13
Apr
Key Differences and Requirements
Both the United States and the European Union require mandatory pre-merger notification for significant transactions, but their frameworks, criteria, and the role of subnational jurisdictions (states or member states) differ in several important ways.
United States
States are increasingly introducing broad pre-merger notification rules in addition to the federal Hart-Scott-Rodino (HSR) Act. Many state regimes mirror or modestly expand upon federal triggers and requirements:
Key Features
Notification Triggers:
Mergers reportable under the federal HSR Act are typically triggered...