ABSTRACTThe article analyzes aspects of the change in the legal nature of private healthcare from “for-profit” to “non-profit” entities. It is an exploratory research, supported by the policy analysis framework, focusing on secondary data from theCadastro Nacional de Estabelecimentos de Saúde(National Registry of Health Facilities – CNES) from 2012 to 2020 and a case study. The results show an increase in these entities in all regions of the country and evidence that they behave like profit-oriented entities. The change in legal nature hides a broader process of implicit commodification of healthcare services, encouraged by state policies and related to exemptions provided by law.