Hart-Scott-Rodino Resources

In February 2025, new rules went into effect for reporting transactions under the Hart-Scott-Rodino Antitrust Improvements Act, commonly called the “HSR Act.” In February 2026, a federal court in Texas held that the new HSR rules are invalid and ordered that the rules be vacated; however, this ruling has been appealed, and the Fifth Circuit Court of Appeals has ordered that the new rules remain in place “until further order of our court.”  Therefore, the new HSR rules continue to remain in place unless and until the Fifth Circuit directs otherwise.

The new HSR rules are complex and can be challenging to understand — let alone apply — in certain cases. To help clients understand the new reporting rules, Foley has prepared the following resources. But if you ever have any questions about the HSR Act, please do not hesitate to contact a member of the Foley & Lardner’s HSR Team or your primary Foley & Lardner attorney.

1. HSR Rules for Overlap and Supply Relationships Descriptions
2. NAICS Code Reporting Requirements
3. HSR Rules for Select 801.30 Transactions
4. Business Document Requirements Under HSR Rules
5. Prior Acquisitions Requirements Under HSR Rules
6. The “Subsidies” And “Countervailing Duties” Requirements Under HSR Rules
7. The “Defense or Intelligence Contracts” Requirement Under HSR Rules

In addition, we provide the following resources:

• Foley & Lardner summary of district court decision finding HSR rules invalid
• A blank HSR form for buyers
• The official HSR instructions for buyers
• A blank HSR form for sellers
• The official HSR instructions for sellers
• Foley & Lardner summary of the recent HSR changes
• Foley & Lardner summary of current HSR filing thresholds
• Comments submitted by Foley & Lardner in response to proposed HSR changes