According to the agencies, companies notified them of 2,006 transactions under the HSR Act in fiscal 2025, and about 31.8% were valued at more than $1 billion. The FTC and DOJ also took 18 merger-enforcement actions across healthcare, technology, energy, defense, consumer goods and services, labor, and manufacturing.

The filing picture is still deal-heavy

HSR notifications are the front door to federal merger review, so the annual totals matter for lawyers, bankers, and company executives planning deal timelines. The report is a fiscal 2025 scorecard, not a live count of 2026 activity.

The HSR form fight is still unresolved

The report says the updated HSR form went into effect on February 10, 2025, but a federal district court vacated it on February 12, 2026, and the Fifth Circuit later denied a stay. The agencies say the district court order is effective while the appeal continues.

For deal teams, that means filing prep still needs to track the court case and current FTC guidance. The practical question now is not whether merger review matters, but which filing format applies while the litigation plays out.

What to watch next: the appeal, any new rulemaking, and whether the agencies issue additional filing guidance.

Sources

• FTC press release: DOJ and FTC issue FY2025 Hart-Scott-Rodino annual report
• DOJ press release: DOJ and FTC issue FY2025 Hart-Scott-Rodino annual report