Transparency In Merger Enforcement: Second Request Review Timelines Continue To Drop in 2026
Transparency In Merger Enforcement: Second Request Review Timelines Continue To Drop in 2026

Transparency In Merger Enforcement: Second Request Review Timelines Continue To Drop in 2026
The Trump administration’s antitrust leadership has consistently expressed an intent to streamline merger review timelines. And DOJ announced new targeted review processes this past July intended to streamline extended (so-called Second Request) reviews further. But while many administrations pledged to economize merger review, timelines continued to stretch ever longer.
But times are changing for dealmakers: although the first three quarters of 2025 were marked by stubbornly long Second Request investigations, perhaps a function of holdover matters from the last administration, Akin’s Transparency in Merger Enforcement (TIME) data show measurable progress towards shorter timelines in Second Request merger investigations and welcome relief for parties considering strategic transactions.
Akin’s data provide a more complete picture of the agency’s activity because they include not only published Second Request outcomes but also Second Request investigations that the agencies do not publish. With two quarters down in 2026, average timelines for Second Request investigations that resulted in a published agency outcome fell below 10 months in the first half of 2026, more than two months lower than historic highs above 12 months just a year ago. And Second Request investigations that ended without any agency statement concluded on average in about eight months, just slightly above what was observed in Q4 2025.
The delta is likely a function of a different mix of outcomes. At the start of the Trump administration, the agencies expressed their openness to merger settlements, which were disfavored by the last administration. This change alone has been excellent news for dealmakers.
Our sixth installment of the Agency TIME Report looks back at the first half of 2026 and the latest trends in Second Request investigations announced by the antitrust agencies. It supplements the agencies’ record with information publicly disclosed by merging parties to provide a more complete picture than available from published agency statements alone.




