No Pay, No Play: WWE’s New Non-Compete Policy

Professional wrestler Andrade El Idolo was released from World Wrestling Entertainment (WWE) in September 2025 following multiple reported wellness policy violations. He returned to rival promotion All Elite Wrestling (AEW) on the October 1 edition of their weekly television program Dynamite. However, he has yet to be seen again on television. Wrestling Observer’s Bryan Alvarez confirmed that WWE sent legal notice to AEW asserting that Andrade remains subject to a one-year non-compete clause because he was terminated “for cause.” AEW President Tony Khan has since declined to comment substantively on Andrade’s contractual status, stating only that he has “a ton of respect” for the wrestler and is “excited to see what’s next for him.” Reports indicate that Andrade is currently consulting with legal counsel and may challenge WWE’s enforcement of the clause.

Under WWE’s updated TKO-era contracts, performers fired for cause or breach of contract are now subject to a one-year non-compete restriction. This is in stark contrast to WWE’s longstanding practice of imposing 90-day paid non-competes, during which released wrestlers would receive compensation. The new clause reportedly states that upon termination for breach, the wrestler “shall not work, appear, or perform in any capacity” for any wrestling, sports entertainment, or mixed martial arts organization in the United States for up to one year. Alvarez emphasized that while the clause has existed in some older contracts, it is now “standard” across all new TKO deals. Fightful Select corroborated these reports but noted that “if fought in court, this would almost certainly be thrown out.”

Non-compete agreements in the United States generally require fair compensation during the restrictive period. Michael Morales, a legal analyst interviewed by Lucha Libre Online, explained that while non-competes lasting six months to two years are considered reasonable under Connecticut, Florida, and federal law, they must be accompanied by payment. “You can’t have a non-compete without compensation,” Morales stated. “Otherwise, it’s technically slavery, and slavery isn’t legal in the U.S. or anywhere else.” He clarified the distinction between a suspension (where the contract remains active, but the employee is temporarily barred from work) and a non-compete (where the contract has ended but the individual is restricted from working elsewhere).

In Andrade’s case, if WWE terminated his contract and is now preventing him from working without providing compensation, the arrangement likely violates basic employment law principles. Connecticut law, the jurisdiction where WWE is headquartered, requires that non-compete agreements be reasonable in duration and geographic scope, as well as protect legitimate business interests. Courts in the state assess whether the restriction imposes an excessive restraint on the employee’s ability to earn a living. An unpaid one-year ban on a professional wrestler pursuing his occupation would almost certainly fail this test.

WWE’s classification of wrestlers as independent contractors rather than employees creates a vulnerability for enforcement of the non-compete clause. WWE has maintained this classification for decades, despite exclusive contracts that restrict wrestlers from working for other promotions, mandatory appearance schedules, and extensive control over performance and character development. All of these are considered hallmarks of an employment relationship. The IRS uses a common-law test focused on the degree of control the company exercises over the worker. Factors such as exclusive contracts, company-dictated schedules, and prohibition on outside work strongly suggest employee status. This classification becomes particularly problematic when WWE attempts to enforce restrictive covenants. WWE cannot credibly maintain both that its wrestlers are independent contractors and that it can unilaterally prevent them from working for a full year after termination.

WWE has attempted to enforce aggressive non-compete clauses before and lost. In 2005, Brock Lesnar filed a lawsuit in federal court in Connecticut seeking a declaration that his non-compete agreement with WWE was unenforceable. After Lesnar’s departure from WWE in 2004, the company attempted to enforce a non-compete that would have prevented him from working in professional wrestling or mixed martial arts until June 2010, effectively a six-year restriction. Lesnar argued that the restriction was not reasonably tailored to protect WWE’s legitimate business interests and imposed an excessive restraint on his ability to support himself and his family. WWE ultimately settled the case in 2006, allowing Lesnar to return to professional wrestling with New Japan Pro Wrestling (NJPW) and begin his professional mixed martial arts career. The Andrade case presents a similar scenario. If WWE seeks to enforce a one-year unpaid restriction, Andrade’s legal team will likely argue, as Lesnar did, that the clause is overly broad, oppressive, and inequitable under Connecticut law.

While the Federal Trade Commission’s (FTC) proposed rule banning most non-compete agreements was struck down in 2024 and the agency has since withdrawn its appeal, the FTC has signaled that it will continue to pursue enforcement actions against unfair non-compete practices on a case-by-case basis. In September 2025, the FTC filed a complaint against a pet cremation company for imposing one-year nationwide non-competes on nearly all employees regardless of position, similar to WWE’s approach. The FTC’s continued focus on non-competes in low- and mid-wage industries suggests that aggressive restrictions in the entertainment sector could draw regulatory scrutiny, particularly when imposed on workers classified as independent contractors who lack traditional employee protections. For the wrestling industry, the Andrade case could establish important precedent. If Andrade successfully challenges WWE’s clause, it may embolden other wrestlers to contest similar restrictions and could pressure WWE to reconsider its contract practices. However, if WWE prevails, it could signal a shift toward greater corporate control over talent mobility in professional wrestling.

WWE’s attempt to enforce a one-year non-compete against Andrade El Idolo represents a notable escalation in the company’s contractual control over talent. While TKO’s corporate restructuring may have emboldened WWE to standardize such aggressive clauses, the legal foundation for enforcement is questionable. Non-compete agreements require fair compensation, must be reasonable in scope and duration, and cannot impose excessive restraints on an individual’s livelihood. If Andrade proceeds with litigation, this case could reshape how wrestling contracts are structured and force a long-overdue reckoning with WWE’s classification of its performers.

Calvin Holle is a 3L at the University of Missouri-Kansas City School of Law.  He can be found on LinkedIn and X.