Dramatic Changes To The FTC And DOJ's HSR Act Premerger Filing Requirements Have Arrived

On February 10, 2025, the Federal Trade Commission and Antitrust Division's new premerger notification form and requirements under the Hart-Scott-Rodino Act (HSR Act) will go into effect, despite the pendency of a lawsuit attacking the new notification form and filing instructions. Barring a last-minute reprieve, the new HSR form and requirements will become the most substantial update to the premerger program in over 40 years.^[1]

All mergers and acquisitions meeting the updated HSR filing thresholds must be filed using the Premerger Notification Office's new form.^[2] As a result, transacting parties should be prepared to submit substantially more information and documents to comply with the new HSR rules, all at increased time and costs.