No 'Paws' in Oversight: Will New York’s Proposed Veterinary Transaction Review Law Take Effect in 2026?
In September 2025, the New York State Assembly introduced Assembly Bill A9042, which would require veterinary clinics to provide notice and undergo Attorney General review for certain “material change” transactions, such as mergers or significant asset transfers. Momentum is building in 2026, with the bill recently referred to the Agriculture Committee for review on January 7th. This initiative builds on New York’s 2023 action to regulate healthcare transactions by requiring notice to the Department of Health for similar changes, but it goes further by extending oversight to the veterinary sector. Unlike most states, which primarily regulate ownership through bans on the corporate practice of veterinary medicine, the law would require formal notice and Attorney General review of certain transactions in the veterinary industry. As private equity investment continues to reshape veterinary care, this proposal could signal a broader trend toward increased regulation in 2026, potentially making New York the first state to set this precedent and raising the question of whether others will follow. This post will examine the bill’s key provisions and explore how current state laws govern veterinary practice ownership across the United States.
Corporate Practice of Veterinary Medicine & New York’s Proposed Transaction Review Law
States’ regulations currently in place focus on ownership restrictions for veterinary practices, most notably through bans on the corporate practice of veterinary medicine (CPVM). Corporate practice of medicine (CPOM) bans in human healthcare prohibit non-physicians and corporate entities from owning or controlling medical practices. This same principle applies in CPVM bans: non-veterinarians or corporations are barred from owning or controlling veterinary practices. Prior to New York’s proposal, legislative efforts in the veterinary space largely mirrored this ownership-focused model rather than introducing transaction oversight. Most recently, Senate Bill 613 was introduced in the Texas legislature during the state’s 2024 legislative session, but the bill died in committee this past summer. The goal of S.B. 613 was to codify a CPVM prohibition and only permit ownership and control of veterinary practices by veterinarians. Several states have enacted CPVM bans. This includes New York, where under New York Education Law § 6706, only veterinarian-owned professional service corporations may be organized for and granted a license to practice veterinary medicine. Though this ownership restriction limits non-veterinarians from having control over clinical decisions, non-veterinarian management services organizations are often contracted with practices to provide administrative, operational, and business support to a practice.
Like CPOM prohibitions, CPVM prohibitions aim to protect a veterinarian’s clinical decision-making from improper corporate influence. Transaction review laws, to contrast, are focused on the broader market and the potential results of consolidation, including impact on consumers, cost of and access to care, and potential antitrust risks. Indeed, this is the focus of New York’s proposed veterinary transaction review law. Under the law, entities that acquire “veterinary clinics” through a “material change” transaction must submit notice of the transaction to the New York Department of Agriculture and Markets (Department) no later than 14 days after the parties have agreed to the transaction and prior to the consummation of any or all portions of the transaction. A “veterinary clinic” includes “a health care entity involving the practice of veterinary medicine,” such as a professional services corporation, a small practice, group, or management service organization. A “material change” includes transactions such as the sale, transfer, lease, or encumbrance of $200,000 or more in clinic assets or operations; mergers, acquisitions, changes in control, or affiliations with another clinic; and transactions that involve distributing or reducing, or creating an obligation to distribute or reduce, a veterinary clinic’s equity by $200,000 or more.
The Department would be charged with creating a process for notice and disclosure of transactions and with forwarding electronic copies of the notice to the Antitrust, Charities, and Health Care Bureaus of the New York Attorney General’s Office. The acquiring entity would be responsible for submitting a comprehensive set of disclosures. In addition to standard governing documents, such as its charters, bylaws, and shareholder agreements, fully executed transaction and ancillary agreements would need to be submitted, as well as pre- and post-transaction organizational charts. The statute doesn’t stop at basic governance and transaction documents—it also demands reports on subsidiary impact, asset contribution and management agreements, plus robust financial disclosures including audited statements, ownership records, and projections. Unique requirements include independent valuation reports, fairness opinions, and detailed disclosures of related-party transactions. Veterinary clinics must also provide valuations for non-cash consideration such as stock restrictions or membership interests. Additional obligations cover data on tax-advantaged debt and transactions with disqualified persons, a full litigation list with court captions, and community impact assessments on patient care and service access. These requirements go beyond typical corporate filings, emphasizing transparency on valuation, community impact of the transaction, and governance structure.
A key feature of Assembly Bill A9042 is that the Attorney General can prohibit acquisitions that it deems “against the public interest.” The Attorney General could consider the transaction to be against the public interest if the transaction would have the impact of reducing competition, increasing costs to pet owners, enabling unfair competition or deceptive acts or practices affecting “veterinary care commerce,” decreasing quality of care, or reducing access to care. This is a critical difference from New York’s Disclosure of Material Transactions Review Law, which does not empower the Attorney General to block the transaction. Notably, in its initially proposed form, the Disclosure of Material Transactions Law not only required DOH’s approval, but if DOH disapproved or approved the transaction subject to certain conditions, it could notify the New York State Attorney General’s Office (NYS Attorney General). The NYS Attorney General would have had authority to investigate the transaction to determine if the parties engaged in unfair competition or other anti-competitive behaviors. It remains to be seen whether the proposed veterinary transaction review law will advance as drafted or, as with the Disclosure of Material Transactions Law, require removal of its approval provisions.
Conclusion
According to reporting from the Atlantic, between 2017 and 2023, private equity investors channeled 51.6 billion dollars into the veterinary sector. Much like human healthcare, the industry is experiencing rapid consolidation. If New York enacts its proposed legislation, it would become the first state to pair two safeguards: the existing ban on corporate practice of veterinary medicine (CPVM) and a transaction review framework aimed at preserving fairness and transparency in the veterinary market. Whether New York sets this precedent in 2026—and whether other states follow suit—will be a key development to watch as consolidation pressures continue to reshape the profession.
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