The Revised HSR Rule Goes Live (For Now)

On February 10, 2025, the revised HSR Rule went into effect after the statutory 90-day Federal Register publication waiting period lapsed. All HSR filings will now have to conform to the revised Rule. The revised Rule is widely seen to increase filing requirements and burdens on filing parties.

Notably, the final Rule overhauls both the form and instructions for HSR filings. The final Rule requires the submission of new categories of documents and information, including certain ordinary-course documents, additional disclosures, and narrative descriptions of the parties' competitive activities and supply relationships, similar to antitrust premerger filing regimes in many other countries.

While some speculated that the revised Rule would be rescinded or at least delayed, the current split of Commissioners (two Republican and two Democratic) apparently prevented the new Administration from acting. Some practitioners, however, still believe that the Rule may be subject to change once the fifth Commissioner is confirmed by the Senate. President Trump has nominated Mark Meador, a former FTC and DOJ lawyer, for the position.  

On a more business-friendly front, the FTC has pledged to restart its Early Termination program in which filers in non-competitively sensitive deals can shorten the 30-day HSR waiting period.

Practical Guidance is updating our materials on the HSR filing requirements and will continue to monitor changes at the FTC. Get up to speed with the revised Rule.

For detailed information and analysis on the revised Rule, see Rule Revising Hart-Scott-Rodino (HSR) Filing Requirements Now in Force.  

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