Last mentioned: Mar 20, 2026
FTC Guidance Issued
The FTC announces it will accept old forms but allow voluntary submission of new forms.
FTC Guidance Issued
The FTC confirms it will accept legacy forms while its appeal proceeds.
Fifth Circuit Denies Stay
The appellate court refuses to pause the vacatur, reinstating the pre-2025 filing forms immediately.
Fifth Circuit Denial
The appellate court denies the FTC's stay request, reinstating the old filing regime.
District Court Vacatur
A lower court rules the 2025 HSR requirements are invalid and vacates the rule.
District Court Vacatur
A lower court finds the new HSR rules improperly promulgated and vacates them.
New HSR Rules Effective
The FTC's expanded premerger notification requirements go into effect, increasing disclosure burdens.
New HSR Rules Effective
The FTC's expanded premerger notification requirements officially take effect.
The U.S. Court of Appeals for the Fifth Circuit has denied the FTC's request to stay a lower court ruling, effectively suspending the rigorous 2025 HSR filing requirements. This decision provides immediate relief to dealmakers by reverting to the less-burdensome pre-2025 disclosure framework while the legal battle continues.
The U.S. Court of Appeals for the Fifth Circuit has denied the FTC's request to stay a lower court ruling, effectively vacating the 2025 HSR filing requirements. This decision reinstates the less burdensome pre-February 2025 framework, providing immediate relief to dealmakers while the agency's broader appeal proceeds.