May 8, 2026
ATF Proposes Major Revision to Form 4473
On May 8, 2026, ATF published a 60-day Paperwork Reduction Act notice seeking public comment on a proposed revision to ATF Form 5300.9 and 5300.9A, Firearms Transaction Record, commonly known as Form 4473. The notice is identified as Federal Register Document No. 2026-09183, published at 91 FR 25448, under OMB Control No. 1140-0020. Comments are due by midnight on July 7, 2026.
What ATF is Proposing
ATF is not merely updating wording on the current Form 4473. The agency is proposing a material revision to the form in its entirety, including reorganization, reduced sections, revised buyer eligibility attestations, altered race/ethnicity and sex fields, changes to ID documentation handling, and removal of several existing reminders and instruction sections. ATF says the changes are intended to reduce burden, make the form easier to complete, align the form more closely with statutory requirements, and improve plain-language readability.
Biggest Operational Change
Buyer Page / FFL Page Workflow
The most important structural change is that ATF is reorganizing the form so that the transferee completes the first four items, including:
- Transferee identifying information
- Transferee eligibility to receive a firearm
- Citizenship questions
- Transferee certification Part I
The FFL then completes later portions of the form. ATF explains that this is intended to eliminate the current “pass-back” structure where the form alternates between buyer and seller sections. For FFLs, this means the counter workflow, software flow, review process, and employee training may all need to change.
Key Proposed Changes to ATF Form 4473
ATF identifies the following proposed changes:
- Overall Form Style
- Plain-language edits, active voice, punctuation changes, and general simplification throughout.
- Form Structure
- Section headings A–D are removed. Questions are reorganized into numbered items.
- Transaction Checkboxes
- Two transaction-related checkboxes are added to the top right side of the form, if applicable.
- Firearm Information
- Firearm information moves from the beginning of the form to new Item 5.
- Buyer Workflow
- The transferee completes the first four items before the FFL completes its portions.
- Sex Field
- “Non-binary” is removed; the only selections are male or female.
- Name Fields
- New boxes allow the transferee to indicate “initial only” for first name or “no middle name.”
- Race / Ethnicity
- Separate race and ethnicity questions are combined into one race/ethnicity question. Hispanic or Latino becomes a checkbox like the other categories, and Middle Eastern/North African is added.
- Eligibility Questions
- Prohibiting or qualifying questions become Item 2. Instead of yes/no checkboxes, the transferee initials statements in Items 2a through 2d.
- Straw Purchase Language
- The prior “actual transferee/buyer” question is moved and rephrased as a statement that the transferee is not engaging in a straw purchase, tied to statutory changes made in 2022.
- Citizenship / Alien Status
- Citizenship and nonimmigrant alien questions are consolidated into Item 3. The prior question regarding sale to a nonimmigrant alien who does not meet an exception is removed.
- Transferee Certification
- Certification is split into Part I and Part II. Part II replaces what was formerly called recertification.
- Firearm Type
- The handgun / long gun / other firearm question is removed from the main form, though ATF says there will be an optional notation area on page 4.
- County Field
- County is removed from the address section because ATF says it is not required by statute.
- Identification Documents
- FFLs must either attach a copy of the identification document or record the document information on page 4.
- Supplemental ID / Military Orders / Nonimmigrant Exception
- These former separate fields are folded into Item 7 with revised wording.
- Under-21 Notice
- The earlier under-21 waiting-period notice before the NICS section is removed, though similar language is moved later into new Item 11.
- FFL Certification
- The “transferor certification” heading is changed to FFL certification and revised.
- Multiple-Sale Reminder
- The reminder to complete ATF Form 3310.4 for multiple sales is removed from Form 4473.
- Instructions
- Many instruction sections are removed from the form and will instead be available on ATF’s website. Remaining instructions are shortened significantly.
Comment Submission Information
ATF is asking for comments on whether the collection is necessary, whether the burden estimate is accurate, how the quality and clarity of the information collection can be improved, and how the burden can be minimized through electronic or technological methods.
Burden Estimate Issue Worth Noting
The notice contains a potential inconsistency in the burden estimates. ATF states that there are approximately 22.5 million respondents, with each response taking approximately 15 minutes, for a total annual burden of approximately 5.625 million hours. However, the burden table later lists 546,424 total annual responses, 0.20 hours per response, and 109,285 total burden hours. Because ATF specifically requests comments on the accuracy of the burden estimate, this discrepancy may be worth addressing in industry comments.
Practical FFLGuard Takeaway
ATF’s proposed 2026 Form 4473 revision is a major workflow and compliance change, not a simple form refresh. The proposed version would change who completes what, when they complete it, how eligibility is certified, how identity documents are handled, how race/ethnicity and sex are recorded, and where firearm and transaction information appears on the form.
FFLs should prepare to review and comment on the proposal before July 7, 2026, especially where the changes may affect counter operations, electronic 4473 software, ID-copy retention practices, multiple-sale controls, under-21 transaction workflows, training materials, and internal compliance audits.
LOTS of Work Ahead
Once finalized, this will require updated SOPs, staff retraining, revised quality-control checks, and coordination with software providers to ensure the electronic workflow mirrors the approved form.
ATF just put a new Form 4473 workflow on the table. That means new questions, new training, new software updates, and plenty of new ways for a simple counter mistake to become an inspection problem.
Don’t wait until the new form lands in your lap and your staff is guessing at the gun counter.
Join FFLGuard now and get the guidance, tools, and compliance backup you need before the chaos hits.
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