Insight

2025 Energy & Chemicals Antitrust Report

Client Alerts

January 13, 2026 • 1-minute read

Related Categories

Vinson & Elkins’ 2025 Energy & Chemicals Antitrust Report details how antitrust enforcement under the second Trump administration has shifted toward a more traditional, pragmatic, and business-friendly approach while remaining firmly committed to vigorous enforcement. New leadership at the DOJ and FTC reaffirmed the 2023 Merger Guidelines for stability, reinstated early termination of HSR reviews, and showed greater openness to negotiated settlements—particularly structural remedies such as divestitures—rather than reflexively blocking mergers.

Enforcement activity in the energy and chemical sectors declined compared to prior years, with fewer merger challenges and the rollback or modification of several Biden-era consent orders, especially in oil and gas. At the same time, agencies continued to prioritize consumer welfare and labor market competition, pursuing cases involving retail fuel, construction materials, wage-fixing, non-competes, and unlawful pre-closing coordination, while imposing record civil penalties for HSR violations.

State attorneys general expanded their role through new “Mini-HSR” laws and increased scrutiny of federal settlements, creating a more complex enforcement landscape. Overall, the report depicts an environment that is more receptive to M&A but still active, disciplined, and enforcement-oriented, with heightened compliance burdens driven by expanded HSR filing requirements and ongoing non-merger investigations.

Included in this report:

Antitrust Enforcement in the Second Trump Administration
2025 Summary of Developments
Merger Enforcement Data & Trends
Merger Enforcement Policy Developments
Merger Enforcement Cases
Non-Merger Enforcement Cases
State & Private Litigation
Overview of Antitrust Law and Enforcers
Vinson & Elkins’ Nationally Recognized Antitrust Practice

This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.

Discover our latest:

Insights

CLE Events

Financing and Bankability of Data Center Projects

This program will examine the key legal and commercial considerations for financing data center projects, with a focus on what makes these projects bankable for lenders and investors.

September 29, 2026

September 29, 2026 • 1-minute read

View Event