This is an update to our February 23, 2026, client alert on the legal challenge to the Federal Trade Commission’s (FTC’s) expanded Hart-Scott-Rodino Act (HSR) form.
On March 19, 2026, the Fifth Circuit denied the FTC’s motion for a stay to keep the FTC new HSR rules in effect pending appeal. The district court’s vacatur of the FTC rules implementing the expanded HSR form is effective immediately. For the time being, the FTC’s Premerger Notification Office will accept HSR filings under both the prior (pre-February 2025) and new HSR form and instructions. We will provide further updates when and if the FTC changes this policy.
Click here to read the full Insight: "Just Like That: New HSR Form Vacated; Old Form Reinstated."
