Editor’s Note: This article is part of ComplexDiscovery’s ongoing monthly reporting on Hart-Scott-Rodino (HSR) transaction trends. It offers a concise analysis of April 2025’s rebound in deal volume, explores the broader economic and policy context, and provides actionable insights for cybersecurity, information governance, and eDiscovery professionals navigating an increasingly volatile M&A environment. The inclusion of historical transaction comparisons and professional implications underscores the continued importance of regulatory agility and strategic foresight.


Content Assessment: April 2025 HSR Rebound: Regulatory Shifts, Tariff Tensions, and M&A Impacts

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Background Note: The Hart-Scott-Rodino (HSR) Act established the Premerger Notification Program, requiring certain mergers and acquisitions to be reported to the Federal Trade Commission (FTC) and the Department of Justice (DOJ) for antitrust review. This program ensures that transactions meeting specific thresholds are evaluated for their potential impact on competition before they are finalized. The HSR filing process plays a critical role in preserving competitive markets by identifying and addressing potential risks, such as monopolistic practices or reduced consumer choice.

Under the program, companies must submit detailed documentation about the transaction and the parties involved. A waiting period—typically 30 days—follows, allowing regulators to review the deal and determine whether further investigation is needed. This process can impact transaction timelines and requires robust compliance and information governance frameworks to manage the regulatory requirements.


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April 2025 marked a period of measured recovery in Hart-Scott-Rodino (HSR) reportable transactions, following a notable decline in March. This rebound unfolded against a backdrop of significant regulatory change and the announcement of new U.S. tariffs that have introduced heightened uncertainty into the mergers and acquisitions (M&A) landscape. The U.S. economy itself experienced a contraction in the first quarter of 2025, but consumer fundamentals remained relatively resilient despite broader volatility.


HSR Transaction Activity: Patterns and Volatility

HSR transaction activity in April reflected both the episodic nature of recent dealmaking and the impact of the evolving regulatory and policy environment. According to official data, there were 117 HSR-reportable transactions in April 2025, a decrease from the 162 transactions recorded in April 2024, but a marked increase from the 89 transactions seen in March 2025. Over the past 12 months, monthly transaction volumes have fluctuated widely, with a high of 233 transactions in November 2024 and a low in March. February 2025 also saw a surge, with 230 transactions, underscoring the volatility that has characterized the market in recent quarters.

To provide additional perspective, Chart 1, “HSR Act Annual Transactions Reported in Fiscal Years 2000 – 2025,” offers a long-term view of annual transaction volumes. This historical context highlights the cyclical nature of M&A activity and underscores how current volumes compare to those seen over the past quarter-century.


Chart 1: HSR Act Annual Transactions Reported in Fiscal Years 2000 – 2025

HSR Act Merger Transactions Reported - April 2025

A closer look at the current fiscal year is presented in Chart 2, “Monthly HSR Act Transactions Reported in the Fiscal Year 2025 (October-September).” This chart details the monthly ebb and flow of transactions, making clear the sharp dip in March and the partial recovery in April. When set alongside Chart 3, “Monthly HSR Act Transactions Reported in the Fiscal Year 2024 (October-September),” it becomes evident that the 2025 pattern diverges from the steadier transaction activity observed in the previous year, reflecting the influence of recent regulatory and policy shifts.


Chart 2: Monthly HSR Act Transactions Reported in the Fiscal Year 2025 (October-September)

HSR Act Merger Transactions Reported - FY 2025 - April 2025

Chart 3: Monthly HSR Act Transactions Reported in the Fiscal Year 2024 (October-September)

HSR Act Merger Transactions Reported - FY 2024 - Final

For further context, Chart 4, “Monthly HSR Act Transactions Reported in the Fiscal Year 2023 (October-September),” provides a baseline for understanding pre-2024 transaction dynamics. This comparison helps to underscore the extent to which both regulatory and economic factors have contributed to the heightened volatility seen in the current environment.


Chart 4: Monthly HSR Act Transactions Reported in the Fiscal Year 2023 (October-September)

HSR Act Merger Transactions Reported - FY 2023 - Final

External Shocks: Policy Changes and the Pandemic

Chart 5, “Monthly HSR Act Transactions Reported in the Fiscal Year 2020 – Initial Pandemic Economic Impact in April and May,” revisits the pronounced decline in transactions during the onset of the COVID-19 pandemic. This historical episode serves as a reminder of how external shocks, whether public health crises or sudden policy changes, can dramatically affect transaction volumes. The recent volatility following the announcement of new tariffs closely parallels the sharp declines seen during the pandemic, highlighting the correlation between abrupt policy shifts and market disruption.


Chart 5: Monthly HSR Act Transactions Reported in the Fiscal Year 2020 – Initial Pandemic Economic Impact in April and May

HSR Act Merger Transactions Reported - FY 2020 (Pandemic Impact)

Regulatory and Policy Developments

New HSR rules that took effect in February 2025 have raised filing thresholds and expanded the documentation and narrative requirements for premerger notifications. These changes, combined with increased filing fees and ongoing legal uncertainty, have contributed to short-term swings in deal volume as market participants adjust to the new compliance landscape.

The announcement of new U.S. tariffs in late Q1 and early Q2 2025 has further complicated the M&A environment. The tariffs, which include a 90-day implementation pause for most trading partners, have led many dealmakers to delay or reconsider transactions, particularly those with significant cross-border or import-dependent components. Early indications suggest that this policy shift has introduced additional caution into the market, as companies reassess supply chain exposures and cost structures in light of potential trade disruptions.

Economic Context and Inflationary Pressures

Macroeconomic conditions have also played a role in shaping transaction trends. The U.S. economy contracted at an annual rate of 0.3 percent in the first quarter of 2025, reversing the 2.4 percent growth recorded in the previous quarter. This contraction was driven largely by a surge in imports and a reduction in government spending, which offset gains in consumer expenditures, investment, and exports. Inflationary pressures persisted, with the price index for gross domestic purchases rising 3.4 percent in the first quarter, up from 2.2 percent in the prior period. The Personal Consumption Expenditures price index climbed to 3.6 percent, and core PCE reached 3.5 percent. In March, PCE inflation was flat on a monthly basis, while year-over-year headline and core inflation registered at 2.3 percent and 2.6 percent, respectively.

Professional Implications: Cybersecurity, IG, and eDiscovery

For legal, compliance, and technology professionals, these developments carry important implications. The ongoing reliance on foreign-sourced digital components continues to pose cybersecurity and supply chain risks. However, the 2025 tariff environment is accelerating a shift toward reshoring, nearshoring, and diversification, as U.S. organizations seek to reduce their dependence on overseas suppliers for critical digital components. This transition makes rigorous third-party risk assessments and supply chain security audits essential. Information governance teams face greater regulatory scrutiny and evolving compliance requirements, especially with respect to cross-border data flows and post-merger disclosures. At the same time, the episodic nature of M&A activity and the prospect of increased regulatory inquiries are likely to drive demand for agile, AI-enabled eDiscovery workflows capable of handling rapid changes in transaction pace and complexity.

Strategic Resilience Amid Uncertainty: Navigating What’s Next

April 2025 underscores both the fragility and resilience of the U.S. M&A environment. The rebound in HSR transactions, set against a backdrop of economic contraction and new tariff announcements, highlights the need for agility and diligence among legal, compliance, and technology professionals. As regulatory changes and trade policy developments continue to unfold, continued volatility in transaction volumes and compliance requirements should be expected in the months ahead.



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