CFIUS 2025 Annual Report: Key Statistics and Trends
On August 7, 2026, the U.S. Department of the Treasury (Treasury), as chair of the Committee on Foreign Investment in the United States (CFIUS or the Committee), released its annual report to Congress for calendar year 2025 (the Report). The Report provides statistics on the Committee’s activities for the preceding calendar year, including overall filing numbers and resolutions, trends on the industries and countries associated with CFIUS filings, and themes in the Committee’s investigation and mitigation of transactions that pose national security risks to the United States. These metrics provide insight into the current state of CFIUS’s review process and enforcement, which may help assess risk when planning transactions and deciding whether to file with CFIUS. High-tech and life sciences companies raising foreign capital should be aware of the following:
- Filing volume indicates that CFIUS remains active: CFIUS reviewed 347 covered transactions in 2025, up slightly from 325 in 2024, but still well below volumes from a few years ago. Parties continue to come before the Committee to comply with mandatory filing requirements and mitigate the risk of non-notified review.
- A short-form Declaration does not guarantee a quick or final resolution. A quarter of Declarations resulted in a request to file a long-form Notice, with another 8% concluding without resolution, both up from last year.
- Non-notified transaction outreach remains active, and parties that forgo a CFIUS filing do so at their own risk: CFIUS made 62 formal inquiries into unreported transactions, requesting nine of those to file.
- The America First Investment Policy has not yet meaningfully changed CFIUS practice, as CFIUS continues to subject over half of long-form Notices to a longer national security investigation. CFIUS imposed mitigation measures in 25 transactions, the same as in 2024, but dramatically decreased site visits and, even where noncompliance was found, did not impose monetary penalties. While this may indicate a lighter-touch approach to enforcement, filers should not read this as reduced compliance risk, as the penalty framework remains in place.
Number of Transactions Shows Slight Increase in Filing Volume
In 2025, CFIUS reviewed 347 covered transactions submitted as either a shorter-form Declaration or the longer-form Notice, a modest increase from 325 covered transactions in 2024. However, the number remained significantly lower than in calendar year 2022, following broader trends in deal activity. The 347 transactions reviewed in 2025 consisted of 140 Declarations and 207 Notices.
CFIUS asked filers to submit a formal Notice for 25% of Declarations in 2025, up from 14% in 2024, and more than half of all Notices were investigated.
Top Filing Countries Remain Similar
Like in previous years, the most frequent filers align with traditional sources of U.S. investment but also include several countries that are of particular interest to the Committee (e.g., China and the UAE). Below are the top five investor countries by number of filings in 2025:
Investments from these countries were heavily focused on businesses involved in critical technologies, including from countries of heightened CFIUS concern like China (although those percentages have been decreasing in recent years).
Timelines for Review May Be Longer Than Anticipated and Unpredictable
When preparing a CFIUS filing, the parties need to plan for the Committee’s unpredictable review timelines. For both Declarations and Notices, the Committee has statutory timing constraints governing its acceptance and review of filings. Declarations must be accepted by the Committee within seven days and reviewed within 30 days following acceptance. Notices must be accepted within 10 days and reviewed within 45 days after acceptance, except that Notices may be subject to a 45-day extension for investigation, and in some cases, the Committee may be permitted to further extend its investigation. CFIUS generally uses the full time allowed in the review period. Time then gets added to the process, with many Notice cases rolled over from the review period into the investigation period, and the determination as to which cases will be investigated is unpredictable. Government shutdowns may further extend the statutory periods, as was the case in 2025.
Filers should take these extended timelines into consideration when preparing to file and ensure they leave adequate time for Committee review relative to transaction closing and other timelines.
The Committee “aims to grow its staff to continue building its capacity across all functions,” but it is not yet clear whether this increase in staff will result in swifter review of CFIUS filings, or whether the increase will be focused on some of the administration’s other priorities, including the launch of the Known Investor Program and the Committee’s increased attention to non-notified inquiries.
Non-Notified Transactions Remain a Steady Enforcement Priority
Non-notified transactions, or transactions that the Committee identifies and reviews on its own initiative without receiving a filing from the transaction parties, remain a critical enforcement mechanism. CFIUS routinely reviews media reports, commercial databases, and referrals from other agencies to screen investments and acquisitions and identify non-notified transactions that may present a national security risk. In 2025, CFIUS identified thousands of potential non-notified transactions and further investigated 90 of these transactions. These investigations led to 62 formal inquiries to companies and, following official inquiries, CFIUS required nine of the transactions to submit a filing.
While these figures indicate a decrease in the overall number and percentage of non-notified investigations and formal inquiries from 2024, filers should not interpret this to mean that enforcement of non-notified transactions is no longer a priority. These statistics align with previous years’ non-notified transaction figures, and CFIUS continues to allocate resources to “functions such as detection of and response to non-notified and non-declared transactions.”
The America First Investment Policy
In its 2024 Annual Report, CFIUS indicated it was undergoing a review to ensure it was positioned to address the Trump administration’s America First Investment Policy (AFIP), specifically to be vigilant about potentially adversarial foreign investment while also ensuring the United States continues to be a strong and open investment ecosystem to allies.
Despite this commitment, the Committee’s 2025 Report shows little change in response to AFIP. CFIUS did launch a “fast-track” Known Investor Program process to facilitate greater investment from specified allied and partner sources. However, the program remained in the pilot stage during the reporting period, and the Report did not provide any information on efficiencies gained.
Further, while AFIP criticized the use of “overly bureaucratic, complex, and open-ended” mitigation agreements, the Committee adopted mitigation with respect to 25 Notices filed in 2025, the same number as the prior year. Additionally, all mitigation measures in 2025 are subject to a compliance plan. However, CFIUS reduced the number of mitigation monitoring site visits to 40, down from 79 the previous year. While the Committee did not issue any enforcement penalties in 2025, it did issue two formal determinations of noncompliance with mandatory filing requirements in 2025, compared to one in 2024.
On balance, the 2025 Report reflects more continuity than change: filing volume, mitigation frequency, and review timelines held close to recent-year norms, and the quieter enforcement year on the penalty side was offset by increased use of the Committee’s mandatory-filing noncompliance authority. Filers should continue to plan around CFIUS’s established statutory timelines, tendency toward national security investigations, mitigation expectations, and enforcement priorities rather than anticipating near-term procedural relief.