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ARTICLE · 02 MARCH 2026

State-Level Merger Control Grows: California Joins "Mini-HSR" Trend With Senate Bill 25

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On February 10, 2026, California enacted Senate Bill 25 ("SB 25"), known as the California Uniform Antitrust Pre-Merger Notification Act.

United StatesAntitrust/Competition Law
Charlene Sun
Charlene Sun
Megan L. Wolf
Megan L. Wolf
Daniel Leff Esq.
Daniel Leff Esq.
Angel Prado
Angel Prado

What You Need to Know

  • Key takeaway
    #1SB 25 Expands Notification Requirements for Mergers with a California Nexus:
    Beginning January 1, 2027, parties that file a federal HSR notification and meet certain California-specific thresholds must also provide the filing to the California Attorney General within one business day of federal submission, with content requirements that differ depending on whether the threshold is met by principal place of business or net sales.
  • Key takeaway #2
    Interpretation and Compliance Complexity Remain:
    Although California's new law tracks the model bill and is similar to Washington's and Colorado's laws, key questions remain, such as how to identify which sales are "involved in the transaction" and whether certain filing fees will affirmatively be imposed, making further state guidance especially important.

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