ATF Fingerprint Rule Proposal Could Ease NFA Paperwork

Published: August 10, 2026 at 3:59 PM MST

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Updated August 10, 2026: An ATF fingerprint rule proposal could reduce the amount of paperwork submitted with many National Firearms Act and federal firearms license applications. The proposal would allow applicants to use a copy or scan of photo identification instead of a separate passport-style photograph and would change how many fingerprint sets several applicant groups must provide.

The changes are not yet in effect. The Bureau of Alcohol, Tobacco, Firearms and Explosives published the notice of proposed rulemaking on July 6, and comments remain open through October 5, 2026. Until ATF publishes a final rule with an effective date, applicants must continue following the requirements on the current forms.

The proposal, identified as RIN 1140-AA63 and docket ATF-2026-0397, applies differently to individual NFA applicants, responsible persons for trusts and other entities, and applicants for licenses under the Gun Control Act. Understanding those distinctions is essential because the rule would not eliminate identity checks or background checks.

What the ATF fingerprint rule proposal would change

ATF’s official rulemaking summary divides the proposed changes into fingerprint and photograph requirements.

For individual applicants using NFA Forms 1, 4, or 5, the proposal would reduce the fingerprint requirement from two sets to one. An individual filing a Form 1 to make and register an NFA firearm or participating in a Form 4 transfer would therefore still submit fingerprints, but only one properly completed set.

For responsible persons associated with a trust, corporation, or other entity filing an NFA application, the change would be larger. Those responsible persons generally would no longer submit fingerprints with every Form 23. ATF could subsequently request one set when fingerprints are needed to resolve an identity or criminal-history issue during the background check.

ATF estimated that fewer than 1 percent of NFA responsible-person applicants would later be asked for fingerprints. That estimate is an agency projection, not a guaranteed processing outcome.

Applicants and responsible persons seeking a federal firearms license under the Gun Control Act would continue providing one fingerprint set. The proposed rule does not reduce that requirement.

Photo ID copies could replace passport-style photographs

Current regulations generally call for a 2-by-2-inch passport-style photograph from affected individual applicants and responsible persons. Under the proposal, every covered applicant group could instead submit a clear copy, scan, or similar reproduction of a qualifying photo identification document.

An applicant could still submit a traditional passport-style photograph if preferred. ATF would also retain authority to request one when a photo-ID copy is unclear, unacceptable, or insufficient to establish identity.

The Federal Register proposal says advances in scanning and digital imaging now allow photo-ID copies to serve the identity-verification purpose previously associated with a separate photograph. ATF estimated that applicants choosing a photo-ID copy could avoid approximately $17 in photograph costs per paper application.

Digital fingerprints would be formally recognized

The proposal would also place the existing practice of submitting digital fingerprints and photographs into ATF’s regulations. Electronic fingerprint files are already widely used in modern NFA application workflows, but the rule would expressly recognize digital submission rather than relying primarily on form instructions and agency practice.

ATF’s proposal also states that individuals could take and submit their own fingerprints on an FBI FD-258 card or with digital fingerprint equipment, provided the impressions are clear enough to be accurately identified. That does not mean any image of a fingerprint would qualify; the submission would still need to meet the applicable format and quality requirements.

For applicants following current processing trends, Gun Place’s earlier review of ATF Form 4 wait times in 2026 provides additional context on how electronic applications and background-check processing are performing.

What the proposal would not eliminate

The proposed rule would reduce supporting paperwork, not remove the application or approval process.

Individual NFA applicants would still submit fingerprints. Responsible persons would still complete Form 23 and undergo the required review, even if fingerprints were not routinely attached. ATF could request prints when necessary to resolve a background-check issue.

The proposal would not eliminate Form 1, Form 4, Form 5, Form 7, or the NFA registration process. It also would not change whether a person is prohibited from possessing firearms or override federal, state, or local restrictions.

The distinction matters because a proposal to reduce documentation can easily be mistaken for a proposal to end background checks. The text does not do that. Its stated purpose is to rely more heavily on biographical information for routine checks while preserving fingerprint requests for cases that require additional identity resolution.

Estimated savings for applicants and responsible persons

ATF’s economic analysis estimates different savings depending on the applicant and submission method.

For NFA individuals filing on paper, ATF estimated combined savings of approximately $42 per application from submitting one fingerprint card instead of two, using a photo-ID copy instead of obtaining a passport photograph, and avoiding related time costs.

For NFA responsible persons, ATF estimated savings of approximately $100 for paper submissions or $99 for electronic submissions when fingerprints are not required. A small portion of those savings would be lost when ATF later requests prints.

These figures are regulatory estimates rather than promised retail prices. Actual costs depend on local fingerprinting services, electronic fingerprint providers, photography costs, and the number of responsible persons associated with an entity.

How and when the public can comment

Comments must be submitted or postmarked by October 5, 2026, and must identify RIN 1140-AA63. Electronic comments may be filed through the federal rulemaking docket. ATF’s notice warns that material placed in the public portion of a comment may appear online, so commenters should review the agency’s privacy instructions before including personal or proprietary information.

After the comment period closes, ATF may issue a final rule, revise the proposal, publish another proposal, or withdraw it. As Gun Place explained in its overview of what happens after ATF comment windows close, submission of a proposal does not guarantee that the same language will become final.

Gun Place will continue monitoring RIN 1140-AA63 and related developments in its Legal & Regulatory coverage.

This article is for general informational purposes and is not legal advice. Applicants should follow the current ATF forms and instructions unless and until a final rule becomes effective.

Sources

• ATF: Fingerprint and Photograph Requirements for Firearms Applications
• Federal Register: RIN 1140-AA63 proposed rule
• Regulations.gov: Docket ATF-2026-0397

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