As of February 10, 2025, the new Hart-Scott-Rodino (HSR) reporting requirements that expand the volume of documents and information filing parties must submit to the Department of Justice and Federal Trade Commission (FTC) are effective for all transactions that meet the HSR thresholds. The new HSR filing requirements, which the FTC unanimously voted to adopt in October 2024, are a significant expansion of prior HSR reporting requirements and the FTC estimates that parties will spend up to 121 additional hours preparing their filings. Parties considering an HSR reportable transaction should engage antitrust counsel early in the diligence process to avoid HSR-related delays.
To determine whether a transaction is HSR reportable, reference the latest thresholds, which go into effect on February 21, 2025.