Insights

In October 2024, the FTC adopted a final rule that substantially modified the HSR form, requiring new categories of information and documents. The final rule was the most significant overhaul of the HSR premerger notification requirements in decades. The new requirements imposed additional time and expense on merging parties, with the FTC estimating that the new form would likely take triple the amount of time to complete than the previous form. Numerous groups, including the U.S. Chamber of Commerce, sued to challenge the rule.

On October 16, 2025, the European Commission and the High Representative of the Union for Foreign Affairs and Security Policy presented their Defense Readiness Roadmap 2030 to the EU Member States. This comprehensive plan aims to strengthen European defense capabilities. It follows, and should be read together with, the Commission’s Defense Readiness Omnibus that was published in June 2025. The Omnibus contains a set of proposals to facilitate defense investments and boost EU Member States’ responsiveness to today’s security challenges.

Government contractors face a growing range of antitrust concerns that are unique to the industry—from how the FTC, DOJ, and DOD analyze defense mergers, to managing information sharing in prime/sub relationships, to navigating antitrust investigations involving classified information. Join us over the coming months for a new series on contractors and competition, where we will explore best practices for in-house counsel and procurement teams to reduce risk in this complex area.