Getting in the way: The demise of early termination at the antitrust agencies

The FTC and DOJ have effectively ended early termination of Hart-Scott-Rodino waiting periods, with grant rates falling from 77% historically to 29% in FY 2025 and 30% in FY 2026. The agencies cite regulatory form changes and deal complexity, but the practical effect is that M&A deals now face the full 30-day review period as standard.