FFL Compliance Guide 2026: Every ATF Rule, Violation, and Inspection Checklist for Federal Firearms Licensees

Updated February 2026 — Based on ATF FY 2024 inspection data (published 2025). Written by the team whose compliance software has been audited by the ATF hundreds of times with zero infractions.

In fiscal year 2024, the ATF conducted 9,696 compliance inspections across the 128,690 active federal firearms licensees in the United States. The results were sobering: only 54% of inspected FFLs had zero violations. Approximately 100,000 individual violations were documented. 195 licenses were revoked — a 122% increase from 88 revocations in FY 2022.

The message from the ATF is unambiguous: compliance errors that were once treated as minor clerical issues now carry the potential to end your business.

This guide is the single reference document every FFL needs. It covers the complete ATF compliance framework — what the regulations actually require, what inspectors actually look at, what violations actually get FFLs in trouble, and exactly how to build systems that keep your license protected. Every section is grounded in current ATF regulations, official inspection data, and the operational reality of running a firearms business in 2026.

Bookmark this page. Share it with your staff. Review it quarterly. Your FFL depends on it.

Table of Contents

1. ATF Inspection by the Numbers: FY 2024 Data
2. The ATF Inspection Process: What Actually Happens
3. ATF Form 4473: The #1 Source of FFL Violations
4. Acquisition & Disposition (A&D) Bound Book Requirements
5. NICS Background Check Procedures
6. Multiple Sale Reporting (Form 3310.4)
7. Record Retention Requirements
8. What Triggers License Revocation
9. Inspection Outcomes: From No Violations to Revocation
10. The FFL Compliance Checklist: Daily, Weekly, Monthly, Annual
11. Digital vs. Paper Records: The Compliance Case for Going Digital
12. Frequently Asked Questions

1. ATF Inspection by the Numbers: FY 2024 Data

Before diving into the rules, understand the enforcement landscape you're operating in. These numbers are directly from the ATF's published FY 2024 compliance inspection results.

128,690 — Active federal firearms licensees in the United States

9,696 — Compliance inspections conducted in FY 2024

5,207 (54%) — Inspections with no violations found

1,689 (17%) — Inspections resulting in a report of violations

721 — Warning letters issued

214 — Warning conferences held

1,488 — Licenses surrendered or businesses closed

195 — Licenses revoked

~100,000 — Total individual violations documented across all inspections

The trajectory is clear. FFL revocations have increased dramatically: 88 in FY 2022, 157 in FY 2023, 195 in FY 2024. While a change in enforcement posture under the current administration may alter this trajectory going forward, the underlying regulations have not changed. The ATF's "zero tolerance" policy for specific willful violations — transferring to a prohibited person, failing to run a background check, falsifying records, failing to respond to a trace, or refusing an inspection — remains the enforcement framework.

The practical takeaway: nearly half of all FFLs inspected in 2024 had at least one violation. The difference between a minor corrective action and losing your license often comes down to whether your violations are classified as "willful" — and whether you have a documented history of the same issues. Your compliance systems, your records, and your daily habits determine that outcome.

2. The ATF Inspection Process: What Actually Happens

Understanding the inspection process removes the uncertainty. Here is exactly what happens when an ATF Industry Operations Investigator (IOI) shows up at your shop.

When and Why Inspections Happen

The ATF is authorized to conduct one warrantless compliance inspection per FFL per 12-month period under the Gun Control Act. Inspections are generally unannounced and occur during your regular business hours. The ATF can also contact you at any time regarding records related to a specific firearm involved in a criminal investigation (trace requests).

Inspections are triggered by several factors: routine compliance scheduling, FFL license renewal, a high volume of crime gun traces linked to your shop, failure to respond to ATF trace requests, tips or complaints, prior violations, and geographic risk factors. The ATF's goal is to inspect every FFL at least once every three years, though resource limitations mean some FFLs go longer between inspections.

While the IOI may call ahead to schedule a convenient time (which benefits both parties), they are not required to provide advance notice. They can arrive unannounced during business hours, and you must allow them access. Refusing an inspection is itself a willful violation that triggers license revocation proceedings.

The Opening

The IOI will introduce themselves, present ATF credentials, and explain the purpose of the inspection. They will provide their contact information and ask to speak with a responsible person on the FFL. This is a professional, regulatory process — not an adversarial encounter. Be cooperative, professional, and prepared.

What the IOI Reviews

The inspection covers four primary areas, though the IOI may address additional compliance topics as needed:

1. Acquisition & Disposition (A&D) Records. The IOI will examine your bound book — every firearm acquisition and every disposition. They will select a sample of entries and physically locate the corresponding firearms in your inventory (or verify the disposition record for items that have left). They're looking for accuracy, completeness, and timeliness of entries. Missing entries, incorrect serial numbers, and gaps between acquisition dates and entry dates are all findings.

2. ATF Form 4473 Records. The IOI will review a sample of your completed Form 4473s. They're checking for completeness (every required field filled), accuracy (information matches the buyer's identification), proper corrections (single-line strikethrough with initials and date — never white-out), signatures and dates, and proper NICS documentation. This is where the majority of violations are found.

3. Physical Firearm Inventory. The IOI will physically count a sample of serialized firearms in your inventory and match serial numbers to your A&D records. Every firearm on your shelves, in your vault, in your display cases, and in storage must have a corresponding acquisition entry. Every firearm in your A&D book that hasn't been disposed of must be physically present. Discrepancies — firearms present without records, or records present without firearms — are serious findings.

4. NICS/Background Check Procedures. The IOI will verify that background checks were conducted for all required transactions, that the results were properly documented, and that transfers were not completed before receiving a "Proceed" response (or the expiration of the delay period, if applicable). Brady transfers — transactions completed after the delay period expired without a final determination — receive particular scrutiny.

The Closing Conference

At the end of the inspection, the IOI will sit down with you for a closing conference. If violations were found, the IOI will present them in writing. You will have the opportunity to respond — explain the circumstances, describe corrective actions you've already taken or plan to take, and ask questions. Your responses are documented.

This is a critical moment. Your response to documented violations becomes part of your inspection record. Demonstrating that you take the findings seriously, have identified the root cause, and have implemented corrective actions can be the difference between a report of violations and more serious enforcement action.

Important: You are not required to sign the inspection results immediately. You can request time to review them. You are also permitted to have a consultant, attorney, or compliance advisor present during the closing conference — and doing so is strongly recommended, particularly if significant violations are being discussed.

3. ATF Form 4473: The #1 Source of FFL Violations

Form 4473 errors have been the leading violation category for over a decade. In FY 2024, they contributed the largest share of the approximately 100,000 violations found across all inspections. If you solve your 4473 problem, you solve the majority of your compliance risk.

The Top 4473 Error Categories

Error #1: Transferee fails to complete Section A properly. This has been the single most common ATF violation for years running. Section A is the buyer's portion of the form. Common problems include: skipping or incompletely answering Questions 10a and 10b (ethnicity and race — both must be answered), misunderstanding Question 21.a ("Are you the actual transferee/buyer?" — buyers purchasing gifts must answer "Yes," not "No"), and leaving fields blank or illegible. The FFL is responsible for reviewing Section A before proceeding. If the buyer's section is incomplete, the transaction should not move forward.

Error #2: Incorrect firearm identification in Section D. The FFL's portion of the form requires accurate recording of the firearm's manufacturer (and importer, if applicable), model, serial number, type, and caliber/gauge. Common mistakes include: misidentifying the type (listing "rifle" when transferring a "receiver"), transposing serial number digits, entering the wrong caliber, and failing to record both the foreign manufacturer and U.S. importer for imported firearms. A misidentified firearm can obstruct criminal investigations and put the FFL under scrutiny for negligence.

Error #3: Missing or incomplete signatures and dates. The buyer's signature (Box 19), the buyer's date (Box 18), the FFL's certification signature and date — all must be present. Unsigned or undated forms are among the easiest violations to prevent and among the most consistently found during inspections.

Error #4: Address discrepancies. The buyer's current physical residential address (Box 10) must match the address on their government-issued photo ID. If the addresses don't match — because the buyer recently moved, for example — supplemental documentation (vehicle registration, utility bill, etc.) is required. Even small discrepancies like "Apt. 2B" versus "2B" can trigger findings during an inspection.

Error #5: Improper corrections. When a mistake is made on a paper 4473, the correct procedure is: draw a single line through the error, write the correct information nearby, and have the person who made the error initial and date the correction. Never use white-out, correction tape, erasers, or overwriting. Improper corrections raise questions about the integrity of the record and are frequently cited during inspections.

How to Prevent 4473 Errors

Second-set-of-eyes review. Before completing any transfer, have a second qualified employee review the 4473 for completeness and accuracy. This single practice catches the majority of errors before they become violations. The reviewer should initial Section 30c to document that verification occurred.

Pre-check explanation for buyers. Before handing the customer the form, briefly explain the most commonly confused questions: 10a/10b require both to be answered, 21.a should be "Yes" if they're buying for themselves or as a legitimate gift, and their address must match their ID. A laminated instruction card at the counter takes 30 seconds and prevents hours of compliance headaches.

Go digital. Digital 4473 systems validate every required field in real time, prevent submission of incomplete forms, flag address mismatches, enforce proper correction procedures, and eliminate illegibility. The error rates on digital 4473 systems are a fraction of paper — because the software won't let a transaction proceed until the form is complete and internally consistent. This is not a nice-to-have. It is the single most impactful compliance investment an FFL can make. Bravo's E4473 validates every field in real time and has been through hundreds of ATF audits across our customer base with zero software-related infractions.

4473 Storage Requirements

Completed Form 4473s must be retained for a minimum of 20 years, or for the duration of the FFL's licensure — whichever comes first. Forms for denied transactions must be retained for at least 5 years. Forms must be organized and readily accessible for ATF inspection at all times.

Digital storage is permitted under ATF Ruling 2016-2. Digital systems must maintain the form's accuracy and integrity, provide search and retrieval capabilities, produce legible reproductions, and store records securely with appropriate access controls. If using digital storage, your ATF variance letter (or notification confirmation) should be readily available for the IOI during inspection.

4. Acquisition & Disposition (A&D) Bound Book Requirements

Your A&D record is the second major focus of every ATF inspection. It is the complete chronological record of every firearm that enters and leaves your business. The "bound book" can be a physical bound book, a computerized record, or a combination — but it must meet specific regulatory requirements regardless of format.

Acquisition Entries

Every firearm you acquire — through purchase, consignment, pawn forfeiture, trade, or any other means — must be recorded in your A&D book by the close of the next business day following acquisition. For firearms received from a common carrier (shipped to you), the acquisition date is the date you actually receive them.

Each acquisition entry must include: the date of acquisition, the manufacturer (and importer, for imported firearms), the model, the serial number, the type (pistol, revolver, rifle, shotgun, receiver, etc.), the caliber or gauge, and the name and address (or FFL number) of the person or entity from whom the firearm was acquired.

Common bound book acquisition errors include: delayed entries (logging firearms days after receipt), incorrect or transposed serial numbers, failing to record both manufacturer and importer for imported firearms, and failing to record acquisitions from walk-in sellers with proper identification information.

Disposition Entries

Every firearm you transfer — through sale, return, theft/loss, or destruction — must be recorded in your A&D book. Disposition entries must include: the date of disposition, the name and address of the person or entity receiving the firearm (or their FFL number for licensee-to-licensee transfers), and the Form 4473 transaction number for transfers to non-licensees.

Common bound book disposition errors include: failing to record the disposition at all (the firearm leaves your inventory but the A&D book still shows it as on-hand), recording the disposition date incorrectly, and failing to reference the 4473 serial number that corresponds to the transfer.

Inventory Reconciliation

Your A&D book should reflect your actual physical inventory at all times. The number of firearms "on hand" according to your records (acquisitions minus dispositions) must match the number of serialized firearms physically present in your shop.

When the ATF conducts an inventory check during inspection, they will select a sample of serial numbers from your bound book and physically locate those firearms — and they will select a sample of firearms from your shelves and look up their bound book entries. A discrepancy in either direction is a finding. A firearm present without an acquisition record, or a bound book entry without a corresponding physical firearm (and no disposition record), are both serious.

The remedy is regular self-audits. At minimum, conduct a complete physical inventory against your A&D records quarterly. Ideally, do it monthly. Resolve any discrepancies immediately. If a firearm is missing, file ATF Form 3310.11 (FFL Theft/Loss Report) within 48 hours of discovery and report to local law enforcement. Bravo's electronic bound book automatically logs acquisitions and dispositions as part of every transaction — no separate data entry step, no lag between the sale and the record, no transposed serial numbers from re-keying.

5. NICS Background Check Procedures

Before transferring any firearm to a non-licensee, you must initiate a background check through the National Instant Criminal Background Check System (NICS) — either directly through the FBI or through your state's designated point of contact (POC), depending on your state.

The Three Possible NICS Responses

Proceed. The background check is clear. You may complete the transfer.

Delayed. NICS needs additional time to research the buyer's eligibility. You must wait. The federal default delay period is 3 business days — if NICS has not issued a final determination within that period, you may proceed with the transfer at your discretion. Some states have extended delay periods that supersede the federal default. Know your state's rules.

Denied. The buyer is prohibited from purchasing a firearm. You must not complete the transfer. Document the denial on the 4473 and retain the form per retention requirements (minimum 5 years for denied transactions).

Brady Transfers

A "Brady transfer" occurs when you proceed with a transfer after the federal delay period expires without a final NICS determination. Brady transfers are legal under federal law, but they carry risk — if NICS subsequently returns a "Denied" result, the ATF may issue a firearm retrieval request. Brady transfers are flagged and reviewed closely during ATF inspections. Track them carefully and maintain documentation of the original NICS submission date, the date you proceeded, and the basis for your decision.

NICS Documentation on the 4473

Your 4473 must document: the date and time of the NICS check, the NICS Transaction Number (NTN) or state transaction number, and the response received (Proceed, Delayed, or Denied). For delayed transactions, also record the final disposition date and result.

The most common NICS-related violation is failing to initiate a background check at all before completing a transfer. This is an automatic revocation-level offense under the ATF's enforcement framework. There is no circumstance under which you may transfer a firearm to a non-licensee without initiating a NICS check.

6. Multiple Sale Reporting (Form 3310.4)

If a single buyer purchases (or otherwise acquires) two or more handguns within five consecutive business days, you must complete ATF Form 3310.4 (Report of Multiple Sale or Other Disposition of Pistols and Revolvers). A copy must be sent to your local ATF field office and to the chief law enforcement officer in your jurisdiction by the close of business on the day the multiple sale occurs.

Under the Bipartisan Safer Communities Act (2022), this reporting requirement was expanded to include rifles and shotguns for buyers under 21 years of age.

Failure to file required multiple sale reports is a commonly cited violation during inspections. Your POS system should track transaction history per customer and automatically flag when a multiple sale threshold is triggered. If you're tracking this manually, you're relying on your staff's memory and attention — and during a busy Saturday, that's a vulnerability.

7. Record Retention Requirements

Understanding retention requirements is straightforward but non-negotiable:

Form 4473 (completed transactions): 20 years minimum

Form 4473 (denied transactions): 5 years minimum

A&D bound book: Retained for the duration of your FFL. If you go out of business, your bound book and all 4473 records must be sent to the ATF National Tracing Center within 30 days of closing.

Form 3310.4 (multiple sale reports): Retained as part of your 4473 records (attached to the relevant 4473)

Form 3310.11 (theft/loss reports): Retain copies indefinitely

Records must be organized, accessible, and retrievable during an ATF inspection. "Organized" doesn't mean stuffed in boxes in the back room — it means an IOI can request a specific 4473 from three years ago and you can produce it in a reasonable timeframe. If you have 10,000 paper 4473s spanning a decade and no filing system, you have a compliance problem even if every individual form is perfect.

8. What Triggers License Revocation

The ATF's published enforcement framework identifies specific violations that, when committed willfully, will result in a Notice of Revocation absent extraordinary circumstances:

1. Transferring a firearm to a prohibited person.

2. Failing to conduct a required NICS background check before transfer.

3. Falsifying records (4473s, bound book, or other required records).

4. Failing to respond to an ATF trace request.

5. Refusing to permit ATF to conduct an inspection.

Beyond these bright-line revocation triggers, the ATF can also pursue revocation for repeat violations that demonstrate a "willful disregard of the law." This is where the enforcement landscape has shifted most dramatically. The ATF's interpretation of "willful" has broadened: if you received a warning about specific violations, attempted to correct them, but a subsequent inspection finds the same or similar issues, the ATF may characterize this as willful — regardless of your intent.

This means: a warning letter is not just informational. It is the starting point of a documented record. Any violation cited in a warning letter that reappears in a subsequent inspection carries significantly elevated revocation risk. Every warning letter should trigger an immediate, thorough, and documented corrective action plan — and that plan should include systemic changes (not just promises to "try harder") to prevent recurrence.

9. Inspection Outcomes: From No Violations to Revocation

ATF inspection outcomes follow a graduated enforcement model, from least severe to most severe:

No violations. The best outcome. You passed. 54% of inspected FFLs in FY 2024 achieved this result. This is your goal every time.

Report of violations (ROV). The IOI identified violations that are documented in a formal report. You are expected to take corrective action. The ROV becomes part of your inspection history and will be reviewed during your next inspection. 1,689 FFLs received an ROV in FY 2024.

Warning letter. A formal written warning from ATF. More serious than an ROV. The warning letter identifies specific violations and puts you on notice that failure to correct them may result in revocation proceedings. 721 FFLs received warning letters in FY 2024.

Warning conference. A face-to-face meeting between you (and ideally your attorney or compliance advisor) and ATF officials to discuss violations and required corrective actions. This is the last step before revocation proceedings. 214 FFLs received warning conferences in FY 2024.

License revocation. The ATF initiates formal proceedings to revoke your FFL. You will receive a Notice of Revocation (ATF Form 4500) detailing the violations. You have the right to a hearing before an administrative law judge. 195 FFLs were revoked in FY 2024.

License surrender. The FFL voluntarily surrenders their license — often in lieu of revocation proceedings or as part of a settlement. 1,488 FFLs surrendered or went out of business in FY 2024. Not all of these were enforcement-related (some are simply business closures), but a significant portion result from compliance pressure.

10. The FFL Compliance Checklist

Compliance is not a one-time event — it's a set of daily, weekly, monthly, and annual habits. Build these into your operations.

Daily

A&D entries are current. Every firearm acquired today is logged in the bound book by close of the next business day. Every firearm sold or transferred today has a disposition entry.

All 4473s from today's transactions are complete, reviewed, and filed. Second-set-of-eyes review was conducted before every transfer.

NICS checks were conducted and documented for every transfer. No firearms left the building without a background check on record.

Multiple sale thresholds were checked. If any customer purchased two or more handguns (or applicable long guns for under-21 buyers) within five business days, Form 3310.4 was completed and submitted.

Weekly

Spot-check 5–10 recent A&D entries against physical inventory. Pick random serial numbers from your bound book and physically confirm the firearm is on your shelf (or has a valid disposition record). This takes 15 minutes and catches errors early.

Review pending NICS delays. Check the status of any open delayed transactions. If a delay has exceeded the federal period, decide whether to proceed with the transfer (Brady transfer) or continue waiting. Document your decision.

Check for any outstanding ATF trace requests. Respond to all trace requests promptly. Failure to respond is a revocation-level violation.

Monthly

Conduct a partial inventory audit. Count a representative sample of your serialized inventory — at least 20% — and reconcile against your A&D book. Rotate which section of your inventory you audit each month so you cover everything quarterly.

Review 4473 filing and storage. Confirm that all completed 4473s are properly filed and accessible. If using paper, ensure your filing system is organized chronologically or by transaction number. If using digital storage, verify that records are backing up correctly and are retrievable.

Staff compliance check-in. Brief your team on any errors caught during the month, reinforce proper procedures for the most common mistake areas, and address questions. Keep a record of these check-ins.

Quarterly

Full physical inventory reconciliation. Count every serialized firearm in your inventory and match against your A&D records. Resolve all discrepancies. File theft/loss reports for any firearms that cannot be accounted for. This is your most important compliance activity outside of daily recordkeeping.

Review and update your Standard Operating Procedures (SOP). Are your documented procedures still accurate? Have any regulations changed? Are new employees trained on the current SOP?

Annually

Conduct a mock ATF inspection. Walk through the entire inspection process as if an IOI were present. Review a sample of 4473s, audit your bound book, reconcile inventory, verify NICS documentation, and check multiple sale report compliance. Identify and fix any gaps. Consider engaging a third-party compliance consultant to conduct the mock inspection for an objective assessment.

Review your previous ATF inspection results. If you received an ROV or warning letter at your last inspection, verify that every cited violation has been corrected and that systemic changes are in place to prevent recurrence. Document your corrective actions.

Review ATF regulatory updates. Check for new ATF rulings, form revisions, or regulatory changes that affect your operations. The ATF's "New Era of Reform" initiative (announced May 2025) includes potential changes to Form 4473 and enhanced e-forms capabilities. Stay current.

Bravo customers run these checklists inside the platform — spot-checks, inventory reconciliation, and audit prep tools are built into the daily workflow, not bolted on as an afterthought.

11. Digital vs. Paper Records: The Compliance Case for Going Digital

Paper-based recordkeeping was the only option for decades. It is no longer the best option — and for many FFLs, it is an active source of compliance risk.

The Problem with Paper

Paper 4473s are filled out by hand. Handwriting is illegible. Fields get skipped. Corrections are made improperly. Forms are misfiled, lost, or damaged. An IOI requests a specific 4473 from 2019 and your staff spends 30 minutes searching through filing cabinets. During a busy week, a 4473 gets separated from its stack and ends up in the wrong folder — or disappears entirely.

Paper bound books are maintained by hand. Serial numbers are transposed. Entries are made on the wrong line. Cross-outs and corrections accumulate. An IOI conducting an inventory audit has to manually read your handwriting to match serial numbers — and when they can't, it becomes a finding.

Paper doesn't prevent errors. Paper doesn't flag missing fields. Paper doesn't validate serial numbers. Paper doesn't alert you when a multiple sale threshold is triggered. Paper doesn't search. Paper doesn't back up. Paper can burn, flood, and disappear.

What Digital Systems Solve

Digital 4473 systems validate every required field in real time. They prevent submission until the form is complete. They flag address mismatches between the buyer's entry and their ID. They enforce proper correction procedures. They eliminate illegibility entirely. They store completed forms in the cloud — searchable, retrievable in seconds, backed up continuously, and accessible during an inspection without delay. Systems operating under ATF Ruling 2016-2 provide 20-year secure retention that meets all regulatory requirements.

Digital A&D systems (electronic bound books) automatically create acquisition entries when firearms are received and disposition entries when firearms are transferred. They link dispositions to their associated 4473 transaction numbers. They flag serial number discrepancies in real time. They make inventory reconciliation a search query instead of a manual cross-reference. They generate trace responses in seconds instead of hours.

Integrated POS systems that combine the point of sale, digital 4473, bound book, and NICS submission into a single workflow eliminate the gaps between systems where errors occur. When a customer buys a firearm, the data flows from the transaction to the 4473 to the NICS check to the bound book disposition — without re-keying information at any step. This is where the majority of compliance errors die before they're born.

The Numbers

Digital 4473 providers consistently report that their systems eliminate 90–97% of the human errors found on paper forms. For an FFL processing 500 transactions per year, eliminating 95% of form errors means potentially avoiding dozens of violations that an ATF inspection would otherwise find. At the scale of 1,000+ annual transactions, the risk reduction is proportionally greater.

The cost of a digital 4473 and electronic bound book system is a fraction of the cost of a single compliance violation — and a rounding error compared to the cost of license revocation. The ROI calculation is not close.

12. Frequently Asked Questions

How often does the ATF inspect FFLs?

The ATF is authorized to conduct one unannounced compliance inspection per FFL per 12-month period. In FY 2024, 9,696 of 128,690 active FFLs were inspected (approximately 7.5%). The ATF's stated goal is to inspect every FFL at least once every three years, though resource constraints mean some go longer. Higher-risk FFLs — those with prior violations, high trace volumes, or located in high-risk areas — are inspected more frequently.

What are the most common ATF violations?

The #1 violation, consistent for over a decade, is failure of the buyer to properly complete Section A of Form 4473. Other top violations include inaccurate A&D bound book entries, incorrect firearm descriptions on the 4473, missing signatures and dates, and failure to file multiple sale reports. In FY 2024, these categories contributed to approximately 100,000 total violations across 9,696 inspections.

Can I have an attorney present during an ATF inspection?

Yes. There are no formal restrictions on who can be present during an ATF inspection or closing conference. You are strongly encouraged to have a compliance consultant, attorney, or other advisor present — particularly during the closing conference where violation findings are discussed. Their presence as a witness and advisor can be valuable if findings are disputed or if enforcement proceedings follow.

What happens if I disagree with the IOI's findings?

During the closing conference, you have the opportunity to respond to each finding and document your perspective. You are not required to sign the inspection results immediately — you can request time to review. If violations lead to a Notice of Revocation, you have the right to request a hearing before an administrative law judge within the timeframe specified in the notice. Legal representation is strongly recommended at this stage.

Can the ATF revoke my license for a single violation?

Yes. Federal courts have upheld that a single willful violation of the Gun Control Act's regulations is a sufficient basis for license revocation. However, for most recordkeeping violations, the ATF follows a graduated enforcement approach (ROV → warning letter → warning conference → revocation) unless the violation involves one of the bright-line revocation triggers (transferring to a prohibited person, failing to run a background check, falsifying records, failing to respond to a trace, or refusing an inspection).

How long must I keep Form 4473 records?

Completed 4473s for approved transactions must be retained for 20 years or the duration of your FFL licensure, whichever comes first. Denied transaction 4473s must be retained for at least 5 years. If you go out of business, all records must be sent to the ATF National Tracing Center within 30 days.

What is ATF Ruling 2016-2?

ATF Ruling 2016-2 authorizes FFLs to store completed Form 4473 records digitally, provided the digital system meets requirements for accuracy, integrity, searchability, security, and the ability to produce legible reproductions. To use digital storage, FFLs must notify the ATF in writing at least 30 days before beginning digital storage. This ruling is the regulatory basis for all digital 4473 storage solutions currently on the market.

What changed under the "zero tolerance" policy?

Announced in June 2021, the ATF's zero tolerance policy directed that certain willful violations — particularly the five bright-line revocation triggers — would result in revocation proceedings without the intermediate steps of warning letters or conferences. The policy also resulted in a broader interpretation of "willful," with repeat violations after a warning being treated as evidence of willfulness. FFL revocations increased from 88 in FY 2022 to 195 in FY 2024. In April 2025, the ATF announced it was ending the zero tolerance policy, though the underlying regulations and revocation authority remain unchanged.

How can I protect my FFL?

The playbook is straightforward: maintain accurate, complete, and timely records every day. Use digital systems that prevent errors before they happen. Conduct regular self-audits — weekly spot-checks, monthly partial audits, and quarterly full inventory reconciliations. Train every employee who touches a 4473 or the bound book. Document all training. Review and address any prior inspection findings immediately and systemically. Respond to every ATF trace request promptly. And if you receive a warning of any kind, treat it as an emergency — implement documented corrective actions and verify they're working.

Your Compliance Technology Matters

Every data point in this guide reinforces the same conclusion: the majority of FFL violations are preventable, and the single most effective way to prevent them is to replace error-prone manual processes with integrated digital systems that enforce compliance as part of the workflow.

Bravo Store Systems builds the compliance technology that powers thousands of FFL operations. Our integrated platform combines point-of-sale, digital Form 4473 with real-time field validation, electronic A&D bound book with automatic acquisition and disposition logging, direct NICS integration, cloud-based 4473 storage meeting ATF Ruling 2016-2 requirements, automated multiple sale detection, and instant record retrieval during ATF inspections.

Our compliance record speaks for itself: hundreds of ATF audits across our customer base. Zero infractions attributed to the software. Zero.

If you're still running paper 4473s and handwritten bound books, every day is a roll of the dice. Talk to our team and see what audit-ready compliance actually looks like.

Bravo Store Systems — Built by five generations of pawnbrokers. Trusted by thousands of FFLs. Audited hundreds of times. Zero infractions.

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