NFA Firearm Questionnaire Gets Facelift: Feedback Invited
Published Date: 11/20/2025
Notice
Summary
The ATF is updating its Responsible Person Questionnaire (Form 5320.23) and wants your feedback by December 22, 2025. This form affects folks involved with National Firearms Act items, helping the ATF keep things safe and clear. The update aims to make the form easier to use without adding extra hassle or costs.
Analyzed Economic Effects
4 provisions identified: 2 benefits, 1 costs, 1 mixed.
Shift to Electronic Filing and IDs
ATF will make Form 5320.23 electronically fillable and digitally signable as an interim step and expects to add the form to its eForms platform soon, with a move to solely electronic forms in 2026. The revisions also reduce paper/photo/fingerprint burdens by removing a photo box, allowing a copy of a photo ID instead of a passport-style photo, reducing who must provide fingerprints or photographs, permitting additional types of electronic/digital signatures, and allowing electronic fingerprints on-site.
Large Increase in Affected Responsible Persons
The information collection was revised to reflect an increase in responsible persons from 115,829 to 749,242 per year (an increase of 633,413 people). As a result, ATF estimates total annual burden hours rose from 57,915 to 149,848 (an increase of 91,933 hours) even though per-person burden fell.
Who Must Submit Form 5320.23
If a trust or other legal entity (including corporations or married couples acting jointly) files ATF Form 5320.1, 5320.4, or 5320.5, each "responsible person" listed must submit ATF Form 5320.23 so the ATF can collect personal identity information for background checks. Submitting Form 5320.23 is required to obtain or retain the benefit of registering or transferring National Firearms Act (NFA) firearms, and it is completed once annually for each responsible person.
Reduced Time Per Respondent
ATF estimates each responsible person will spend about 12 minutes (0.2 hours) to complete Form 5320.23 once per year. ATF estimates 749,242 respondents per year and a total annual burden of 149,848 hours, with total estimated annual other costs of $0.
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