Under ATF’s October 9, 2026 guidance, prior NFA approval and registration requirements are no longer enforced for suppressors, short-barreled rifles, short-barreled shotguns, and AOWs. ATF continues to accept voluntary Form 1 applications for these items. The NFA has not been repealed, and other applicable federal, state, and local requirements remain in effect.
ATF Form 5320.1, better known as “Form 1,” is the application to make and register a firearm under the National Firearms Act (NFA). An approved application registers the firearm in the NFRTR (National Firearms Registration and Transfer Record).
ATF’s current revised Form 1 is the “Revised December 2025” version, which includes updated tax, payment, and signature instructions.
This blog breaks down what changed and what it means for firearms owners, dealers, and manufacturers.
Section 1: What is ATF Form 5320.1 (“Form 1”)?
Form 1 is the Application to Make and Register an NFA Firearm. It’s used when you are the “maker” (not a transferee) and are applying to make and register the item described on the form. Prior NFA approval is no longer enforced for making suppressors, short-barreled rifles, short-barreled shotguns, or AOWs, although voluntary applications remain available. Applicable approval requirements remain in effect for machine guns and destructive devices. Form 1 does not override separate restrictions on making new machine guns or any state or local requirements.
Who uses Form 1?
- Individuals
- Trusts
- Corporations / other legal entities
- Government entities
Why it matters: Form 1 is one of those “do it right the first time” items—because NFA compliance isn’t the place to freestyle.
Section 2: Overview of the New Changes
1) Tax Payment Clarification (Items 1a / 1b)
The revised form makes the tax handling more explicit:
- Item 1a (Tax-paid): $200 making tax for each machinegun or destructive device—and it specifically calls out payment options including credit/debit and pay.gov.
- Item 1b (Tax-paid): $0 tax payment for “other types of firearms,” and it clearly states you don’t complete the payment section (Item 19) when the tax is $0.
- New/clearer tax-exempt pathway: There’s also an explicit tax-exempt option referencing 26 U.S.C. 7801/7805, with a note ATF may request supporting documentation (e.g., documents, photos, etc.).
2) Revised Structure and “User-Friendly” Clean-Up
This version is visibly designed to be easier to follow, with clearer instructions and modern submission language (including eForms references).
3) Updated Electronic Signature Options
The instructions now clearly allow:
- ATF eForms-generated signatures
- Handwritten ink signatures
- Other electronic signatures
4) Other Notable Updates (the “small stuff” that causes big delays)
- Race/ethnicity selections were updated (including a Middle Eastern/North African option and “select one or more”).
- Fillable/print handling improved: the form may be downloaded and filled/signed electronically, and it does not have to be printed front-to-back.
- Pay.gov integration details: the payment section notes that eForms/pay.gov filings may have an internal tracking number not listed in the payment box.
Section 3: Why These Changes Matter
Less friction, fewer “kicked back” applications
The updated tax language and signature guidance reduce the classic errors that trigger rejections/returns (wrong payment handling, wrong signature method, incomplete payment fields).
Time + convenience
The form explicitly supports modern workflow: pay.gov, electronic fill/sign, and clearer “what applies when” instruction language.
Proposed joint registration for married couples
ATF has proposed allowing spouses to jointly register NFA firearms without creating a trust. This remains a proposal, rather than an implemented Form 1 filing option. Follow the current application instructions.
Section 4: How These Changes Affect You
For individual applicants
- Clearer “what to fill out / what to skip” based on tax status and submission method.
- Explicit acceptance of eForms/e-signature pathways (per instructions).
For trusts, corporations, and other entities
- The instructions reiterate entity existence documentation requirements and responsible-person packet expectations (Form 5320.23, etc.).
For firearms dealers / manufacturers
- Cleaner payment and submission mechanics help reduce customer delays and “what did ATF mean here?” confusion.
- The form still expects correct entity documentation and responsible-person handling—areas that commonly create downstream compliance headaches if mishandled.
- Under the established filing process, qualified NFA manufacturers report manufactured firearms on Form 2 rather than Form 1.
Section 5: What You Need to Do Next
How to submit Form 1 (updated workflow)
- Get the current Form 1 directly from ATF’s forms library.
- Choose the correct application type (tax-paid vs. tax-exempt) and follow the updated payment guidance (especially $0 = don’t fill Item 19).
- Use an approved signature method (eForms / ink / other electronic signature).
- If applying as an entity: provide the required entity documentation or qualifying certification, and complete the applicable responsible-person requirements.
Key documents you may need
- Entity documentation (trust/corporate/other legal entity) if applicable
- Any supporting documentation if claiming a tax-exempt status under the listed authority
How FFLGuard Helps You Navigate the Process
A revised form can affect how your business answers customer questions and handles paperwork. FFLGuard connects compliance professionals and firearms counsel from DAY ONE to help FFLs review those changes and apply consistent procedures.
PREVENT. RESPOND. DEFEND.
FFLGuard recommends that clients follow its established NFA procedures and consult its team before changing their making or registration practices.
Start with How FFLGuard Works, then explore the Law Plus Guidelines. The LPGs help clients establish practices and documentation that can support a defense before an ATF issue arises. That same coordinated team helps clients respond to ATF concerns and defend covered regulatory matters.
Find your plan or contact our team to discuss your business’s needs.