California to require copy of federal HSR filing for 2027 deals
From January 1, 2027, certain federal HSR filers with a California nexus must electronically file a full copy of the federal submission with the state, adding a parallel filing step for California-connected transactions.
Beginning January 1, 2027, California will require certain federal Hart-Scott-Rodino filers with a California nexus to submit a complete electronic copy of their federal HSR filing to the state. The Hogan Lovells alert frames this in the context of health care transactions and indicates those deals may face two separate California filing tracks rather than one, though the alert excerpt does not spell out the second track's scope or recipient.
Why sophisticated counsel should care: a duplicate state submission is not a clerical afterthought. It carries its own completeness and format standard, adds a state-level filing deadline to the deal timetable, and may land on a public record with different confidentiality protections than the federal filing. Transaction checklists, closing conditions and internal deal budgets need to carry the extra step, and a late or defective state filing is the kind of defect that surfaces at closing rather than at signing.
Next to watch: implementing regulations, the definition of covered filers and of a California nexus, and how the copy requirement interacts with California's separate health care transaction review regime. The alert does not identify the statute or rulemaking timetable, so precise triggers and mechanics should be confirmed with California counsel before 2027 closings are calendared.