This is an important reminder that the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) will implement new NFA forms and NFA eForms beginning January 1, 2026.

As previously outlined in our article, ‘2026 NFA Tax Stamp Changes: What FFLs Need to Know’, the $200 federal tax stamp for certain NFA items, most notably silencers, is being reduced to $0. While the tax is going away, the NFA process itself and the tax stamp requirement remain fully in place.

End of the Temporary ATF eForms Blackout

To prepare for these changes and the expected surge in NFA submissions, the ATF had announced a temporary shutdown of the eForms system as of Midnight, December 26, 2025. Those systems are said to resume operation as of Midnight, January 1, 2026.

What’s Changing on January 1, 2026

These updates stem from the One Big Beautiful Bill, signed into law on July 4, 2025, which reduced the making and transfer tax for certain NFA firearms, specifically silencers, short-barreled rifles (SBRs), short-barreled shotguns (SBSs), and Any Other Weapons to $0.

As a result, the ATF is revising several NFA forms, including:

• ATF Form 1 (5320.1) – Application to Make and Register an NFA Firearm
• ATF Form 4 (5320.4) – Application for Tax Paid Transfer and Registration of Firearm
• ATF Form 5 (5320.5) — Application for Tax Exempt Transfer and Registration of Firearm
• ATF Form 5320.20 — Application to Transport Interstate or to Temporarily Export Certain NFA Firearms

What is Changing on ATF NFA Form 1?

• Clearer form title and instructions
• Removal of the embedded photo box (photos may be attached separately or via ID)
• Combined race/ethnicity fields
• Expanded acceptance of electronic/digital signatures
• Linked fillable PDF copies for consistency
• Updated references to eForms, Pay.gov, and refunds
• Removal of the CLEO notification copy requirement
• New guidance for married couples filing jointly as an “other legal entity”

What is Changing on ATF NFA Form 4?

• All draft Form 4 applications will be deleted due to structural and formatting changes
• Expanded eForms access, allowing both qualified licensees and other transferors to submit Form 4 applications electronically

What is Changing on ATF NFA Form 5?

• The ATF is updating Form 5 to support electronic fillable formats and eventual eForms integration, helping modernize how this form is completed and submitted.
• The revisions do not change the core purpose or eligibility criteria for tax-exempt transfers. It remains the form used to register and transfer NFA firearms when a statutory tax exemption applies (e.g., estate transfers, government entity transfers).

What is Changing on ATF NFA Form 5320.20?

• This form has been added to the ATF eForms submission platform, allowing electronic preparation and submission where previously it was paper only.

What Is Not Changing

Despite the $0 tax stamp:

• Photographs and fingerprints are still required for applicable Forms
• The NFA approval process remains unchanged

Important Notes on Existing eForms

• Draft eForms: Any Form 1 or Form 4 left in Draft status as of December 26, 2025 will be permanently deleted
• Submitted eForms: Forms certified and submitted prior to December 26 will continue through ATF review
• Delayed background checks: ATF has advised that delayed submissions will be held until December 30 to allow for FBI clearance; unresolved submissions will be denied and returned without action (RWA)

What This Means for FFLs

This transition represents a significant operational and business moment for FFLs handling NFA items. FFLs should prepare for:

• Increased consumer demand
• Higher submission volumes
• The need for updated workflows, training, and compliant software solutions

Orchid will continue monitoring these changes closely and will provide ongoing guidance to help our customers stay compliant and prepared.