ATF's New Era of Reform: What Every FFL Needs to Know in 2026
The Bureau of Alcohol, Tobacco, Firearms and Explosives is undergoing the most significant policy overhaul in its recent history. Under new leadership and a clear directive from the Department of Justice, the ATF has rolled back enforcement policies that defined the previous administration's approach to FFL oversight and replaced them with a framework that prioritizes public safety outcomes over paperwork technicalities.
For federal firearms licensees, these changes affect virtually every aspect of day-to-day compliance — from how inspections are conducted, to what violations trigger revocation, to how the Form 4473 itself will look in the near future.
This guide breaks down every major change, what it means for your operations, and what you should be doing right now to stay ahead of the curve.
The End of Zero Tolerance
On April 7, 2025, the ATF formally repealed the Enhanced Regulatory Enforcement Policy — commonly known as the "Zero Tolerance Policy." Under the previous administration, this policy required ATF Industry Operations Investigators to initiate license revocation proceedings for certain categories of violations regardless of context, frequency, or severity.
The practical effect was devastating for many FFLs. A single clerical error on a Form 4473 — a transposed digit, a missed checkbox, an incomplete address — could trigger the same enforcement response as a pattern of willful noncompliance. Dozens of FFLs lost their licenses and their livelihoods over mistakes that posed no threat to public safety.
That policy is now gone. In its place, the ATF has published ATF Order 5370.1H, a new administrative action framework that draws a clear line between genuine compliance failures and honest mistakes.
What this means for you: If you lost your license or surrendered it under the Enhanced Regulatory Enforcement Policy, the ATF is actively encouraging you to reapply. Your application will be evaluated under the new policy — not the old one.
ATF Order 5370.1H: The New Inspection Framework
The new Administrative Action Policy, formalized in ATF Order 5370.1H on May 6, 2025, establishes a tiered approach to compliance violations. Understanding these tiers is critical for every FFL because they determine what happens when an inspector finds a problem. For a deeper dive into the inspection process itself — including a pre-inspection checklist — see our ATF Inspection Survival Guide 2026.
Violations That Still Trigger Revocation
Certain violations remain serious enough to warrant license revocation when committed willfully. These include:
Transferring firearms to prohibited persons or deliberately avoiding NICS denials
Refusing to conduct required Brady Act background checks
Falsifying or misrepresenting information on records or license applications
Refusing to respond to ATF trace requests within 24 hours
Repeatedly refusing ATF right of entry for inspection
Allowing prohibited employees to possess firearms on your premises
The key word in every one of these is "willfully." Under the new policy, the ATF must establish that the FFL acted with intentional disregard of a known legal duty or with plain indifference to their legal obligations. An honest mistake — even a serious one — is not the same as willful noncompliance.
Warning Conferences
For violations that are less severe or appear to be repetitive but accidental, the ATF will now use warning conferences as the primary corrective mechanism. During a warning conference, you'll meet with ATF officials to discuss the violations, present your corrective action plan, and demonstrate your commitment to compliance.
Examples of violations that typically warrant a warning conference rather than revocation include isolated failures to obtain a Form 4473, isolated failures to timely report theft or loss, certain percentages of non-compliant 4473s, unfiled multiple sales reports, and instances of unauthorized manufacturing.
The ATF will evaluate your response. If you arrive with a documented plan — even something as straightforward as a revised checklist for your counter staff — that demonstrates you've taken the issue seriously, the conference is likely to end with corrective guidance rather than enforcement action.
Warning Letters
For violations that merit formal documentation but don't rise to the level of a warning conference, the ATF will issue warning letters. These are appropriate for issues like failing to timely maintain acquisition and disposition records, minor gaps in multiple sale report filings, incomplete transferee identification, or inaccurate but non-fraudulent Form 4473 entries.
A warning letter goes into your file and will be reviewed during your next inspection. If the same issue appears again, it may escalate to a warning conference. If you've corrected it, the letter serves as evidence that you identified and resolved the problem.
Factors the ATF Considers
Under the new framework, inspectors are directed to evaluate several contextual factors before recommending any administrative action:
Whether your continued operations pose a threat to public safety or contribute to violent crime
Whether you self-reported the violations before the inspection discovered them
Your acceptance of responsibility and demonstrated ability to achieve compliance
Whether violations were employee-driven, and whether you took corrective employment actions afterward
Your overall inspection history and pattern of compliance
Self-reporting is particularly significant under the new policy. If you discover an error in your records and proactively report it to the ATF before an inspection reveals it, that works strongly in your favor during any subsequent evaluation.
Uniform Inspections Nationwide
One of the most impactful changes for FFLs operating in multiple jurisdictions or comparing notes with peers in other states: the ATF has committed to ensuring uniform inspection and enforcement practices across all 25 field divisions.
Previously, the experience of an ATF inspection could vary dramatically depending on which field division you fell under and which IOI conducted the review. Some divisions applied standards more strictly than others, and FFLs in certain regions faced scrutiny that FFLs elsewhere did not.
Under the new framework, inspection protocols are being standardized so that an FFL in Texas receives the same treatment and is held to the same standards as an FFL in California or New York. This doesn't mean enforcement will be lenient — it means it will be consistent and predictable.
The Simplified Form 4473
The ATF has announced that a revised, simplified ATF Form 4473 is in development. The stated goal is to make the form more concise and user-friendly for both purchasers and FFLs.
While the final version has not yet been released — see our complete guide to the simplified 4473 for a deeper analysis — the direction is clear: reduce the form's complexity to reduce the number of unintentional errors that have historically accounted for the majority of compliance findings during inspections.
This is significant because Form 4473 errors have consistently ranked among the top ATF compliance violations. Seven of the ten most commonly cited inspection findings relate directly to the 4473. By simplifying the form itself, the ATF is addressing the root cause of many compliance issues rather than simply punishing the symptoms.
What FFLs should do now: Continue using the current version of the form (August 2023 revision, mandatory since February 2024) until the new version is officially released and mandated. When the simplified form drops, expect a transition period similar to previous revisions — the ATF will announce the form, provide a download, and set a mandatory use date.
If you're still using paper 4473s, the transition to a simplified form is another strong argument for moving to a digital 4473 system. Electronic systems can be updated immediately when form changes take effect, eliminating the risk of accidentally using an outdated version. They also enforce required-field completion and apply conditional logic automatically — two features that prevent the most common 4473 errors regardless of which version of the form is in use.
Additional Reform Measures
Beyond the headline changes, the ATF's reform agenda includes several additional measures that affect FFL operations:
Brady Chart Revisions: The ATF is publishing changes to the Permanent Brady Permit Chart, which determines whether a state-issued firearms permit can substitute for a NICS background check at the point of sale. Revisions may expand the number of qualifying state permits, potentially streamlining transactions for customers who hold them.
$0 NFA Tax Stamp: The federal tax on suppressors, SBRs, SBSs, and AOWs dropped to $0 on January 1, 2026. For FFLs handling NFA transfers, the compliance requirements remain unchanged — only the tax line item is gone. See our $0 NFA Tax Stamp: Complete FFL Dealer Guide for updated forms and workflows.
Form 20 Simplification: The ATF Form 20 — used to request authorization to transport registered NFA items interstate — is being converted from a permission-based system to a simplified notification-based system. For FFLs who regularly transport NFA inventory between locations or to events, this eliminates a significant administrative burden.
Electronic Signatures on NFA Forms: A new ruling allows electronic signatures on NFA forms, modernizing a process that previously required wet signatures in many contexts.
NICS Alert Policy Reform: NICS alerts are now restricted to federal firearms trafficking violations only. Previously, alerts had been used more broadly to flag non-criminal compliance issues, creating confusion and unnecessary disruption for legitimate dealers.
Comprehensive Regulation Review: The ATF is conducting a full review of existing regulations with the goal of identifying and eliminating outdated, duplicative, or unnecessary rules. This review specifically includes the regulatory framework surrounding stabilizing braces (Final Rule 2021R-08F) and the definition of "engaged in the business" of firearms dealing (Final Rule 2022R-17F).
Industry Partnership Liaison: A new Senior Industry Partnership Advisor/Liaison position has been established within the Office of the ATF Director to serve as a direct channel for industry concerns. This creates an official point of contact for FFLs and trade organizations to raise issues without going through the traditional enforcement chain.
What You Should Do Right Now
The regulatory landscape has shifted significantly in favor of FFLs who operate in good faith. But "more lenient enforcement" is not the same as "no enforcement." The ATF is still conducting inspections, still reviewing records, and still revoking licenses for willful violations. The difference is that the bar for what constitutes a career-ending finding has been raised — and the process for addressing lesser violations is now more transparent and proportionate.
Here's what every FFL should be doing in response to these changes:
Audit your current compliance posture. Walk through your 4473 files, your A&D book, and your NICS records with fresh eyes. If you find errors, document them and correct them. Under the new policy, self-identified and self-corrected issues demonstrate exactly the kind of proactive compliance the ATF wants to see.
Document your training. The new framework considers whether violations were employee-driven and whether you took corrective action. Having a documented training program — even a simple one — shows that compliance is part of your operational culture, not an afterthought.
Prepare a corrective action plan template. If an inspector does find an issue, arriving at a warning conference with a written plan demonstrates seriousness. Don't wait until you need one to create one.
Consider digital compliance tools. The simplified 4473, electronic NFA signatures, and modernized record-keeping standards all point in the same direction: the ATF expects digital competence from modern FFLs. A digital 4473 system doesn't just reduce errors — it creates an auditable trail that proves your compliance efforts during inspections.
See how Bravo's E4473 handles this → Our digital 4473 system enforces required fields, applies conditional logic automatically, and gives you instant retrieval during inspections. Request a demo to see how it works with the current form — and how it'll seamlessly update when the simplified version drops.
Stay informed. The ATF's reform agenda is still in progress. Additional rulings, form revisions, and policy updates are expected throughout 2026. Subscribe to ATF updates, follow industry trade groups, and monitor compliance resources to ensure you're operating under the current rules — not last year's.
The ATF has explicitly stated that this is a "new chapter" built on "transparency, accountability, and partnership with the firearms industry." For FFLs who have spent years operating under uncertainty and fear of disproportionate enforcement, that's a meaningful shift. The opportunity now is to use this window to strengthen your compliance foundation so that when the next inspection comes — under whatever policy framework exists at that point — your records speak for themselves.