DOJ Proposes Changes to ATF Forms for Sale of Silencers and Short-Barreled Firearms

On October 30, 2025, the DOJ published notices in the Federal Register, proposing to make changes to the ATF Form 1 and ATF Form 4 (OMB 1140-0011; OMB 1140-0014). This publication follows ATF’s earlier notice from Aug. 8, 2025 and opens another 30-day period for public comment on the proposed form revisions.

The changes reflect two general goals: (1) updating the forms due to the Big Beautiful Bill’s elimination of the $200 transfer and making taxes for silencers, SBRs, SBSs, and AOWs(effective Jan. 1); and (2) preparing the forms to implement this administration’s goal to reduce burdens on NFA applicants.

What’s Changing

The big news is that it appears ATF wants to eliminate the CLEO notification requirement for making or buying a silencer. Also, it looks like ATF is working on an alternative way for married couples to share silencers and other NFA firearms. There are few details regarding this latter point but we suspect the proposed change to the forms anticipates a new rulemaking from ATF, which will likely provide more information. Currently, registering through a trust offers a good solution to lawfully share silencers and other NFA items among family members and trusted friends.

The notices reflect a number of proposed changes to the Form 1 and Form 4, including:

• revising the title to be more clear

• removing the photo box on the form to allow the option to attach either a passport-style photo or a copy of a photo identification document

• combining race/ethnicity items

• allowing additional types of electronic/digital signatures

• revising the fillable pdf form to link copy 1 and copy 2 so that copy 2 gets populated as the copy 1 is filled in, except for check boxes and signature

• adding references to eForms and pay.gov

• adding reference to the refund process

• removing the CLEO notification requirement and copy

• adding instructions for married couples jointly making, transferring, and registering a firearm, as an `other legal entity’

• correcting typographical/grammar items

• adding email addresses for different questions: nfa@atf.gov, ipb@atf.gov, & nfafax@atf.gov.

Two additional changes are proposed for the Form 4:

• removing the $5 box in Item 1, Type of Transfer, and replacing it with a $0 box

• revising Instructions 2.b. in the ‘‘Preparation of Application section to read: ‘‘Transfer Tax Rates. The transfer tax is $200.00 for machine guns and destructive devices. The transfer tax is $0.00 for other types of firearms.’’

Why It Matters

DOJ and ATF are getting ready for the elimination of the $200 tax on silencers and short-barreled firearms, and so should you. Starting January 1, silencers and SBRs will be $200 cheaper for your customers and demand is expected to be high. These changes from ATF indicate the tax-elimination is not the only way buying and owning a silencer is about to get easier. If you don’t already have an SOT to sell NFA firearms, now might be a good time to take the plunge.