What Happened: The US government shut down began Wednesday, October 1, 2025. As federal agencies operate under contingency plans, the Federal Trade Commission (FTC) and Department of Justice (DOJ) have outlined the impacts on Hart-Scott-Rodino (HSR) filings.

Why It Matters: The FTC contingency plan and website describe the following changes to HSR filings:

• HSR filings will continue to be accepted.
• The Premerger Notification Office (PNO) will remain open to accept HSR filings electronically. Filings can be made until 5 p.m. Eastern each day as usual, although the PNO will operate on a reduced schedule from 9 a.m. to 1 p.m. Eastern. The PNO will have staff on duty to accept and process new filings, but will not respond to questions or requests for information or advice from outside parties.
• HSR waiting periods will be unaffected and run as usual.
• However, early termination (ET) of waiting periods will not be granted.

The FTC contingency plan does not identify any changes to the review of HSR filings and conduct of investigations to determine whether to challenge transactions under the antitrust laws. However, both the FTC and DOJ will be operating with reduced staff, and parties may need to anticipate potential delays and uncertainties in deal timelines, as well as plan for possible post-shutdown review and investigations. If the shutdown is prolonged, the FTC and DOJ could suggest parties voluntarily to pull-and-refile HSR filings to allow the agencies additional time to review.