SSF Supports ATF Proposal to Reduce Fingerprint Requirements for NFA Trust Applicants

The Silencer Shop Foundation supports ATF’s proposed rule to reduce unnecessary fingerprint and photograph requirements for certain firearms applications, including NFA applications filed by trusts and other legal entities. 

The Silencer Shop Foundation has pushed for a simpler, more modern, less burdensome NFA process. Law-abiding Americans should not have to navigate needless red tape just to exercise their rights and protect their hearing. This proposed rule is not the finish line, but it is a meaningful step in the right direction. 

What ATF Is Proposing 

ATF’s proposed rule would update fingerprint and photograph requirements for several firearms applications. For NFA applicants, the most important change is that responsible persons listed on a trust or other legal entity would no longer be required to submit fingerprints with their Form 23s, upfront. Instead, ATF would request fingerprints only if needed to complete a background check. Individual NFA applicants would still submit fingerprints with their application, but the proposal would reduce the requirement from two fingerprint cards to one. ATF also proposes allowing applicants to submit a copy of a photo ID instead of a 2” x 2” passport-style photo in many cases.  

That matters because fingerprints have rarely been needed for the background check process. ATF states that fingerprint cards have only been helpful and used for NICS purposes in fewer than 1% of these applications, and the agency says requiring fingerprints and passport-style photos with every NFA application is “needlessly burdensome” on applicants.  

That is exactly the kind of unnecessary burden SSF has been fighting to remove. 

A Simpler Process Is a Better Process 

The NFA process has never been simple. Even for law-abiding customers, the process can feel confusing, slow, intimidating, and outdated. 

Every extra step creates friction. Every added requirement creates another place where a customer can get delayed, discouraged, or forced to spend more time and money. Fingerprinting has long been one of those steps. 

This proposed rule recognizes what silencer owners, applicants, and industry advocates have known for years: the process can be simpler without abandoning background checks. ATF would still conduct background checks. ATF could still request fingerprints when they are actually needed to resolve a specific issue. But the government would no longer require every responsible person on a trust to submit fingerprints upfront when, by ATF’s own data, fingerprints are rarely needed for standard background check processing.  

That is common sense.

The Rule Is Not Final Yet 

This is still a proposed rule. The current process has not changed yet. 

ATF’s notice is scheduled to be published in the Federal Register on July 6, 2026, and the agency is accepting public comments for 90 days after publication. Until a final rule is issued and implemented, applicants should continue following the current process.  

The proposed rule cannot be finalized until after the comment period expires (in about 90 days) and until ATF prepares the final version.  Issuance of the final rule can take up to a year, or longer (for example, Rule 41F, which created the fingerprint requirement for trusts, took just over 28 months to finalize).  If you’re reading this, then please consider filing a comment at federalregister.gov to show your support for this proposed rule and increase the likelihood that it will become final.  The comment period is expected to open July 6, 2026. 

SSF will continue reviewing the proposal and supporting reforms that make the NFA process more efficient, more accessible, and less burdensome for law-abiding Americans. 

This Is the Kind of Reform SSF Has Been Fighting For 

The Silencer Shop Foundation was created to protect and expand the rights of law-abiding Americans who own, use, and want access to silencers and other NFA items. 

That mission includes litigation, education, public advocacy, and direct engagement with policymakers and regulators. For years, Silencer Shop leadership has advocated for changes that would modernize the NFA process, reduce unnecessary burdens, and make lawful ownership easier for ordinary Americans. 

This proposed rule reflects the type of reform we have long supported. 

We are not claiming the work is done. It is not. The NFA still imposes significant burdens on law-abiding Americans. Silencers remain heavily regulated despite being safety devices that reduce noise, protect hearing, and make shooting safer and more enjoyable. Applicants still face forms, approvals, background checks, regulatory uncertainty, and a federal process that remains more complicated than it should be. 

But when ATF acknowledges that a long-standing requirement no longer serves a useful purpose, that is worth recognizing. When the agency proposes removing an unnecessary hurdle for trust applicants, that is worth supporting. 

Progress matters. 

Good for Gun Owners, Good for the Industry, Good for the Second Amendment 

The biggest beneficiaries of this proposed rule are the folks who have always wanted a silencer but never pulled the trigger because Uncle Sam was overstepping too much. 

A simpler process means fewer headaches. It means less confusion. It means fewer unnecessary steps between a law-abiding gun owner and the suppressor they are legally allowed to own. 

That matters for first-time buyers who are already intimidated by the NFA process. It matters for families using trusts to share lawful access to NFA items. It matters for customers who want to protect their hearing at the range, in the field, or while training. 

It also matters for the broader Second Amendment industry, which creates an incentive for more businesses to enter the market and provide more options, more innovation, and better technology. When lawful ownership becomes easier, more people participate. More people buy products. More people train. More people become educated, responsible, long-term members of the firearms community. 

Unnecessary red tape does not make people safer. It makes lawful ownership harder. 

The Bottom Line 

ATF’s proposed rule is a positive step. 

It does not eliminate the NFA. It does not fix every problem with the current system. It does not remove every unnecessary burden placed on law-abiding gun owners. 

But it does acknowledge something important: some requirements create cost, delay, and frustration without providing meaningful benefit.

That is exactly why the Silencer Shop Foundation exists. We will continue fighting for a simpler, fairer, and more constitutionally sound process for silencers and other NFA items.

Law-abiding Americans deserve less red tape, not more. 

Silencer Shop Foundation continues to fight against bad gun laws, and our fight against the NFA is still in full effect. If you want to support those fighting on the front lines to make suppressor ownership easier, please consider donating.