On Jan. 14, 2026, the Federal Trade Commission (FTC) announced the annual changes to the notification thresholds for filings under the Hart-Scott-Rodino Antitrust Improvements Act (HSR) and certain other values under the HSR rules. The new thresholds will become effective on Feb. 17, 2026.
State antitrust enforcement is becoming increasingly significant, with a diverse array of laws across 51 jurisdictions, including the District of Columbia. State Attorneys General (AGs) are not merely filling gaps left by federal enforcement but are actively shaping the landscape with robust state-specific laws. This post provides an overview of the current trends and legislative developments in state antitrust enforcement that businesses need to be aware of as they assess their conduct and develop growth strategies.
When the words “Hart Scott” or “HSR” are mentioned, business executives and deal lawyers often react with indifference. While they recognize the necessity of HSR compliance before closing a transaction, it typically garners little attention unless the deal is expected to face intense scrutiny. The goal is usually to check the HSR box and move forward.
This attitude has shifted recently as the government itself has focused attention on HSR. Over the past few months, the federal government has brought a couple of notable enforcement actions for HSR violations, and the HSR form itself has changed significantly, forcing people to pay closer attention to HSR than perhaps ever before.
On Jan. 10, 2025, the Federal Trade Commission (FTC) announced the annual changes to the notification thresholds for filings under the Hart-Scott-Rodino Antitrust Improvements Act (HSR) and certain other values under the HSR rules. The new thresholds will become effective in late February, 30 days after publication in the Federal Register.
