FTC Announces Annual Update to HSR and Section 8 Thresholds
Client Alert | 1 min read | 01.20.26
The Federal Trade Commission (FTC) has announced its annual updates to the thresholds and filing fees related to the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the HSR Act). These dollar thresholds are indexed annually based on changes in the U.S. gross national product and the Consumer Price Index.
The HSR Act requires that certain transactions be notified prior to their consummation. This year, the “size-of-transaction” threshold for reporting mergers and acquisitions under the HSR Act will increase from $126.4 million to $133.9 million. In addition, the “size-of-person” threshold, the filing fee thresholds, and the fee schedule will all also increase. The new filing fee thresholds and fee schedule are as follows:

The FTC also issued revised thresholds relating to the prohibition of certain interlocking directorates under Section 8 of the Clayton Act.
The revised thresholds will become effective 30 days after their publication in the Federal Register, which is expected in the next few days. Click here to read a full copy of the FTC's announcement, including a complete listing of the revised thresholds. Click here for a copy of the FTC’s announcement and information regarding the Clayton Act, Section 8 thresholds.
We would like to thank Associate Emil Zhang for their contribution to this alert.
Contacts
Insights
Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
Client Alert | 4 min read | 04.16.26
ROI Tracking as Mens Rea? Novartis Ruling Reframes AKS Pleading Risk




