ATF Inspection Survival Guide 2026: What's Changed Under the New Administrative Action Policy
If you're an FFL, an ATF compliance inspection is a matter of when — not if. There are approximately 136,000 active FFLs in the United States and roughly 816 Industry Operations Investigators conducting inspections. The ATF's stated goal is to inspect every FFL at least once every three years, though many dealers go longer between visits and higher-risk FFLs may be inspected more frequently.
What's changed in 2026 isn't whether inspections happen — it's how the results are handled. The repeal of the Enhanced Regulatory Enforcement Policy — part of the ATF's broader New Era of Reform — and the implementation of ATF Order 5370.1H have fundamentally rewritten the rules for what happens when an inspector finds a violation. For FFLs who understand the new framework and prepare accordingly, inspections are less threatening than they've been in years. For FFLs who assume "zero tolerance is gone" means they can relax their standards, the risk hasn't disappeared — it's just been recalibrated.
This guide covers the current inspection process, the new violation tiers, what inspectors are actually looking for, and a practical preparation checklist for 2026.
How ATF Inspections Work
The basic mechanics of an ATF compliance inspection haven't changed under the new policy. Understanding the process helps reduce the anxiety that causes many FFLs to make avoidable mistakes during an inspection.
The Arrival
Inspections are unannounced and conducted during your regular business hours. An Industry Operations Investigator will arrive at your business premises, present their ATF credentials, and explain the purpose of their visit. They'll also provide their contact information for follow-up questions.
You are legally required to allow the IOI access to your business premises, inventory, and records. Refusing entry is considered a willful violation of the Gun Control Act and will result in ATF pursuing revocation of your license. This hasn't changed under the new policy — and it's one of the violations where the consequences remain severe regardless of circumstances.
The ATF is generally limited to one compliance inspection per twelve-month period. However, they may contact you at any time regarding records that relate to a firearm involved in a criminal investigation, and inspections of off-site storage locations may also occur.
What They Review
IOIs will examine several key areas during the inspection:
Acquisition and Disposition records. Your A&D book is the foundation of every inspection. Investigators will verify that every firearm you've acquired has a corresponding entry with complete information — serial number, manufacturer, model, type, caliber, date of acquisition, and source. They'll check that every disposition has the corresponding detail: date of transfer, transferee information, and method of disposition. Gaps, missing entries, late entries, and inconsistencies between your A&D records and your physical inventory are primary areas of focus.
Form 4473 files. Investigators will pull a sample of your completed 4473s and review them for completeness and accuracy. Common findings include missing buyer information, incomplete eligibility responses, missing or incorrect NICS transaction numbers, undated signatures, and forms completed on outdated revisions. A simplified version of the 4473 is in development — but until it's released, the current form and its pain points are what inspectors will review.
NICS records. The IOI will verify that background checks were conducted for every applicable transfer and that the results were properly documented. Particular attention is paid to delayed transactions — situations where the NICS check returned a "Delay" response and the three-business-day period elapsed before a final determination. How you handled those transactions matters.
Physical inventory. The investigator will typically conduct a physical count of your firearms inventory and compare it against your A&D records. Discrepancies — firearms in your inventory that don't appear in your records, or entries in your records for firearms that can't be located — are taken seriously because they directly impact the traceability of firearms.
Multiple sale reports. ATF Form 3310.4 is required when you sell or dispose of two or more handguns to the same buyer within five consecutive business days. Inspectors verify that these reports were filed correctly and on time.
NFA records (if applicable). If you hold NFA items, your Form 3, Form 4, and NFA-specific A&D entries will be reviewed for accuracy and completeness. With the $0 NFA tax stamp driving a surge in NFA transfers, keeping these records clean is more important than ever.
The Exit Interview
At the conclusion of the inspection, the IOI will sit down with you to review their findings. If violations were identified, the investigator will document them, explain each one, and note your response — including any corrective actions you've already taken or plan to take. You'll receive a copy of the signed report.
This exit interview is your opportunity to demonstrate accountability and cooperation. How you respond to findings directly influences what happens next under the new administrative action policy.
The New Violation Tiers Under ATF Order 5370.1H
This is where the 2026 landscape differs most dramatically from previous years. Under the old zero-tolerance framework, certain violation categories triggered automatic revocation proceedings regardless of context. Under the new framework, the ATF evaluates each situation individually based on the nature of the violation, its severity, its intent, and the FFL's response.
Tier 1: Revocation
License revocation is reserved for willful violations that pose direct threats to public safety. The key legal standard is "willfulness" — the ATF must establish that the FFL acted with intentional disregard of a known legal duty or with plain indifference to their legal obligations.
Violations in this tier include transferring firearms to persons you knew or should have known were prohibited, deliberately avoiding or circumventing NICS background check requirements, falsifying information on ATF forms or records, refusing to respond to trace requests within the required 24-hour window, repeatedly refusing to allow ATF inspections, and knowingly allowing prohibited individuals to access or possess firearms on your premises.
A single willful violation in any of these categories is sufficient basis for revocation under both the old and new policies. The difference is that the new policy requires a genuine finding of willfulness rather than treating certain error categories as presumptively willful.
Tier 2: Warning Conference
Warning conferences are the primary corrective mechanism for violations that are serious but appear to be accidental, negligent, or the result of systemic issues rather than intentional misconduct.
During a warning conference, you'll meet with ATF representatives to discuss the findings in detail. You'll be asked to present a corrective action plan that identifies the root cause of the violations and outlines specific steps you'll take to prevent recurrence. The ATF will evaluate your plan's adequacy and may provide coaching and education if they believe your approach can be strengthened.
Situations that typically warrant a warning conference include isolated failures to obtain a Form 4473 when one was required, isolated failures to report lost or stolen firearms within the 48-hour requirement, a significant percentage of 4473s with errors (though not at a level suggesting deliberate falsification), unfiled or late-filed multiple sale reports, and instances of unauthorized manufacturing.
The ATF retains a copy of your corrective action plan and will reference it during your next inspection. If the same violations recur, the fact that you had a plan in place and failed to follow it will weigh against you. If the violations are resolved, the warning conference serves as documentation that you identified and corrected the issue.
Tier 3: Warning Letter
Warning letters address violations that require formal documentation but don't rise to the level of a face-to-face conference. They serve as official notice that a specific issue was identified and that continued occurrence could result in escalation.
Common scenarios for warning letters include failure to maintain timely or accurate A&D records (minor gaps, late entries, formatting issues), a smaller number of unfiled or incomplete multiple sale reports, incomplete transferee identification on a limited number of transactions, and inaccurate but clearly non-fraudulent entries on Form 4473s.
A warning letter goes into your inspection file. If your next inspection reveals the same issue, it will likely escalate to a warning conference. If the issue is resolved, the letter documents that you were notified and responded appropriately.
Tier 4: Report of Violations
For minor infractions that don't warrant formal action, the IOI will issue a Report of Violations documenting what was found. This is the lightest level of official response — it puts the finding on record without triggering any administrative process.
Factors That Work in Your Favor
Under ATF Order 5370.1H, several mitigating factors can influence the outcome of an inspection:
Self-reporting. If you discover a compliance issue and report it to the ATF before an inspection reveals it, that proactive disclosure weighs strongly in your favor. Self-reporting demonstrates that you're monitoring your own compliance and that you prioritize transparency over concealment.
Documented training programs. Having records that show your staff receives regular compliance training demonstrates organizational commitment to lawful operations. It also provides context when violations are employee-driven — showing that you provided the tools and education to prevent errors, even if a specific employee failed to follow procedures.
Corrective employment actions. If a violation was caused by a specific employee's conduct and you took appropriate corrective action (retraining, reassignment, or termination depending on severity), documenting that response shows accountability.
Cooperation and acceptance of responsibility. FFLs who acknowledge findings honestly, avoid making excuses, and engage constructively with the IOI's feedback consistently receive more favorable treatment than those who become defensive or dismissive.
Clean inspection history. If your previous inspections showed no violations or showed violations that were subsequently corrected, that track record provides important context for any new findings.
Your 2026 Pre-Inspection Checklist
You can't predict when your next inspection will happen, but you can ensure you're prepared when it does. This checklist covers the areas that IOIs focus on most heavily and the documentation that supports a positive outcome under the new framework.
Records
Verify that your A&D book is current, with every acquisition and disposition recorded completely and accurately. Conduct a physical inventory count and reconcile it against your A&D records — any discrepancies should be investigated and resolved before an inspection finds them. Review a sample of your recent 4473s for completeness, checking especially for the common error points: eligibility question responses, NICS transaction numbers, dates, and signatures. Confirm that all multiple sale reports have been filed correctly and on time. If you handle NFA items, verify that your NFA-specific records (Form 3s, Form 4s, NFA inventory) are complete and current.
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Compliance Infrastructure
Confirm that you're using the current mandatory version of Form 4473 (August 2023 revision) and that no outdated forms are in circulation anywhere in your operation. Verify that your NICS procedures are clearly documented — including how delayed transactions are handled and how the three-business-day rule is applied. Ensure that your loss and theft reporting procedures are documented and that all staff know the 48-hour ATF reporting requirement.
Documentation for Inspectors
Prepare a brief overview of your compliance program, including any training you provide, SOPs you follow, and quality checks you perform. If you identified and self-corrected any issues since your last inspection, have that documentation ready to present. If you received a warning letter or report of violations from a previous inspection, have documentation showing what corrective actions you took in response.
Staff Preparation
Ensure every employee who handles firearms transactions understands the inspection process, knows what an IOI will ask for, and knows not to volunteer information beyond what's requested. Brief your team on cooperating fully while maintaining professionalism. Designate a primary point of contact who will work with the IOI during the inspection — typically the owner or compliance officer.
The Bottom Line
ATF inspections in 2026 are more predictable, more proportionate, and more focused on public safety outcomes than they've been in recent years. The new framework rewards FFLs who invest in compliance, self-monitor their operations, and respond constructively to findings.
But the inspection itself is still a serious event with serious potential consequences. The ATF hasn't stopped revoking licenses — they've narrowed the circumstances under which revocation is the appropriate response and created a structured pathway for addressing everything else.
The FFLs who come through inspections cleanly aren't the ones with zero mistakes. They're the ones with documented processes, trained staff, current records, and the humility to acknowledge and correct errors when they occur. The new policy framework makes that approach more effective than it's ever been.
Prepare accordingly.