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A large international acquisition is most often delayed because a required regulator has not cleared it. The main causes are mandatory merger-control waiting periods, a deeper antitrust investigation, foreign-investment or national-security screening, and the difficulty of coordinating reviews in several countries. Requests for documents, negotiated remedies, litigation, or conflicting decisions can all move the closing date. The exact cause and duration depend on the countries, industries, transaction structure, and review stage; there is no reliable universal timetable.
Why an announced closing date is not guaranteed
When buyers and sellers announce an acquisition, they usually publish an expected closing window. That date is a target, not proof that every legal condition has been satisfied. A purchase agreement commonly makes regulatory clearance a condition to closing. If a mandatory waiting period is still running, or an approval remains unresolved, the parties may be legally unable to complete the transaction even when commercial negotiations are finished.
International deals are especially exposed because one transaction can fall under several regimes at once. Competition authorities examine whether the combination could harm competition, while investment-screening bodies examine security or public-order risks. Those reviews use different legal tests, information requirements, and calendars. The slowest unresolved track can determine when the entire acquisition closes.
The regulatory tracks that can hold up closing
United States merger-control waiting periods
Under the U.S. Hart-Scott-Rodino (HSR) process, certain acquisitions require premerger notification. The Federal Trade Commission states that parties generally may not close until the statutory waiting period expires or the government grants early termination. Its process description gives an initial 30-day waiting period for most covered transactions. Specified cash tender offers and bankruptcy transactions have a shorter 15-day initial period. These are descriptions of the U.S. process, not a prediction for an individual deal or for another country.
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A transaction can therefore be ready in every business respect and still be unable to close because the initial HSR clock has not ended. Filing thresholds, exemptions, and procedural rules can change, so the applicable period must be checked against the law and guidance in force when the filing is made.
A Second Request and extended antitrust review
A routine preliminary review can become much longer when an agency issues a Second Request. This is a formal demand for additional business documents and data, such as information about products, customers, competitors, pricing, internal strategy, and market conditions. Preparing, collecting, reviewing, and producing that material can take substantial time for multinational companies with many systems and jurisdictions.
The request extends the waiting period. After the parties substantially comply, the FTC describes a further 30-day review period for typical transactions and a 10-day period for specified cash tender offers or bankruptcy transactions. The government and the parties can also agree to extend that phase while remaining concerns are addressed. “Substantial compliance” is a procedural milestone, not a guarantee of clearance.
Substantive competition concerns
Authorities may investigate whether the acquisition could substantially lessen competition or tend to create a monopoly. They can let the waiting period expire, ask for more information, negotiate a settlement, or bring legal action. An investigation may focus on overlapping products, concentrated markets, important inputs, distribution channels, technology, or the loss of a particularly important competitor; which issues matter depends on the facts and the authority’s jurisdiction.
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The FTC has said that the vast majority of deals reviewed by the FTC and Department of Justice proceed after preliminary review. That qualitative statement does not provide a percentage and does not predict the result for a large or international transaction. A deal with significant overlaps or a strategically important market can receive more intensive scrutiny than an ordinary filing.
Foreign-investment and national-security screening
Investment screening is separate from competition review. In the United States, the Committee on Foreign Investment in the United States (CFIUS) can review certain foreign investments in U.S. businesses and certain real-estate transactions for national-security effects. Its authority includes transactions that could result in foreign control of a U.S. business, along with other covered investments defined by statute and regulation. A transaction may therefore face a CFIUS issue even when competition is not a concern.
The European Union’s framework is aimed at identifying, assessing, and mitigating potential security or public-order risks. The European Commission said a new Foreign Investment Screening Regulation was adopted on 17 June 2026, entered into force on 16 July 2026, and is scheduled to apply from 17 January 2028. That application date concerns the framework’s implementation, not the expected duration of any particular review, and should be verified against the Commission’s latest materials before relying on it.
In the United Kingdom, government guidance says an accepted notification under the National Security and Investment regime is reviewed within 30 days. The time before a notification is accepted can vary with demand and case-specific factors, so the 30-day period should not be treated as a universal period from first contact to closing.
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Several jurisdictions reviewing the same transaction
A cross-border acquisition can require filings in countries where the buyer, seller, subsidiaries, customers, facilities, or revenues create jurisdictional links. OECD analysis notes that different merger-control standards and extraterritorial reach can produce uncertainty, inconsistent or conflicting rulings, and remedies that are burdensome to negotiate. Concurrent merger and foreign-investment reviews can be particularly difficult when a transaction has an urgent commercial timetable.
One authority may be satisfied while another asks for more data. A remedy acceptable in one country may affect operations in another, forcing the parties to redesign the package or seek compatible commitments from several agencies. Closing cannot safely proceed while a mandatory approval or waiting period remains outstanding in a jurisdiction whose rules apply to the deal.
What each review stage can add to the calendar
| Stage | What triggers it | Why it takes time | Possible result |
|---|---|---|---|
| Initial filing or notification | Transaction size, structure, foreign ownership, sensitive assets, or other statutory tests | Preparation of accurate forms, translations, jurisdictional analysis, and waiting for the statutory period | Clearance, early termination, acceptance for review, or a request for more information |
| Additional-information request | The authority needs documents, data, interviews, or clarification | Large document collections, privilege review, translations, data validation, and agency analysis | Clearance, further negotiations, remedies, or continued investigation |
| Substantive investigation | Possible competitive, security, or public-order risk | Market testing, economic analysis, internal agency review, and responses to the parties’ arguments | Unconditional clearance, clearance with conditions, mitigation, litigation, or prohibition |
| Remedy discussions | The authority identifies a concern but may accept commitments | Defining assets or conduct obligations, testing feasibility, and coordinating terms across countries | Consent agreement, mitigation agreement, revised transaction, or no settlement |
| Legal challenge | The authority seeks to stop or modify the transaction | Court schedules, pleadings, evidence, hearings, and possible appeals | Deal proceeds, is restructured, is blocked, or is abandoned |
Timelines that can be stated safely
Regulatory clocks are process rules, not closing estimates. The following figures describe specific regimes and carry their stated qualifications.
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| Regime or event | Published period or date | How to interpret it |
|---|---|---|
| U.S. HSR initial review | 30 days for most covered transactions | Initial statutory waiting period described by the FTC; parties generally cannot close before it ends or is terminated early. |
| U.S. HSR special categories | 15 days | Shorter initial period described for specified cash tender offers and bankruptcy transactions. |
| U.S. HSR after substantial compliance with a Second Request | 30 additional days for typical transactions | Further review period described by the FTC; the parties and government may agree to extend it. |
| U.S. HSR special categories after substantial compliance | 10 days | Further review period described for specified cash tender offers or bankruptcy transactions. |
| UK National Security and Investment review | 30 days after notification is accepted | Government guidance period; the time required for acceptance can vary. |
| EU Foreign Investment Screening Regulation | 17 January 2028 application start | Date stated by the European Commission for the new regulation to apply; it is not an individual deal-duration estimate. |
For an international acquisition, the practical timetable may be governed by the longest or most complex applicable review. No reliable universal average duration has been established for large international acquisitions.
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Why remedies and litigation create further delay
If an authority sees a competition problem, the parties may propose a remedy rather than abandon the transaction. Remedies can involve divesting a business, licensing technology, supplying rivals, preserving access, or accepting behavioral restrictions, but the appropriate commitment is fact-specific. Negotiation requires the authority to test whether the proposal actually addresses the predicted harm and whether it can be monitored and enforced.
Cross-border remedies are harder when several agencies must agree on scope and timing. A divestiture buyer, regulatory approvals, or operational separation may be needed before closing or as a continuing obligation. If negotiations fail, an authority can seek a court order or other legal action to block the acquisition. Litigation introduces court calendars and uncertainty; even a successful defense can move the original closing date.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How national-security reviews differ from antitrust reviews
Competition agencies ask whether the transaction may harm competitive conditions. Investment-screening authorities ask whether foreign ownership, control, access, or influence creates a security or public-order risk under their governing rules. Sensitive technology, critical infrastructure, personal data, defense connections, or strategic real estate may matter even when the buyer and target sell competing products only minimally.
The two reviews can run concurrently. A transaction could receive antitrust clearance yet remain subject to security mitigation, or face competition remedies while a security review continues. The existence of a filing does not prove that a prohibition or mitigation order will follow; the outcome depends on the regime and the facts.
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How to identify the real cause of a specific delay
For an unnamed transaction, an announced date alone cannot establish why closing moved. Use the parties’ latest public filings, investor announcements, and statements from the responsible authorities to identify the status of each required track.
- List every authority with jurisdiction. Separate competition regulators from foreign-investment or national-security screeners.
- Check the trigger. Determine whether the filing is based on transaction size, market overlap, foreign control, sensitive assets, or another statutory test.
- Locate the review stage. Look for an initial waiting period, an accepted notification, a request for additional information, a formal investigation, remedy talks, or a court action.
- Look for explicit requests. Public language about a Second Request, supplemental information, interviews, or extended review is stronger evidence than speculation about a missed date.
- Read closing-condition language. A statement that approvals remain conditions to closing indicates a legal constraint, while an amended outside date may reflect the parties’ contract management rather than a regulator’s decision.
- Compare jurisdictions. One country’s clearance does not show that all other required reviews are complete.
What parties usually manage while reviews continue
Buyers and sellers can reduce avoidable slippage by mapping every filing before signing, assigning ownership for each authority, and preserving a consistent factual record across submissions. A multinational document-retention and collection plan is important because an information request can cover subsidiaries and historical materials in several countries.
Parties also need a coordinated remedy strategy. They should understand which assets, contracts, data-access arrangements, or operating commitments could be affected and whether a proposed remedy in one jurisdiction would create problems elsewhere. None of these steps guarantees faster clearance; they improve readiness while the authorities make independent decisions.
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- Unconditional clearance: The authority closes its review without imposing commitments.
- Clearance with remedies or mitigation: The deal proceeds subject to divestitures, conduct obligations, security controls, or monitoring.
- Extended negotiations: The parties and authority continue discussing a package, often requiring an amended outside date.
- Litigation or prohibition: An authority seeks to stop the transaction or a court blocks it.
- Abandonment: The parties terminate the agreement, sometimes because the regulatory risk, cost, or delay is no longer acceptable.
Explanations that require transaction-specific evidence
Financing problems, diligence findings, shareholder approvals, foreign-exchange permissions, integration disagreements, or contract disputes can also affect a particular acquisition. They are not established merely because a large international deal is late. Attribute one of these causes only when the parties or a responsible authority disclose it. Regulatory delay is the strongest general explanation supported by the mechanisms described above, but it is not proof of what happened in any unnamed transaction.
Bottom line
A large international acquisition can miss its target date because a mandatory waiting period has not expired, a regulator has demanded extensive additional information, competition concerns have led to remedies or litigation, a foreign-investment review is unresolved, or several jurisdictions are moving at different speeds. The only dependable way to identify the cause is to match each required approval with its authority, trigger, current stage, information burden, and closing condition.
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