New HSR Form Adopted For 2025

Parties to certain acquisitions are required under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the Act) to disclose information about the parties and their transaction to the Federal Trade Commission (FTC) and the Antitrust Division of the Department of Justice (DOJ). Earlier this year, the FTC, in concurrence with the DOJ, issued rules updating the premerger notification form used to disclose that information (HSR Form). Those rules were published in the Federal Register on November 12, 2024.

The new HSR Form will take effect on February 10, 2025, meaning notifications filed on or after that date must use the updated form. Additionally, the FTC announced that it will end the suspension on early termination of the 30-day waiting period once the new HSR Form becomes effective. The current suspension has been in place since February 2021.