HSR Rewind: The New HSR Rules Are Vacated and Parties Return to the Old HSR Form

Parties are no longer required to make HSR Filings using the new and more burdensome 2025 Hart-Scott-Rodino Form and Instructions (“2025 HSR Rules”). On March 19, 2026, the U.S. Court of Appeals for the Fifth Circuit (“Fifth Circuit”) denied the Federal Trade Commission’s (“FTC’s”) motion to stay pending its appeal of the district court’s judgment vacating the 2025 HSR Rules. The district court’s order is effective immediately.... By: White & Case LLP