NFA Transfers at Kitchen Table Guns
On October 9, 2026, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) announced a major change in how it will enforce certain requirements under the National Firearms Act (NFA).
Effective immediately, Kitchen Table Guns will offer customers two options for suppressor transfers:
Form 4473: Transfer a suppressor after completing the required paperwork and background check, without waiting for ATF Form 4 approval.
Form 4: Continue using the traditional ATF approval and registration process.
For now, Kitchen Table Guns will continue requiring an approved Form 4 for all short-barreled rifle (SBR) and short-barreled shotgun (SBS) transfers.
While ATF's announcement creates new opportunities for customers, it also introduces legal risks that I believe everyone should understand before making a decision.
What Changed?
ATF announced that it will no longer enforce certain NFA registration and transfer-approval requirements for suppressors, SBRs, SBSs, and certain other firearms.
This policy applies nationwide, not just to individuals covered by the original court injunction.
However, the underlying federal laws have not been repealed. ATF is choosing not to enforce certain provisions under its current policy. That distinction is important because the policy could change.
All other applicable federal and state firearm laws remain in effect, including dealer paperwork, background checks, and restrictions on who may legally possess firearms.
Understanding the Risks of an Unregistered Suppressor
The biggest concern is what could happen in the future.
A future presidential administration, change in Department of Justice leadership, court decision, or action by Congress could restore enforcement of the NFA's registration requirements.
ATF explicitly warns that owners of unregistered suppressors are not guaranteed protection from future prosecution or an opportunity to register their suppressors later.
If enforcement resumes, someone who legally acquired an unregistered suppressor under today's policy could face serious legal consequences, potentially including felony prosecution and forfeiture. Federal law generally does not permit NFA firearms to be registered after the fact without special authorization or an amnesty.
There are also practical considerations:
Traveling or moving: ATF currently declines to enforce the NFA restriction on transporting unregistered suppressors across state lines. However, individual states may prohibit suppressors or require federal registration. Moving or traveling to another state could create legal problems.
Selling or transferring: Future changes in enforcement could make an unregistered suppressor difficult or impossible to transfer legally.
Inheritance: Passing an unregistered suppressor to a family member could become complicated if federal enforcement resumes.
These are legitimate risks, not predictions about what will happen.
Customers who choose the traditional Form 4 process will have an approved federal transfer and registration record, avoiding the particular risks of relying on today's nonenforcement policy. Registration does not guarantee protection against future changes in law, but it provides a more established legal footing.
I encourage customers to consider the long-term implications, not just the convenience of taking home a suppressor immediately.
Why We're Handling SBRs and SBSs Differently
Although ATF's guidance also covers short-barreled rifles and shotguns, these firearms present additional legal concerns in Virginia.
Under Virginia Code § 18.2-300, possession of a sawed-off rifle or shotgun is generally a felony unless a legal exception applies. § 18.2-303.1 provides an exception for firearms possessed in compliance with federal law.
The problem is that ATF's decision not to enforce a federal requirement does not necessarily mean an unregistered firearm satisfies Virginia's requirement for compliance with federal law. ATF acknowledges that it cannot resolve this question for individual states.
There is also a separate federal requirement under 18 U.S.C. § 922(b)(4) requiring authorization for dealer transfers of SBRs and SBSs. ATF is temporarily declining to enforce that requirement while it develops a new approval process.
Additional Liability for Virginia Firearms Dealers
Virginia's new Firearm Industry Standards of Responsible Conduct creates additional potential civil liability for firearms businesses, including lawsuits, damages, and legal expenses.
The law requires dealers to maintain reasonable business practices and comply with applicable state and federal laws. Its provisions may also apply to suppressor transactions.
As a Virginia FFL, I have to consider the potential consequences for both my customers and my business. While ATF may decline to enforce certain federal requirements, that does not necessarily protect us from state criminal laws or civil liability.
Given these unresolved legal questions, Kitchen Table Guns will continue requiring approved Form 4 transfers for SBRs and SBSs.
I believe this is the responsible approach until the legal situation becomes clearer.
Making an Informed Decision
I support giving customers more freedom and flexibility in how they purchase firearms and suppressors. However, I also believe customers deserve to understand the potential consequences before making that choice.
The most important thing to understand is that today's ATF policy could be reversed, potentially leaving owners of unregistered NFA items without a legal way to keep or register them.
That's a risk each customer needs to weigh carefully.
Kitchen Table Guns will continue following developments and updating our transfer policies as additional guidance becomes available.
For more information, I encourage you to review ATF's official publications:
If you have questions about an existing transfer or want to discuss your options, please contact Kitchen Table Guns.
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