Washington recently became the first state to adopt the Uniform
Antitrust Premerger Notification Act (UAPNA) and establish,
effective July 27, 2025, a general state-level premerger
notification requirement for all transactions. While several states
already require premerger notifications for certain healthcare
industry transactions, Washington will become the only state with a
broad premerger notification system applicable to any industry.
The UAPNA, which was published by the Uniform Law
Commission in 2024, requires parties filing a federal premerger
notification under the federal Hart-Scott-Rodino (HSR) Act to
provide a copy of their HSR filing to the enacting state's
attorney general if they have sufficient nexus to the state based
on sales or location. The Washington law, Senate Bill 5122, adopts the UAPNA's model
notification requirements for transactions in any industry, while
adding a heightened notification requirement specific to
transactions involving
