How Long Must an FFL Keep Form 4473s?
The short version: not 20 years. That answer has been out of date since August 2022, and it is still the most common answer you will find online.
By Dana Fales, licensed FFL dealer and U.S. Army veteran · Published · Updated
Until your business or licensed activity is discontinued. Under 27 CFR 478.129(b), Forms 4473 are retained for as long as you hold your license. There is no routine destruction date while you remain in business.
What changed in 2022
The retention rule was amended effective August 24, 2022, as part of the ATF final rule commonly known by its docket number, 2021R-05F. Before that amendment, the regulation set a 20-year retention period for completed Forms 4473, after which a licensee could dispose of them.
That is no longer the standard. The current regulation ties retention to the life of the license rather than to a fixed number of years. As long as you are licensed and operating, the forms stay.
Why "20 years" is still the most common wrong answer
"Keep 4473s for 20 years, then you can destroy them." This was correct before August 2022. It is not correct now, and repeating it can lead a dealer to destroy records they are still required to hold.
Here is the part that causes most of the confusion: the number 20 still appears in the current regulation. It just does not mean what people think it means.
Under the current rule, once paper Forms 4473 are more than 20 years old, they become eligible to be moved to a separate warehouse facility rather than kept in the main business premises. That is a storage-location allowance. It is not permission to destroy anything.
Records moved to that warehouse are still treated as part of your business premises, and they remain subject to inspection. So the practical effect of the 20-year mark is that you may be allowed to store old paperwork somewhere other than your shop, not that you may get rid of it.
Warehouse storage has its own conditions, and the specifics of what qualifies as an approved separate facility are not covered here. If you are considering moving records off your main premises, confirm the current requirements with ATF before you move anything.
Your A&D bound book follows the same rule
Dealers sometimes assume the acquisition and disposition record has a different clock than the 4473s. It does not. For dealers, 27 CFR 478.129(e) applies the same until-discontinuance standard to the A&D record.
The parallel warehouse allowance exists here too: paper A&D records may be eligible for separate storage where there are no open dispositions and no dispositions within the last 20 years.
27 CFR 478.129(d) is the parallel provision covering importers and manufacturers. It is not the correct citation for a dealer's bound book; that is paragraph (e). If you are quoting the regulation in your own written procedures, make sure you are citing the paragraph that actually applies to your license type.
The records that do have a shorter minimum
Not every FFL record follows the until-discontinuance rule. Under 27 CFR 478.129(c), two forms carry five-year minimum retention periods:
- ATF Form 3310.4: report of multiple sale or other disposition of pistols and revolvers
- ATF Form 3310.11: federal firearms licensee theft/loss report
One clarification worth making, because it gets conflated: 27 CFR 478.39a is the rule that requires you to report a theft or loss. It is a reporting obligation, not a retention authority. The retention period for the resulting form comes from 478.129(c).
Quick reference
| Record | Retention | Citation |
|---|---|---|
| Form 4473 | Until business or licensed activity is discontinued | 478.129(b) |
| Dealer A&D bound book | Until business or licensed activity is discontinued | 478.129(e) |
| Form 3310.4 (multiple sale) | 5 years minimum | 478.129(c) |
| Form 3310.11 (theft/loss) | 5 years minimum | 478.129(c) |
What happens when you actually do go out of business
"Until discontinuance" naturally raises the next question: then what? When a licensee discontinues business, the records do not simply become yours to discard. They are either transferred to a successor licensee or delivered to ATF.
Discontinuance handling, including where records go and the timeframe for delivering them, is governed separately from the retention rule itself. If you are winding down, closing, or selling, get the current procedure directly from ATF rather than relying on a summary. This guide deliberately does not give you a deadline to rely on.
Common questions
Can I keep 4473s electronically instead of on paper?
Does a denied or cancelled transaction change the retention period?
My old compliance binder says 20 years. Should I update it?
Does software make me compliant?
How FFL Command Center handles retention
Since the current rule requires records to be held for the life of the license, the simplest correct behavior is to never delete them. FFL Command Center retains 4473 records and A&D entries indefinitely rather than implementing an automatic purge, which satisfies every subsection above without asking you to track separate clocks per record type.
Bound book output is labeled with the current citation — retain until discontinuance under 27 CFR 478.129(e), rather than the pre-2022 language that still appears on a lot of templates in circulation.
Dana Fales holds an active Federal Firearms License and operates Fales Guns, a licensed dealership in Coral Springs, Florida. A U.S. Army veteran who served as a Blackhawk crew chief, with more than 30 years of firearm ownership, Dana built FFL Command Center after keeping these records by hand, and tested it in an operating gun shop before selling it to anyone else. More about Dana.
Related reading: A&D bound book requirements · What to expect in an ATF compliance inspection · Key ATF rulings explained · Electronic bound book software · Best FFL software in 2026
Built by a Dealer Who Keeps These Records Too
FFL Command Center was built in an operating gun shop, not a software office. If you want to see how the bound book and 4473 workflow actually behave day to day, ask for a walkthrough.