HSR Filing Update: New Translation Requirements Now in Effect
A quick video and guide that covers the HSR filing changes. What it means for you in practice, and a purpose-built approach you can take.
The FTC have finalized a set of changes to the HSR pre-merger notification form—and one shift, in particular, deserves your immediate attention:
As of this update, all foreign-language documents submitted in connection with a notifiable transaction must now be translated into English. This goes well beyond the prior expectations around selective document translation.
The new requirement covers any foreign-language materials prepared by or for officers, directors, or key deals including board presentations, valuation models, draft agreements, and internal memos.
What Does This Mean in Practice?
We know you’re often juggling complex, cross-border filings with tight turnaround windows. Here’s what to keep in mind:
Wider net: Documents like board decks, internal emails, valuations, and other strategy docs now likely need to be translated in full if they’re in another language.
Not limited to one section of the form: This change affects the full range of submission materials. Any documents reviewed at the executive level that include foreign-language content should be assumed in scope.
The Commission noted that the abundant availability of translation tools and service options should significantly reduce the cost of translations for HSR filings. We at Morningside, a Questel company, agree and have a track record of providing translation tools and services to support our client’s corporate development efforts.
We offer flexible options to meet your compliance goals:
- Self-service machine translation through HUBai (great for internal review or pre-filing prep)
- Managed services for machine translation large volume or complex file types that require Morningside’s project management and engineering expertise that cannot be completed by self-service methods
- Machine Translation Post-Editing (MTPE) by legal-expert linguists
- Human translation for especially sensitive or final-stage documents
File types and formatting flexibility: We work with PDFs, PowerPoints, Excel models, scans, and embedded file types, including those most vendors won’t touch. Our file prep maintains formatting and layout integrity, even in deadline-driven environments.
Regulatory assurance and testimony readiness: We carry full liability insurance, operate under ISO-certified workflows, and can provide certified affidavits, sworn declarations, or expert testimony when needed. Whether for regulators or litigation.
A Purpose-Built Approach: HUBai for Regulatory-Grade Translations
We created HUBai to handle exactly this kind of use case — where accuracy, confidentiality, and speed are all non-negotiable.
HUBai blends secure AI technology with expert human oversight to deliver:
- Translation outputs to meet budget and quality expectations, from self-service automated translations to bulk volume automated translations, and human post editing services.
- Legal nuance and deal-specific terminology.
- Fast turnaround to meet pre-merger deadlines
- Full audit trail and revision control
- PDF and Native file support across formats
- Insurance backed, affidavit-testimony-ready service options
- Confidentiality-first infrastructure (ISO-certified)
We’ve supported leading firms through international filings, post-merger integrations, and time-sensitive disclosures. This isn’t new for us. But the filing landscape just changed, and we’re ready to meet these new requirements with you.
Learn more about our Private Client Platform: HUB. If you’re interested, don’t wait you can register now and our team will be in contact with you.
Want to Talk It Through?
We’re already working with clients to update their workflows and translation protocols in response to this rule change. If you’d like:
- A private compliance briefing
- Help reviewing current protocols
- A tailored checklist for your team or client
Want to try HUB+ with zero risk?
We’re now offering a free Business Tier Trial: translate up to 10 documents instantly with no credit card, no auto-renew. Perfect for testing multilingual HSR filings, M&A due diligence, or early case assessment workflows.
Just reach out directly, using the form below. We’ll make sure you’re covered.
Don’t Let Post-Transaction Details Slip Through.
HSR compliance is only one part of the M&A process. Ensure your IP rights stay aligned with corporate changes through Questel’s global patent recordals services.