Last mentioned: Mar 20, 2026
FTC Guidance Issued
The FTC announces it will accept old forms but allow voluntary submission of new forms.
Fifth Circuit Denies Stay
The appellate court refuses to pause the vacatur, reinstating the pre-2025 filing forms immediately.
District Court Vacatur
A lower court rules the 2025 HSR requirements are invalid and vacates the rule.
New HSR Rules Effective
The FTC's expanded premerger notification requirements go into effect, increasing disclosure burdens.
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.