When a Texas federal court vacated the FTC’s proposed nationwide noncompete ban in August 2024, many employers exhaled. But as our colleagues wrote last December, the FTC’s interest in noncompetes did not disappear with its rulemaking authority; the agency simply reoriented toward case-by-case enforcement. We have written separately about how that enforcement campaign has evolved, and why filing a noncompete lawsuit may now invite federal scrutiny of an employer’s entire noncompete program.
This post focuses on a different dimension of the same story: the accelerating state legislative response. The result is a thickening patchwork of laws that, for multi-state healthcare employers in particular, has made noncompete compliance more complex—and more consequential—than at any point in recent memory.
The Scale of Change
At least twelve states have enacted healthcare-specific noncompete legislation since the August 2024 Texas court ruling. Our colleagues’ December 2025 post catalogued the first wave of that activity, covering eight states through early 2025. This post picks up where that survey left off.
The 2026 Class: Complete Bans and Partial Restrictions
Complete Bans
Virginia enacted the most comprehensive package of any state in 2026, signing three separate noncompete bills into law in May, all effective July 1, 2026.
Senate Bill 128 and its companion House Bill 627 categorically bar healthcare systems from imposing noncompetes on licensed healthcare professionals—...
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