Press Release

HSR Report Showed Early Terminations Are (Almost) Back  

On July 2, 2026, the Federal Trade Commission (FTC) and the Department of Justice (DOJ) released the 48th Annual Hart-Scott-Rodino (HSR) Report – for fiscal year (FY) 2025 – providing the first detailed look into merger activity and federal antitrust enforcement since early termination returned in February 2025. In a new insight, Director of Competition Policy Fred Ashton reviews the report’s key findings.

Key points:

  • Federal antitrust law requires companies to report large mergers and acquisitions to the FTC and the DOJ and to observe a mandatory waiting period before closing, though deals that raise no competitive concerns can close early through a grant of early termination.
  • The report showed 1,944 adjusted transactions were reported in 2025, a negligible downtick from the previous year; the trend of massive deals continued, however, with nearly a third of all reported transactions valued at more than $1 billion.
  • The data for FY 2025 confirm the return of early termination, which was indefinitely suspended in February 2021 before being restored in February 2025; the practice allows mergers and acquisitions that pose no competitive concerns to close before the mandatory waiting period expires and reflects the agencies’ ongoing effort to avoid unnecessary roadblocks for competitively benign transactions, ultimately lowering transaction costs.

Read the analysis.

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