HSR Filings Hit 203 in March 2026 as Court Overturns Expanded Form and GDP Slips to 0.5%

Key Takeaways

• 203 HSR filings in March 2026, 128% YoY increase.
• Court restored legacy HSR form on March 19, ending compliance burden.
• Q4 2025 GDP grew only 0.5%, indicating fragile macro backdrop.
• 2026 jurisdictional thresholds rose 6%, slightly reducing filing pool.

Pulse Analysis

The March 2026 court ruling that vacated the 2025 expanded Hart‑Scott‑Rodino (HSR) form removed a major compliance hurdle for practitioners. By reverting to the familiar legacy form, legal teams could file without the extensive narrative requirements that had slowed submissions throughout 2025. This regulatory reset not only explains the sharp rise in filings but also sparked a joint FTC‑DOJ public inquiry, inviting stakeholders to weigh the benefits of richer data against the operational costs of a more burdensome form. Firms now face a near‑term window to influence potential rulemaking while adjusting their internal workflows to the restored baseline.

Even as filing numbers recover, the broader economic backdrop remains tenuous. The Bureau of Economic Analysis reported that real GDP grew at a meager 0.5% annualized in Q4 2025, a slowdown driven by a partial federal shutdown and lingering inflation above the Fed’s 2% target. Such weak growth typically dampens financing conditions and buyer confidence, especially for mid‑market transactions that rely on tighter credit spreads. Nonetheless, large‑cap deals continue to thrive, with a quarter of HSR filings exceeding $1 billion and high‑value transactions up 76% year‑over‑year, underscoring a K‑shaped recovery where well‑capitalized acquirers press ahead while smaller players stay cautious.

Looking ahead, the 2026 jurisdictional thresholds increased by roughly 6%, lifting the minimum transaction size to $133.9 million and the large‑deal benchmark to $535.5 million. While this modestly trims the pool of mandatory filings, it also raises the stakes for transactions that remain subject to review, especially given the FTC’s daily civil penalty of $53,088. Legal operations should embed scenario planning for another possible form revision, monitor the May 26 comment deadline, and align compliance roadmaps with both the higher thresholds and the evolving macro‑economic signals. Proactive engagement now can mitigate future compliance shocks and help firms capitalize on the underlying resilience in deal demand.