practice in Philadelphia throughout the week and arrive in London on Saturday morning.[10]

International travel introduces new variables to player safety, including disrupted sleep cycles, reduced recovery time, and other logistical struggles (such as field quality) that affect health and preparation. Yet, as it currently stands, there is little guidance governing how clubs should structure internation travel or account for these additional burdens. The NFL’s chief medical officer, Allen Sills, even admitted that the league did not have enough data to prefer a particular strategy on international travel.[11] Accordingly, J.C. Tretter and the NFLPA should seek protections that ensure players receive adequate time to prepare and recover while competing abroad. With the current CBA set to expire in March of 2031, international travel should be among the most important player-safety issues addressed in negotiations.

[1] https://operations.nfl.com/programs-initiatives/international-growth/nfl-international-games.

[2] NFL Collective Bargaining Agreement, Pg. 192.

[3] Id.

[4] https://www.nfl.com/news/nfl-owners-approve-playing-up-to-10-international-games-beyond-2026-season.

[5] https://frontofficesports.com/article/nfl-nflpa-havent-discussed-more-than-10-international-games/.

[6] Supra note 2.

[7] https://nflpa.com/press/statement-from-nflpa-executive-director-jc-tretter-on-field-conditions-in-rio-brazil-ravens-cowboys.

[8] Supra note 4.

[9] The 49ers arrived one week before the game in Melbourne, while the Rams flew in only one day before.  https://www.abc.net.au/news/2026-09-10/nfl-rams-49ers-melbourne-jet-lag/107135424.

[10] https://sports.yahoo.com/articles/nick-sirianni-reveals-controversial-travel-001453862.html.

[11] Id.

J.D. Candidate at  | jcsteven@buffalo.edu | + posts

J.D. Candidate at the University at Buffalo School of Law, Class of 2027.
President, Buffalo Sports and Entertainment Law Society.
Executive Editor, Buffalo Law Review.
Former NCAA Athlete.

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