FTC raises HSR premerger threshold to $133.9 million
→Deal teams must apply $133.9m HSR trigger for closings after effective date
Change
US FTC raised the HSR size-of-transaction reporting threshold to $133.9 million for 2026, applying to transactions closing 30 days after Federal Register publication.
Why it matters
HSR filing applicability now turns on the new $133.9m threshold for closings after the effective date. Deal teams must reassess in-flight transactions based on closing timing rather than signing date, and update filing-fee schedules.
Implications
- → M&A legal teams must apply the $133.9m threshold for post-effective-date closings — using the old threshold risks missed mandatory HSR filings
- → Deal teams must re-evaluate all in-flight transactions with closing dates after the effective date — filing obligations may change at close
Unlock the full brief.
Implications — what this change may force you to review
Who is affected — which people, workflows, or obligations are touched
What to watch — dates, deadlines, and triggers that matter next
Real-time alerts — delivered when a decision-forcing change is published
Clarify with AI — ask what this change means for you
Start free trial
No credit card · $29/month after trial · Active in seconds
Source
View on FTC