ATF Compliance Inspection Guide: What Every FFL Needs to Know

What Is an ATF Compliance Inspection?

An ATF compliance inspection is an on-site review of your federal firearms license operation conducted by an ATF Industry Operations Inspector (IOI). The purpose is to verify that you're operating within the scope of your license type, maintaining required records accurately, and complying with all federal firearms laws and regulations.

Inspections are not investigations. They are regulatory audits — the firearms equivalent of an IRS audit. The IOI is checking your paperwork, your processes, and your physical inventory. They are not there because you did something wrong (though inspection findings can trigger follow-up action if violations are serious).

The legal authority for inspections comes from 18 U.S.C. § 923(g), which authorizes the ATF to conduct compliance inspections during business hours without a warrant, provided the inspection is limited in scope to firearms records and inventory.

Types of ATF Inspections

Compliance Inspection

The standard, routine inspection. The IOI reviews your records for completeness and accuracy, conducts a physical inventory check, and verifies that your operation matches your license. This is what most FFLs experience.

Application Inspection

Conducted when you first apply for an FFL or when you renew. The IOI visits your proposed premises, verifies your physical location, reviews your security setup, and conducts an in-person interview.

Trace Inspection

Triggered when the ATF needs to trace a specific firearm — typically one recovered at a crime scene. The IOI will ask to see the A&D records and Form 4473 for a specific serial number. These are usually quick and narrowly focused.

Follow-Up Inspection

Conducted after a previous inspection identified violations. The IOI returns to verify that you've corrected the issues. Follow-ups are typically scheduled and announced.

What the IOI Will Review

A standard compliance inspection covers four primary areas. Understanding what's being checked is the foundation of being prepared.

1. ATF Form 4473 Records

The IOI will pull a sample of your completed 4473s and review them for completeness, accuracy, and proper execution. They're checking:

• All required fields completed — no blanks
• Buyer information matches the ID presented
• All eligibility questions (21.a–21.n) answered
• Signatures and dates present in all required sections
• NICS transaction number, response, and date recorded
• Firearm description matches the A&D entry
• Current form revision in use
• Denied and non-completed forms properly retained

The sample size depends on your transaction volume. High-volume dealers may have 50–100+ forms reviewed. Smaller operations may have every form from the past year examined.

2. Acquisition & Disposition (A&D) Records

Your bound book is cross-referenced against your 4473 files and your physical inventory. The IOI checks:

• Every firearm in your physical inventory has a corresponding acquisition entry
• Every disposition entry has a corresponding 4473 (for non-licensee transfers)
• Serial numbers match across all records
• Entries are timely — acquisitions logged by close of next business day, dispositions logged at time of transfer
• Manufacturer/importer recorded correctly (not just brand name)

3. Physical Inventory

The IOI will count firearms on your premises and compare the count to your A&D book. Firearms present without entries, or entries without corresponding firearms, are inventory discrepancies — one of the most serious findings an inspection can produce.

4. Multiple Sale Reports

The IOI cross-references your A&D records to identify instances where the same buyer received two or more handguns within five consecutive business days. If those transactions exist without a corresponding Form 3310.4, that's a finding.

Your Rights During an Inspection

Compliance inspections are mandatory — you cannot refuse one and keep your license. But you do have rights:

• Business hours only. The ATF can only conduct inspections during your normal business hours. They cannot demand access at 6 AM on a Sunday.
• Scope limitation. The inspection is limited to firearms records, inventory, and premises. The IOI cannot search your personal vehicle, your home (unless it's your licensed premises), or records unrelated to your firearms business.
• One routine inspection per year. Under 18 U.S.C. § 923(g)(1)(B), the ATF is limited to one compliance inspection per 12-month period. Trace inspections, criminal investigations, and follow-ups do not count toward this limit.
• You can have an attorney present. You are not required to, but you have the right. Most routine inspections don't require legal counsel, but if you anticipate significant findings, it's worth considering.
• You can ask for identification. Verify the IOI's credentials before providing access to your records.
• You can take notes. Document what the IOI reviewed, what questions were asked, and what findings were discussed.

The Most Common Inspection Findings

ATF inspection data consistently shows the same categories of violations year after year. These are not obscure technicalities — they're the basics.

Form 4473 Violations

Form 4473 errors account for seven of the top ten ATF compliance findings. The most common:

• Missing or incomplete buyer information
• Blank eligibility questions
• Missing signatures or dates
• NICS documentation failures (no NTN, no response recorded)
• Serial number mismatches between the 4473 and A&D book
• Using an outdated form revision

A&D Record Violations

• Missing acquisition entries (firearms in inventory with no record)
• Missing disposition entries (no record of where a firearm went)
• Late entries
• Incomplete entries (missing manufacturer, caliber, or source information)
• Serial number transcription errors

Inventory Discrepancies

• Firearms on premises without A&D entries
• A&D entries without corresponding firearms or disposition records

Other Common Findings

• Missing Form 3310.4 reports
• Operating outside license scope
• Failure to report theft or loss within 48 hours
• Improper storage of records (not on licensed premises)

What Happens After the Inspection

No Violations Found

The IOI completes the inspection report and you receive a letter confirming no violations were identified. This is the goal.

Minor Violations — Report of Violations

The most common outcome. The IOI issues an ATF Form 5030.5 (Report of Violations) listing every finding. You'll be asked to acknowledge the findings and describe corrective actions. For minor, first-time violations, this is typically the end of it — fix the issues, document your corrections, and move on.

Significant Violations — Warning Conference

If violations are numerous or serious, the ATF may schedule a warning conference with your local Area Supervisor. This is a formal meeting where the ATF presents the findings, discusses the severity, and gives you an opportunity to respond. A warning conference is a serious signal — it means the ATF is considering further action.

Revocation Proceedings

In the most serious cases — willful violations, repeat violations after prior warnings, or patterns that suggest negligence or intentional non-compliance — the ATF can initiate license revocation proceedings. You have the right to a hearing before an administrative law judge.

How to Prepare: The Pre-Inspection Checklist

The time to prepare is now — not the morning an IOI walks through your door. Build these practices into your regular operations and an inspection becomes a non-event.

Records Readiness

• 4473 files organized and accessible. Alphabetically, chronologically, or by transaction number — pick a system and stick to it. The IOI should be able to request any form and have it in hand within minutes.
• A&D book current. No backlog. Every firearm that's on premises has an acquisition entry. Every firearm that left has a disposition entry.
• Denied and voided 4473s retained separately. Not mixed in with completed transactions.
• 3310.4 copies filed and cross-referenced.
• Current form revision only. Destroy old form stock when a new revision becomes mandatory.

Inventory Readiness

• Conduct quarterly physical inventory counts. Count every firearm. Reconcile against your A&D book. Resolve discrepancies immediately and document the resolution.
• Monthly spot checks. Pull 10–15 random serial numbers from your A&D book. Verify the physical firearm is present or has a disposition entry.
• Firearms in transit. Know which firearms are out for repair, on loan to law enforcement, or otherwise off-premises with documentation.

Staff Readiness

• Every employee who handles firearms or processes 4473s should understand the inspection process. They should know where records are kept, how the filing system works, and who the IOI should speak with.
• Designate a point person. When the IOI arrives, one person should manage the interaction — provide records, answer questions, and take notes.
• Train on 4473 review procedures. The best way to prevent inspection findings is to catch errors before the form goes into the file.

Self-Audit Program

The single most effective inspection preparation tool is a regular self-audit. Review your own records the way an IOI would:

• Pull 20 random 4473s per month — check every field
• Cross-reference 10 dispositions against A&D entries
• Verify 10 random serial numbers against physical inventory
• Check for multiple handgun sales that should have triggered a 3310.4
• Document what you found and what you corrected

Inspection Day: Step by Step

• The IOI arrives and presents credentials. Verify their identity. They'll explain the purpose and scope of the inspection.
• Provide access to your records. 4473 files, A&D book, 3310.4 copies, and any other required records. Have them organized and ready.
• The IOI reviews records. This takes hours — sometimes a full day or more for high-volume dealers. They may ask questions as they go. Answer directly.
• Physical inventory count. The IOI counts firearms on premises and reconciles against your book. Help facilitate access to all storage locations.
• Exit briefing. The IOI will discuss preliminary findings with you before leaving. This is your opportunity to ask questions, provide context, or correct misunderstandings.
• Written report follows. The formal Report of Violations (if any) arrives by mail. Review it carefully. Implement corrections. Document everything.

The Digital Advantage in ATF Inspections

FFLs using electronic 4473 and digital bound book systems consistently report smoother, faster inspections. The reasons are straightforward:

• Instant retrieval. Pull any form by name, date, serial number, or transaction number in seconds — not minutes digging through filing cabinets.
• Legibility. No handwriting interpretation issues. Every field is typed.
• Completeness. Digital systems enforce required fields — blank fields and missing signatures don't make it into the file.
• Cross-referencing. Integrated systems automatically link 4473s to A&D entries. Serial number mismatches are flagged at the point of sale, not during an inspection.
• Audit trail. Every action is logged with timestamps. The IOI can see exactly when a form was completed, signed, and filed.