Editor’s Note: This report examines U.S. Hart-Scott-Rodino (HSR) filings through June 2025, which reached 1,519 transactions for the fiscal year to date, including 157 filings in June. Despite GDP contraction and persistent inflation, M&A activity remains steady, reflecting strategic recalibration rather than retreat.
By linking transactional trends to broader economic shifts, this analysis offers critical insights for professionals managing secure and compliant deal execution. With cybersecurity, governance, and eDiscovery roles growing in strategic importance, understanding these dynamics is key to enabling successful transactions in a regulated environment.
Content Assessment: From Volatility to Vision: June 2025 HSR Filings Show Steady Strategic Focus
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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.
Industry News – Antitrust Beat
From Volatility to Vision: June 2025 HSR Filings Show Steady Strategic Focus
ComplexDiscovery Staff
Through June 2025, corporate M&A activity in the United States reflects sustained strategic intent despite macroeconomic challenges. Hart-Scott-Rodino (HSR) premerger notification filings for the first nine months of Fiscal Year 2025 (October 2024 through June 2025) totaled 1,519 transactions, with 157 filings reported in June alone. This pace continues a pattern of deliberate dealmaking amid shifting economic and regulatory conditions. The average monthly volume now stands at 168.8 transactions—slightly below FY 2024’s average of 173.3, highlighting a market characterized more by stability than contraction.
Monthly Volatility Reveals Strategic Timing
Monthly HSR activity in FY 2025 shows notable volatility, revealing how companies strategically time their filings. November’s 233 filings marked the highest point of the fiscal year, followed closely by February’s 230. March dropped sharply to 89—the lowest of the year—before gradually rebounding. June’s count of 157 filings represents a return to the fiscal year’s average. This pattern indicates that companies are not retreating from strategic transactions but are instead adjusting timelines based on regulatory dynamics, market sentiment, and operational readiness.
This measured approach recalls past cycles, where transaction volumes followed broader economic ebbs and flows. While 2000 recorded a high of 4,926 filings and 2009 a low of 716 reflected extremes, the more recent figures—averaging around 2,370 filings annually since 2020—illustrate a recalibrated but healthy M&A environment, emphasizing quality over volume.
Economic Signals: Slower Growth, Persistent Inflation
Macroeconomic conditions provide essential context for current transaction strategies. In Q1 2025, real GDP contracted by 0.5%, a downward revision from earlier estimates. The decline stemmed primarily from increased imports and reduced government spending, partially offset by consumer spending and investment. Meanwhile, real Gross Domestic Income (GDI) increased slightly by 0.2%, and corporate profits declined by $90.6 billion. These mixed signals suggest hesitancy in both public and private sector investment, even as certain sectors remain active.
The price index for gross domestic purchases increased by 3.4%, with the core PCE price index (excluding food and energy) rising by 3.5%. These figures reflect persistent inflation, which continues to influence corporate investment decisions.
Adding further pressure, personal income and disposable income both declined in May 2025 by 0.4% and 0.6%, respectively, and real disposable income dropped by 0.7%. However, the personal savings rate remained at 4.5%, suggesting that while households are cautious, they are still positioned to support consumer-driven sectors.
Implications for Cybersecurity, Governance, and Discovery
In this economic climate, professionals in cybersecurity, information governance, and eDiscovery are pivotal to successful deal execution.
- Cybersecurity: Integration phases remain high-risk periods, as merged entities combine infrastructure and data systems. Cybersecurity teams must conduct pre-acquisition risk assessments, secure transaction data, and ensure continuous threat monitoring post-merger. Regulatory bodies increasingly expect demonstrable cyber diligence in M&A due diligence.
- Information Governance: Professionals face the challenge of harmonizing disparate data policies and infrastructure. The integration of records management, compliance standards, and cross-border data frameworks is critical, particularly as deals often involve multinational entities and jurisdictional complexities.
- eDiscovery: As regulatory scrutiny of M&A deals intensifies, eDiscovery teams must be proactive. Rapid response capabilities, robust cloud-based tools, and advanced analytics are vital for handling requests from agencies such as the FTC or DOJ. Ensuring readiness for audits and litigation can differentiate successful deals from stalled ones.
Strategic Outlook: Planning Trumps Pace
June’s data reinforces a narrative of strategic steadiness. The consistency in HSR filings amid economic contraction and inflation shows that companies continue to prioritize long-term value over short-term gains. Dealmaking is increasingly driven by strategic alignment, technological fit, and operational resilience—an environment where thorough due diligence and robust governance are not just advantageous but necessary.
Professionals in cybersecurity, governance, and discovery must remain agile, informed, and integrated into early transaction planning to ensure compliance and secure value realization.
Looking Forward
Fiscal Year 2025 is shaping up as a year of pragmatic growth and operational discipline. While total filings are tracking slightly below last year, the data reflects a thoughtful recalibration rather than a retreat. As companies adjust to economic headwinds, the demand for specialized support in securing, governing, and disclosing transaction-related data will only intensify.
Analysis based on Hart-Scott-Rodino filing data through June 2025, U.S. Bureau of Economic Analysis reports, and industry observations. For the most current HSR statistics and regulatory updates, consult Federal Trade Commission publications and qualified legal counsel.
HSR Transaction Activity by the Numbers
HSR Transactions by Fiscal Year: 2000–2025
This chart displays the number of Hart-Scott-Rodino (HSR) premerger notification transactions reported annually from fiscal year 2000 through 2025. The data reveals significant fluctuations over the past quarter-century, with a peak of 4,926 transactions in 2000 during the dot-com boom and a low of 716 in 2009 amid the global financial crisis. More recently, filings have demonstrated a recalibrated but resilient M&A landscape, averaging approximately 2,370 transactions annually from 2020 through 2025. This long-term perspective underscores the cyclical nature of merger activity and highlights the market’s capacity for strategic adaptation amid shifting economic conditions.
Chart 1: HSR Act Annual Transactions Reported in Fiscal Years 2000 – 2025
HSR Act Merger Transactions Reported - June 2025 ReportingHSR Transactions by Month: October 2024 – May 2025
This chart presents the monthly Hart-Scott-Rodino (HSR) premerger notification transaction counts for fiscal year 2025, covering October 2024 through June 2025. The data illustrates significant variability in deal activity, with a peak of 233 transactions in November and a low of 89 in March. June recorded 157 filings, aligning closely with the fiscal year’s monthly average of approximately 169 transactions. These fluctuations reflect ongoing market dynamics, strategic timing, and seasonal factors influencing merger and acquisition activity. Despite the volatility, the overall trend points to a stable and deliberate pace of transactions.
Chart 2: Monthly HSR Act Transactions Reported in the Fiscal Year 2025 (October-September)
HSR Act Merger Transactions Reported - FY 2025 - June 2025 ReportingHSR Transactions by Month: Fiscal Year 2024
This chart details the monthly Hart-Scott-Rodino (HSR) premerger notification transactions reported throughout fiscal year 2024, from October 2023 through September 2024. The data highlights a generally consistent level of M&A activity, with monthly filings ranging from a low of 135 transactions in February to a high of 218 transactions in August. Notably, the summer months (July and August) saw an uptick in filings, suggesting increased deal flow during that period. The total number of transactions reported for fiscal year 2024 was 2,079. Overall, the monthly distribution underscores a stable and resilient M&A environment across the fiscal year.
Chart 3: Monthly HSR Act Transactions Reported in the Fiscal Year 2024 (October-September)
HSR Act Merger Transactions Reported - FY 2024 - FinalHSR Transactions by Month: Fiscal Year 2023
This chart provides a month-by-month breakdown of Hart-Scott-Rodino (HSR) premerger notification transactions reported during fiscal year 2023, spanning October 2022 through September 2023. The data reflects moderate variability, with monthly filings ranging from a low of 114 transactions in April to a high of 207 in November. Activity remained relatively steady throughout the year, with minor fluctuations that may be attributed to both seasonal patterns and broader market conditions. The total number of transactions reported for fiscal year 2023 was 1,805. This monthly perspective offers insight into the pacing of M&A activity during a year marked by economic adjustment and evolving deal dynamics.
Chart 4: Monthly HSR Act Transactions Reported in the Fiscal Year 2023 (October-September)
HSR Act Merger Transactions Reported - FY 2023 - FinalHSR Transactions by Month: Fiscal Year 2020 (Pandemic Impact)
This chart illustrates the monthly Hart-Scott-Rodino (HSR) premerger notification transactions reported during the fiscal year 2020, spanning October 2019 through September 2020. The data highlights the volatility of M&A activity amid the global events of the pandemic year, with a notable dip in April and May reflecting the initial economic impact and uncertainty. Monthly filings ranged from a low of 57 transactions in May to a high of 206 transactions in November, underscoring the fluctuating nature of deal-making during this unprecedented period. The total number of transactions reported for fiscal year 2020 was 1,637, demonstrating the resilience and eventual recovery of the M&A market despite significant challenges.
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)News Sources
- Premerger Notification Program | Federal Trade Commission (ftc.gov)
- Personal Income and Outlays, May 2025 | U.S. Bureau of Economic Analysis (BEA)
- U.S. International Trade in Goods and Services, May 2025 | U.S. Bureau of Economic Analysis (BEA)
- Gross Domestic Product, 1st Quarter 2025 (Third Estimate), GDP by Industry, and Corporate Profits (Revised) | U.S. Bureau of Economic Analysis (BEA)
- Strategic Signals: May 2025 HSR Filings Reveal Steady M&A Amid Market Shifts (ComplexDiscovery)
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Additional Reading
- HSR Act Reporting: A ComplexDiscovery Chronology
- FTC Annual Competition Reports (Hart-Scott-Rodino Act Reports)
Source: ComplexDiscovery OÜ