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ARTICLE · 25 MARCH 2026

HSR Form Rollback: What Dealmakers Need To Know Now

Crowell & Moring LLP
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The Fifth Circuit denied the FTC’s motion for a stay pending appeal on March 19, 2026, giving immediate effect to the district court’s earlier ruling vacating the FTC’s 2024 revisions to the HSR form.

United StatesAntitrust/Competition Law
Lauren T. Fleming
Lauren T. Fleming
Megan L. Wolf
Megan L. Wolf
Ashley McMahon
Ashley McMahon
Connor Ahearn
Connor Ahearn

What You Need to Know

  • Key takeaway #1

    The Fifth Circuit denied the FTC’s motion for a stay pending appeal on March 19, 2026, giving immediate effect to the district court’s earlier ruling vacating the FTC’s 2024 revisions to the HSR form.

  • Key takeaway #2

    The old HSR form and instructions are now back in effect. Parties are no longer required to comply with the expanded 2024 filing requirements (for now).

  • Key takeaway #3

    The FTC’s Premerger Notification Office has confirmed it will continue to accept voluntary filings under the vacated 2024 form, though there is no obligation to do so.

  • Key takeaway #4

    The Fifth Circuit’s ruling does not resolve the appeal on the merits, and the FTC has not yet announced whether it will continue to pursue the appeal.

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