ARTICLE · 03 SEPTEMBER 2026
Transparency In Merger Enforcement: Second Request Review Timelines Continue To Drop In 2026
Over the last decade, investigation timelines for transactions subject to Second Requests soared. Before 2015, the average timelines for Second Request investigation regularly fell under eight months. By 2025, that average had climbed to over 12 months. Of course, these average timelines only cover time before the agency decides whether to challenge a transaction. For transactions subject to a complaint, the clock ran longer. And as dealmakers know, time is often the enemy of closing.
United StatesAntitrust/Competition Law
Key Findings
- The average length of time for agency-published outcomes of Second Request investigations fell to 9.9 months in the first half of 2026, a significant drop from record numbers above 12 months recorded for most of 2025. The average duration of Second Request investigations that ended without any agency statement came in even lower at 8.2 months. Together, these declines indicate that the Trump administration’s initiatives to streamline Second Request timelines are working, bringing Second Request timelines closer to averages last seen about a decade ago.
- The DOJ has been the main driver of shorter timelines so far this year. While DOJ timelines in 2025 remained high, perhaps due to a backlog of inherited investigations, newer investigations in 2026 are moving more quickly to resolution. By contrast, FTC Second Request timelines have remained relatively stable under the second Trump administration. Accordingly, while the average FTC investigation fell notably under the
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