2. The Declaration Data Reinforce the Importance of Filing Path Strategy CFIUS received 140 declarations in 2025, up from 116 in 2024. The more consequential difference was in outcomes. Thirty-six declarations resulted in requests for full notices, while CFIUS was unable to conclude action on another 11. Taken together, 47 of 140 declarations, approximately 34%, did not produce clearance on the short form. In 2024, the comparable figure was 24 of 116, or approximately 21%. There is an important qualification. Fifty-one of the 140 declarations filed in 2025 were subject to mandatory filing requirements, compared with 36 of 116 in 2024. The Annual Report does not disaggregate outcomes between mandatory and voluntary declarations. The aggregate outcome data therefore does not tell us how voluntary declarations performed in isolation, and the composition of the declaration population also changed year over year. Declarations nevertheless remained an effective route for many transactions. CFIUS concluded all action without requesting a notice in 92 declaration cases in 2025. The data do not establish that declarations have become a poor filing strategy. Instead, they reinforce the point that the filing path should be selected based on the transaction rather than simply a preference for the nominally shorter process. A declaration gives CFIUS less information and a shorter assessment period than a full notice. For transactions presenting issues likely to require substantial interagency analysis, a declaration may become an additional stage before a full notice rather than a substitute for one. The timing data make that possibility commercially relevant. In 2025, declarations averaged 6.87 days from submission to acceptance and 30.1 days from acceptance to disposition, net of tolled days. Treasury explains that the assessment average can exceed 30 days when the thirtieth day falls on a weekend or public holiday, in which case the next business day is treated as the final day.
347
Total Filings
140
Declarations Filed
207
Notices Filed
3
Notices Rejected
10
Transactions Abandoned
114
Investigations Initiated
25
Transactions Subject to Mitigation Measures
Non-Notified Transactions Investigated
90
Formal Determinations Involving Violations of Mandatory Filing Requirements
2
2
Presidential Actions
3
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