Bold takeaway: U.S. M&A activity is surging again, powered by big-ticket deals and supportive policy shifts, with 2026 looking promising despite ongoing political uncertainty. Here’s a comprehensive rewrite of the original content, preserving all key details while clarifying concepts for beginners and adding context where helpful.
North America: deal value climbs in H2 2025
Renewed confidence for large-scale transactions despite macro headwinds
North American M&A followed the global pattern in 2025, with deal value rising in the second half to USD 1.1 trillion even as deal volumes declined. In the United States, the surge in the October–December period was striking: total transaction value rose 24% from the first half, driven by a flux of megadeals. One of the most notable potential deals involved competing bids for a major film industry company from Netflix and Paramount; if approved, it would rank among the largest transactions in history.
Average deal sizes expanded significantly: from October 1 to December 1, the typical deal valued about USD 400.1 million, over three times the Q1 average of USD 121 million. Q3 alone tallied USD 578 billion in deal value—the highest quarterly total since 2021. This uptick was partly supported by several interest-rate cuts from the Federal Reserve. Private equity shifting toward mid-market opportunities complemented ongoing appetite for large transactions, while corporate buyers rebalanced portfolios through divestitures and carve-outs to fund strategic acquisitions.
Midterms unlikely to derail regulatory enforcement
Looking ahead to the U.S. midterm elections, analysts don’t expect a dramatic shift in deal activity. Regardless of which party controls Congress, enforcement by key agencies such as the Department of Justice (DOJ), Federal Trade Commission (FTC), and the Committee on Foreign Investment in the United States (CFIUS) has not been a dominant focus under the current administration, and that trend may continue. Antitrust actions have continued across administrations, including several litigated transactions since President Trump took office.
United States: momentum builds toward year-end strength
Market dynamics in H2 2025 were driven by larger deal sizes and a push toward AI and technology-enabled opportunities. Artificial intelligence emerged as a central driver across sectors, with transactions targeting AI systems, the data required to train and refine models, and the talent needed to operationalize AI.
High-profile AI activity included September’s strategic partnership between Nvidia and OpenAI. The plan outlined Nvidia’s intention to invest USD 100 billion in OpenAI and to deploy 10 gigawatts of Nvidia systems to support OpenAI’s next-generation infrastructure. Though not yet finalized at the time of reporting, this deal signaled the scale of potential investments in AI infrastructure.
This AI emphasis was part of a broader wave of similar investments among leading tech players. In the same period, Nvidia announced a USD 5 billion collaboration with Intel to co-build data centers and semiconductors. In November, the group pledged as much as USD 10 billion in Anthropic, with Microsoft contributing an additional USD 5 billion. OpenAI itself committed to spending USD 1.4 trillion on AI infrastructure, including a strategic alliance with AMD to deploy 6 gigawatts of AMD GPUs.
Beyond headline multibillion-dollar tie-ups, buyers—including corporates and financial sponsors—are pursuing proprietary data assets to fuel specialized AI systems. Enterprises in data-rich sectors like healthcare and financial services seek AI capabilities to improve decision-making and accelerate drug discovery timelines. These dynamics introduce a range of legal, regulatory, and commercial risks, from IP ownership to data privacy and cybersecurity. Thorough, forward-looking due diligence is essential in M&A to address these challenges.
The scope of AI-related risks varies with factors such as the technology type, training methods, and intended use cases. Even when AI is not the primary value driver, its presence is increasingly a consideration in nearly every deal, given that most targets deploy or develop AI in some form. The regulatory landscape is evolving rapidly and becoming more fragmented as countries pursue their objectives. Issues around data scraping, model training, and retrieval-augmented generation (RAG) are being reshaped by authorities, policymakers, and courts almost daily.
Policy landscape points to heightened oil and gas M&A
We expect more North American oil and gas M&A in 2026 and beyond, driven by favorable policy developments in the United States and Canada.
In the United States, the administration’s Unleashing American Energy initiative and a companion legislative push aim to roll back several sustainability and decarbonization policies while introducing new tax incentives for oil and gas producers. In Canada, Prime Minister Mark Carney recently signed a memorandum of understanding with Alberta’s premier to advance a privately funded 1,100-kilometer pipeline linking oil sands to Canada’s Pacific coast. This project—which would carry up to one million barrels of oil per day—will be supported by government infrastructure funding as part of Canada’s 2025 Budget, intended to diversify exports and reduce reliance on the United States amid simmering tensions between the two countries.
The pipeline deal includes exemptions from certain federal environmental regulations and the longstanding oil-tanker ban off British Columbia, with Alberta committing to a USD 11.7 billion carbon capture and storage facility to offset emissions. If realized, the project would boost exports to Asia and represent a significant policy shift in Canada’s energy strategy, contrasting with the more cautious stance of the previous federal government.
These developments are expected to attract foreign investors to Canada’s oil and gas sector. Canada ranks as the world’s fourth-largest proven oil reserve holder, behind Saudi Arabia, Venezuela, and Iran, but its limited infrastructure has constrained resource exploitation.
Transaction timelines lengthen in response to HSR reforms
From a deal-making perspective, reaction to Hart-Scott-Rodino (HSR) pre-merger reforms has been to extend timelines. The changes raise the information burden on merging parties, requiring additional documents, narrative explanations of overlaps and rationale, details on buy-side structures and foreign subsidies, and information on defense and intelligence contracts.
As a result, purchase agreements now reflect longer preparation and review times for HSR filings. Where deals previously anticipated filing within five to ten business days of signing, a 20-business-day norm has emerged, with up to 30 business days if there are competitive overlaps. Parties are increasingly coordinating early document collection to reduce delays between signing and closing, even before definitive agreements are signed. This heightened information requirement has driven higher costs for filing and compliance.
Nevertheless, early termination of the HSR waiting period remains possible for transactions that do not raise competition concerns. The FTC and DOJ can grant such relief when appropriate, enabling faster closings for deals that don’t require additional regulatory approvals.
CFIUS process undergoes notable modernization
CFIUS has seen significant changes under the current administration’s national-security priorities. The broader policy approach emphasizes more streamlined approvals, with the DoD (referred to by some as the Department of War under past naming) playing a larger role in deal reviews. The aim is to scrutinize foreign acquirers’ connections to China, inbound investors’ cyber-security capabilities, and long-term growth strategies in the United States, including dealings with sanctioned parties and ultimate beneficial ownership structures.
Buyers should assess other potential or pending deals that could delay approvals
In a regulatory-tight environment, buyers must carefully evaluate other transactions under consideration that could affect the timely attainment of required approvals. Purchase and merger agreements commonly include covenants designed to prevent actions that would impede regulatory clearances, but buyers should build enough flexibility to pursue other opportunities if needed while a deal is pending. Additionally, filers—especially private equity funds—should consider how responses in one regulator’s filing might influence future filings with the same regulator.
In summary, the 2025 M&A landscape in the U.S. and North America blends sizable deal momentum with evolving regulatory processes and energy policy shifts. The AI revolution and strategic data assets drive high-value transactions, while policy changes in oil and gas, and procedural reforms at HSR and CFIUS, shape how deals are sourced, structured, and completed. The key question for observers and market participants is how these forces will interact in 2026: will growth persist amid regulatory tightening, or will fresh policy and enforcement dynamics recalibrate the pace and direction of M&A activity? If you have a view on which force will dominate, share your thoughts in the comments.
