Illinois Expands Attorney General Review of Healthcare Transactions

On August 7, 2026, Illinois’ Democratic Gov. JB Pritzker signed House Bill 5000 (HB 5000 or Public Act 104-0782) into law, significantly expanding the requirement that parties to healthcare transactions notify the Illinois Attorney General before closing. The bill makes three principal changes to Illinois’ healthcare transactions law: (1) It broadens the definition of a “covered transaction” to reach more types of transactions, (2) explicitly incorporates transactions involving private equity sponsors that directly or indirectly own healthcare entities, and (3) makes the law, which was previously set to expire on January 1, 2027, permanent. Illinois is the latest in a growing wave of states revising previously enacted healthcare transaction review laws to more explicitly cover private equity, following measures such as California’s recently enacted AB 1415, discussed in our prior Update here (all laws are reviewed on our Tracker here).

Additional details regarding the three primary changes implemented by HB 5000 are as follows:

1. Expansion of a “covered transaction.” Previously, Illinois law covered only “any merger, acquisition, or contracting affiliation between 2 or more health care facilities, or provider organizations ...” (emphasis added). HB 5000 expands coverage to any transaction “involving” these entities (emphasis added). The statute now clarifies that more transactions are captured: “even if the parties to the transaction are not themselves a health care facility or provider organization but own or control, directly or indirectly, one or more of the 2 or more health care facilities or provider organizations ... including if parties to the covered transaction are private equity companies.”
2. Explicit coverage of “private equity.” Private equity transactions are now expressly covered by HB 5000, including indirect and partial ownership transactions. Specifically, the law defines private equity as “any company or partnership that collects capital investments from individuals or entities and purchases, as a parent company, at any level of corporate ownership, or through another entity or entities so that the company completely or partially owns or controls a direct or indirect ownership share of an Illinois health care entity or an out-of-state health care entity that generates $10,000,000 or more in annual revenue from patients residing in this State” (emphasis added).
3. Making the law permanent. The original Illinois healthcare transaction law had a January 1, 2027, sunset. HB 5000 removes the sunset and makes the provisions permanent.

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The law is scheduled to take effect on January 1, 2027. Private equity sponsors and healthcare platforms should closely review their current or proposed transactions for compliance with these new requirements.