Legal MSO Regulation Tracker — Primary Sources
Primary-source index of professional rules, statutes, ethics opinions, and authorization programs relevant to legal MSO analysis.
Legal MSO Regulation Tracker
Statuses were checked August 27, 2026. This is a research index, not a compliance conclusion. ABA Model Rules are models; each jurisdiction's adopted rules, statutes, orders, and decisions control.
Federal and model authority: ABA Model Rule 5.4 addresses professional independence and fee sharing. The FTC Franchise Rule may apply based on the facts of a branded operating relationship.
Colorado: HB 26-1421 was enacted in 2026 and became effective August 12, 2026.
California: AB 931 was signed October 10, 2025 and became effective January 1, 2026. It addresses specified fee sharing with out-of-state alternative business structures and specified service arrangements; it is not a comprehensive MSO statute.
Illinois: HB 5487 was approved by the Governor August 7, 2026 and became Public Act 104-0801.
Texas: Opinion 706 concludes that the percentage-of-revenue arrangement presented would violate Texas Rule 5.04(a). It discusses alternatives but does not approve every arrangement using those labels.
Arizona, Utah, and Washington operate distinct authorization or pilot frameworks. Those frameworks should not be treated as interchangeable with an MSO services agreement.
- ABA Model Rules of Professional Conduct
- FTC Franchise Rule — 16 CFR Part 436
- Colorado HB 26-1421
- California AB 931
- Illinois HB 5487 / Public Act 104-0801
- Texas Ethics Opinion 706
- Arizona Alternative Business Structures
- Utah Office of Legal Services Innovation
- Washington Supreme Court Order No. 25700-B-721