A proposed federal rule would drop the second fingerprint card, scrap the passport-style photo, and remove fingerprinting entirely for trust applicants. Here is what it does, what it does not do, and where to file a comment before the window closes.
This is a proposed rule published July 6, 2026 — not current law. It carries a 90-day public comment period. Nothing changes on your Form 1 or Form 4 until a final rule is issued.
On July 6, 2026, the ATF published a proposed rule titled "Fingerprint and Photograph Requirements for Firearms Applications." It targets the paperwork side of buying or making an NFA item — suppressors, short-barreled rifles, short-barreled shotguns, and machine guns. It does not touch the tax, the registry, or the wait itself. Here is the breakdown.
Right now, an individual filing a Form 1 or Form 4 has to submit two fingerprint cards. The proposal cuts that to one. Most people already file electronic prints through the eForms system, so for them this is a small win. The bigger change is for trusts.
If you buy through an NFA trust, the "responsible persons" on that trust currently each have to submit prints. Under the proposal, that requirement goes away entirely for trust responsible persons. The ATF's own reasoning: the National Firearms Act text requires prints from individual applicants, not from trusts or legal entities — so the 2016-era requirement on trusts was never mandated by statute in the first place.
The 2" x 2" passport-style photo is out. In its place, applicants would submit a clear copy or scan of a government-issued photo ID — a driver's license works. No more trip to the drugstore photo counter. This applies to both individual and trust applicants.
| Requirement | Current Rule | Under the Proposal |
|---|---|---|
| Fingerprint cards (individual) | Two cards | One card |
| Fingerprints (trust responsible persons) | Required from each | Not required |
| Identity photo | 2" x 2" passport photo | Copy of government photo ID |
| Applies to forms | Form 1, Form 4, Form 5 | Form 1, Form 4, Form 5 |
The ATF can still request prints or a photo in limited cases — for example, if the FBI flags a background-check issue that needs to be resolved. The default burden is what changes, not the agency's ability to ask.
This is a paperwork rule, not deregulation. NFA items are still registered, still tracked, and still go through the same approval channel. If you were hoping suppressors would come off the NFA list, that is a separate legislative fight, not this rule.
The ATF says fingerprint cards have been useful to the FBI in fewer than 1% of these applications, so removing them is not expected to speed up approvals in a big way. The rule trims steps on your end; it does not promise a faster stamp.
A standard LPWS2011 pistol is a Title I firearm — no NFA form, no fingerprints, no stamp. It ships to your FFL on a normal 4473. This rule only matters if you also own or plan to buy NFA items like a suppressor or SBR. We are covering it because a lot of serious 2011 shooters run cans, and this is worth knowing.
Because this is a proposed rule, the public can weigh in during the 90-day window. Comments become part of the official record the ATF has to consider before finalizing.
File through the federal portal at regulations.gov and reference the rule by its docket — ATF-2026-0397 (RIN 1140-AA63). The full text is on the Federal Register, and the ATF's own summary of its reform package is on the ATF Reduce Burden page.
// Build While the Paperwork Gets Lighter
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