Key facts
- RPC is planning to revise its strategy in the United States.
- The company is not considering mergers.
- The U.S. Federal Trade Commission's (FTC) expanded merger notification rules, implemented in February 2025, were vacated by a federal court in February 2026.
- The FTC is appealing this decision, but currently accepts filings under the older, less extensive rules.
- The U.S. Department of War will now review certain defense-related transactions, including those involving critical technologies.
RPC is reportedly set to overhaul its strategy within the United States, while maintaining its stance against pursuing mergers. This strategic shift occurs amidst a period of significant regulatory flux concerning merger control in the U.S.
In October 2024, the FTC introduced extensive revisions to the Hart–Scott–Rodino (HSR) Act rules, which went into effect in February 2025. These new requirements mandated substantially more information and documentation for premerger notifications, with predictions of a significant increase in filing time and costs. However, on February 12, 2026, a federal court vacated these rules in the case of Chamber of Commerce v. FTC, ruling that the FTC had exceeded its statutory authority.
The FTC subsequently appealed this decision to the Fifth Circuit Court of Appeals. While initially granting a temporary stay, the court ultimately denied the FTC's motion for a stay pending appeal on March 19, 2026. Consequently, the FTC's Premerger Notification Office is now accepting HSR filings based on the forms and instructions in place before the February 2025 rule changes. The agency has also indicated it will continue to accept filings under the newer rules if parties voluntarily choose to use them.
In parallel, the U.S. Department of War, through its Office of Industrial Base Policy, has issued guidance requiring proactive disclosure of certain transactions that are notifiable under the HSR Act. This disclosure is mandatory for transactions involving parties with contracts with the Department of War, or those that pertain to critical technologies such as applied artificial intelligence, biomanufacturing, contested logistics, quantum and battlefield information, scaled hypersonics, and scaled directed energy.