By May 2026, 41 states plus Guam and the US Virgin Islands have joined the Nurse Licensure Compact. The remaining holdouts are California, New York, Illinois, Oregon, Nevada, Michigan, Minnesota, Hawaii, Alaska, and the District of Columbia. None of these jurisdictions lack the technical capacity to participate — every one of them already runs a fingerprint-based background check program and a functional nursing board. What keeps them out is politics: organized labor opposition, legislative committee gatekeeping, FBI procedural disputes, and a recurring state-sovereignty argument. This post walks the ten holdouts honestly, names the actors, and notes which bills are still alive in 2026.
The Union-Opposition Bloc: California, Illinois, New York
Three of the largest holdout states share the same primary obstacle — a powerful state nurses' union that has lobbied legislators against compact membership for more than a decade.
- California (CNA / National Nurses United). The California Nurses Association and its national affiliate NNU argue that compact membership forces California to recognize licenses issued under lower standards elsewhere, and that the compact functions as a workforce-supply tool that suppresses wages and dilutes union density. AB-410 (2021-2022) died without a floor vote. No active NLC bill is pending in the 2025-2026 session.
- Illinois (INA / NNU). The Illinois Nurses Association opposes the NLC on similar grounds, framing it as a measure that exports Illinois nursing jobs and undercuts collective bargaining leverage. Multiple bills are technically alive in 2026 — HB 1622, HB 4434, SB 0041, SB 2795 — but each has stalled in committee. The Illinois Health and Hospital Association supports passage; the unions have so far prevented it.
- New York (NYSNA). The New York State Nurses Association makes the most detailed public case against the compact: NY requires infection-control and child-abuse-identification coursework that most NLC states do not, and NYSNA argues compact recognition would functionally lower NY's standards. Governor Hochul's FY 2025 and FY 2026 budget proposals to join the compact were rejected by the Legislature. S3916, A04524, A03391, A06421, A07946, S06873 are all pending in 2026, mostly parked in Higher Education committees.
The Legislative-Inertia Bloc: Michigan, Minnesota, Hawaii
The next group has no single dominant opposition force — bills get introduced, hearings happen, and then sessions end without floor votes. Inertia, not active opposition, is the story.
- Michigan — HB 4246 (2025-2026). Michigan has introduced NLC legislation in three consecutive sessions. The Michigan Nurses Association is opposed, but the bigger problem is calendar pressure: NLC bills sit behind larger health-policy priorities and run out of session days.
- Minnesota — SF 2608, HF 1005, SF 3281. The Minnesota Nurses Association opposes the compact, but the legislative pattern is the same — bills move out of one chamber and stall in the other, or get attached to omnibus bills that fail for unrelated reasons.
- Hawaii — HB 897. Hawaii's geographic isolation is the recurring argument against urgency: legislators ask why a multistate license matters for a state with no land border. The Hawaii State Center for Nursing has supported the bill in testimony; it has not moved to a floor vote.
The State-Autonomy Bloc: Oregon, Nevada
Oregon and Nevada both have legislative histories of explicit rejection rather than passive stalling, and both ground their opposition in state-sovereignty language.
- Oregon. The Oregon State Board of Nursing has historically argued that the compact removes the Board's ability to set licensure standards higher than the NLC's Uniform Licensure Requirements. There is no pending NLC bill in Oregon's 2025-2026 session.
- Nevada. Nevada's most recent NLC bill was defeated in February 2021. The Nevada State Board of Nursing's stated concern was loss of investigative jurisdiction over nurses practicing on a multistate privilege from another state — a real but solvable issue that the compact's coordinated investigation rules address. No bill is pending in 2026.
The Federal-Authority Holdouts: Alaska and DC
Alaska and the District of Columbia each face a distinct structural issue.
- Alaska. Alaska has introduced NLC legislation repeatedly. The recurring obstacle is the same one that delayed Pennsylvania for four years — FBI authorization for the state's criminal-background-check statute. The FBI requires specific statutory language authorizing fingerprint-based national background checks for compact applicants, and Alaska's existing statute does not satisfy that requirement. A bill addressing the language is pending in 2026.
- District of Columbia. DC is not technically a state and faces a separate procedural path. The DC Board of Nursing has expressed support, but compact entry requires Council action and has not been prioritized. There is no active NLC bill in DC's 2026 session.
What "Pending" Actually Means in 2026
NCSBN's pending-legislation map shows active bills in Alaska, Hawaii, Illinois, Michigan, Minnesota, and New York. The presence of a bill does not predict passage — Illinois has had multiple bills active in every recent session, and none have passed. The states most likely to move in the 2026-2027 window are Michigan and Alaska: Michigan because the Hospital Association and Michigan Health & Hospital Association have built a sustained legislative push, and Alaska because the FBI-language fix is a narrow technical change rather than a contested policy debate. New York and Illinois will likely remain stalled as long as their state nurses' unions hold their current positions.
What This Means for RNs and LPNs in Holdout States
If you live in one of these ten jurisdictions, your license remains a single-state license in 2026. To work in a compact state, you have two options: licensure by endorsement in the destination state (a one-time process taking 4-12 weeks depending on the state, with fees from $100 to $300), or — if you are willing to relocate — establishing primary state of residence (PSOR) in a compact state, which then opens compact privileges to all 41 NLC states. Travel-nursing agencies routinely sponsor endorsement applications for assignments in compact states, so the practical impact for short-term work is smaller than the political picture suggests.
Sources: NCSBN — Licensure Compacts; Nurse Licensure Compact (overview and legislative history); National Nurses United — Illinois NLC Opposition Fact Sheet; New York Senate Bill S3916 (2025-2026); Illinois Policy — Nurse Shortage Fix Blocked by Unions.
The honest read on the holdout map is that NLC membership is no longer a question of whether the compact "works" — 41 states demonstrate that it does. It is a question of whose interests prevail in each capitol: the hospital associations and workforce groups who want labor mobility, or the state nurses' unions who see the compact as a wage-suppression mechanism. Both readings have evidence behind them. In 2026, the unions are still winning in the largest holdout states, and that is unlikely to change without a shift in the underlying labor politics.
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