The Life-Saving Promise of State Gun Dealer Licensing

Overview of Federal Law Regulating Gun Dealers

Our federal system has failed to protect the public with meaningful regulation and oversight of gun dealers. The federal statutes do require dealers to run criminal background checks on buyers, require on-site record keeping for all sales, and allow regulators to inspect dealers and discipline bad actors. But they provide no physical security requirements—meaning dealers are not required to lock their front door or to secure the guns themselves. The statutes do not require training for gun store employees—or background checks to ensure employees are not barred from handling guns at all. Restrictions in federal law further bar regulators from requiring the centralization of sales records, making it harder to trace crime guns, and block officials from asking for basic inventory records from individual stores, making it harder to uncover malfeasance. And federal regulators must go through an arduous process to discipline dealers for violations, meaning that it is hard to stop bad actors. In addition, the Bureau of Alcohol, Tobacco, Firearms and Explosives’ (ATF) full potential as a law enforcement agency has been stymied not only by legal restrictions that prevent the agency from utilizing these simple modern tools, but also by insufficient funding for operations and personnel.

This regulatory scheme lacks basic safeguards and is inadequate to meet the realities of modern commerce. Indeed, it fails to adequately hold dealers responsible when they engage in illegal conduct, frustrating efforts to curb gun trafficking and gun violence. A small number of dealers account for a large proportion of crime guns:¹“Crime guns” are firearms recovered at crime scenes and traced to the first point of retail sale by law enforcement. Department of the Treasury, Bureau of Alcohol, Tobacco & Firearms, Commerce in Firearms in the United States, February 2000, at 2. A recent examination of firearms trace data in Pennsylvania revealed that six gun shops—making up only 1.2 percent of dealers in the state—accounted for 57 percent of the state’s crime guns. An investigation by the United States House of Representatives yielded similar results, finding a small number of firearm retailers in Georgia, Indiana, Florida, and Michigan are responsible for a large proportion of their respective states’ crime guns.²Letter from the Committee on Oversight and Reform to the ATF, April 28, 2022, https://int.nyt.com/data/documenttools/house-committee-atf-guns/bcb0abe2fc89407f/full.pdf. In fact, between 2014 and 2019, one dealer in Georgia alone accounted for more than half of the state’s crime guns, with approximately one in ten guns sold by the dealer later showing up at crime scenes.³Id. A recent report by Everytown revealed how gun dealers can fuel gun trafficking.

A growing body of evidence demonstrates that gun dealers’ sales practices affect the probability of guns getting to traffickers and that policies designed to hold dealers accountable can curtail the diversion of guns from the legal market. One study found that in-state trafficking was 64 percent lower in places with strong gun dealer regulations and oversight,⁴Webster, Vernick, & Bulzacchelli, “Effects of state-level firearm seller accountability policies on firearm trafficking,” Journal of Urban Health (2009), https://doi.org/10.1007/s11524-009-9351-x. and ATF data shows that gun dealers lose over seven times more guns to robberies in states without dealer licensing laws.⁵Analysis of ATF “Federal Firearms Licensee Theft/Loss Report – 2023” data, https://www.atf.gov/resource-center/federal-firearms-licensee-theftloss-report-2023. Another study found that state licensing requirements and laws requiring or allowing inspections or audits of gun dealers were independently associated with significantly lower firearm homicide rates.⁶Irvin, et al., “Evaluating the effects of state regulation of federally licensed firearms dealers on firearm homicide,” Am J Public Health (2014), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4103238/.

Despite the statutory and resource challenges faced by the ATF, the Biden-Harris Administration committed to crack down on unscrupulous gun sellers. The federal law that requires gun sellers to get licenses in the first place—and therefore run background checks on buyers and keep basic sales records—was written vaguely, and historically regulators had not stepped up to enforce it fully. However, the June 2022 Bipartisan Safer Communities Act (BSCA) revised the law to cover more gun sellers, including those who sell firearms at gun shows and on online marketplaces. In April 2024, ATF finalized its regulation on BSCA’s revised language, ensuring those “engaged in the business” of firearms dealing do indeed submit to regulation and run background checks on their gun buyers. The Administration also leveraged the ATF’s existing authority to combat rogue gun dealers, establishing in June 2021 a zero-tolerance policy for rogue gun dealers that willfully violate the law, pursuant to which the ATF sought to revoke dealer licenses the first time they violate certain federal firearm laws, including for example, selling guns without conducting background checks. But the Trump-Vance Administration has promised to undo this life-saving progress on gun safety, issuing an executive order on February 7, 2025 directing the Attorney General to review all actions touching firearms over the past four years, specifically calling out the zero-tolerance policy as an “infringement” of the Second Amendment,⁷White House, “Fact Sheet: President Donald J. Trump is Protecting Americans’ Second Amendment Rights,” February 7, 2025, https://www.whitehouse.gov/fact-sheets/2025/02/fact-sheet-president-donald-j-trump-is-protecting-americans-second-amendment-rights/. even though the right to keep and bear arms is not implicated by laws regulating gun dealers. On April 7, 2025, the Administration eliminated the zero-tolerance policy entirely—and announced its intention to dismantle the “engaged in the business” rule.⁸ATF Press Release, “DOJ, ATF Repeal FFL Inspection Policy and Begin Review of Two Final Rules,” April 7, 2025, https://www.atf.gov/news/press-releases/doj-atf-repeal-ffl-inspection-policy-and-begin-review-two-final-rules. 

Despite the current Administration focusing on rolling back critical protections, gun safety leaders in many states can step into the regulatory void and set up their own protections against rogue dealers—and many leaders are continuing to innovate and push forward this life-saving work in this consequential moment. State-level licensing requirements can close the hazardous gaps in the federal system—for example requiring that dealers physically secure their stores and their firearms, run background checks on their employees, open themselves up to frequent compliance inspections—and set a stronger bar for which sellers must get a dealer license in the first place. These state-level protections can do what federal law has failed to do: ensure that dealers are not easily susceptible to theft, burglary, straw purchasers, or gun traffickers. 

Sixteen states and the District of Columbia currently license and regulate firearms dealers. The programs vary widely, from a minimal regime in Alabama requiring only that dealers obtain licenses and display them on the premises to the most robust efforts in states like California and Massachusetts, which, among other strong features, require dealers to submit all sales records to law enforcement.⁹Cal. Pen. Code § 26905(a); Mass. Gen Laws ch. 140, §§ 122-122B, 123-128A. While many of these state systems are decades old, several states have passed laws in recent years to either establish their licensing requirements or strengthen their existing systems.

This paper is the latest in Everytown’s series profiling policy innovations in the gun safety movement—exploring the many ways state-level dealer licensing can enhance community safety across the country. The best-in-class state systems point the way for more states to act—and also for federal advocacy,¹⁰The “Federal Firearm Licensee Act” (H.R. 2618/S. 1294), introduced by Representative Kelly (D-IL) and Senator Durbin (D-IL), clarifies responsibilities of gun dealers and provides tools with which ATF can readily identify rogue firearm dealers and address dangerous licensee misconduct that facilitates gun violence. proving we can demand that our federal policymakers build a robust infrastructure around legal gun sales. 

Key Takeaways

1. State dealer licensing systems can stand in for federal regulation—and protect the public more robustly than federal officials are able or willing to do by giving state authorities the power to oversee dealers and enforce strong rules.
2. State dealer regimes can help enforce and complement other gun safety laws and programs, with dealers helping to ensure that purchasers comply with gun laws and educating them about responsible gun ownership policies.
3. Even where it may not be politically feasible to enact a full dealer licensing system, states can still take action to regulate dangerous dealer behavior. 

Key Elements of State-Level Gun Dealer Oversight

• Require gun dealers to obtain a state license in addition to the license required by federal law, and prohibit issuance of a license to a person who is prohibited from having guns under federal or state law, who has previously had a gun dealer license revoked (absent extenuating circumstances), or where the issuance of the license would be a danger to public safety.
• Require gun dealers to implement security measures to prevent theft, including locking gun stores at all times when the business is closed, physically securing guns on the business premises, and utilizing alarm and video surveillance systems.
• Mandate periodic background checks and training for gun dealers and their employees.
• Authorize a state agency or local law enforcement to conduct regular compliance inspections of gun dealers.
• Require gun dealers to send records of all gun sales to state officials for retention.
• Authorize disciplinary action against gun dealers who violate the law, including suspension and revocation of state license in specified circumstances.
• Require gun dealers to provide information to gun buyers at the point of sale about secure storage, suicide prevention, and the risks associated with firearm ownership.
• Establish a minimal threshold for responsible business conduct by gun dealers and allow for civil liability if their firearms cause harm.
• Require authorities to prepare an annual report that includes information on dealer applications, inspections, and disciplinary actions.

I. Strong state dealer licensing can fill in for an inadequate federal system.

While federal law puts some rudimentary obligations on gun dealers—such as keeping firearm purchase and sale records,¹¹18 U.S.C. § 923(g)(1)(A). maintaining a physical premises for their business,¹²18 U.S.C. § 923(d)(1)(E). and fielding trace requests relating to crime guns¹³18 U.S.C. § 923(g)(7).—it lacks many basic features of a smart licensing system, leaving ATF without critical tools in the toolbox.

Indeed, Congress has passed several laws explicitly prohibiting certain ATF actions, leading to some of the more glaring omissions from the federal regime. ATF has no authority to require licensees to send in physical inventories¹⁴ATF has been prohibited from utilizing appropriated funds “to promulgate or implement any rule requiring a physical inventory” by FFLs since 2013. 18 U.S.C. 923 note; Public Law 113–6, Div B, Title II; 127 Stat. 248. and no authority to conduct compliance inspections more than once per year¹⁵18 USC 923(g)(1)(B)(ii)(I).—requirements that could enable more timely reporting of lost or stolen firearms. While ATF’s hands are tied, these stolen and, increasingly, lost guns make their way to the illegal market. There are roughly five incidents per day where firearms go missing from gun dealers through robbery, burglary, larceny, or other loss.¹⁶Department of the Treasury, Bureau of Alcohol, Tobacco & Firearms, Federal Firearms Licensee Theft/Loss Report – 2022, available at https://www.atf.gov/resource-center/federal-firearms-licensee-theftloss-report-2022. Lost guns are rarely found—only 2.6 percent of all firearms reported missing by federally licensed dealers between 2016 and 2020 have been recovered.¹⁷Id. at 109. 

State policymakers have targeted the federal gaps directly, requiring all dealers in their states to take basic steps that prevent firearms from being illegally diverted from lawful commerce. Several of the requirements recently added to licensing regimes in Maryland, New York, and New Jersey—including strong security features, forwarding sales records to state officials, monthly inventory checks, and retention of gun trace information—fit squarely in areas where ATF lacks authority or fails to exercise oversight.

Until we have responsible federal leadership, and until federal law catches up, all states should add licensing laws that include several key requirements for gun dealers within their borders.

A. Physical Security

There is no federal law or regulation that requires gun dealers to implement minimum security measures to safeguard their premises and make themselves less vulnerable to loss or theft. ATF has published a guide with information on how retailers can prevent thefts, but adoption of its practices and procedures is completely voluntary.¹⁸ U.S. Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives, “Loss Prevention for Firearms Retailers,” January 2016, https://www.atf.gov/file/109806/download. In other words, FFLs are not required to lock their front doors or secure their guns to the wall or in a locked room. 

The importance of dealer security cannot be understated—robberies and burglaries from dealers are a significant source of illegally trafficked guns.¹⁹Department of the Treasury, Bureau of Alcohol, Tobacco & Firearms, “Following the Gun: Enforcing Federal Laws Against Firearms Traffickers,” June 2000, at xi. In 2021, a single gun stolen from the display case of a dealer in Wisconsin was linked to 27 shootings over nineteen months in neighboring Illinois before it was recovered by law enforcement.²⁰Jeremy Gorner, Annie Sweeney and Rosemary Sobol, “A Gun Was Stolen From a Small Shop in Wisconsin. Officials Have Linked it to 27 Shootings in Chicago,” The Chicago Tribune, September 25, 2021, https://www.chicagotribune.com/news/criminal-justice/ct-stolen-gun-multiple-crimes-chicago-20210921-aiqhedigtnhrbnikogk26vgdcu-story.html. As custodians of valuable and dangerous inventory, gun dealers should be required to securely guard firearms in their possession against theft.

Many states have addressed this gaping loophole by requiring licensed dealers to implement security measures. The states are varied in their approach—some with statutory mandates and others with detailed regulations—showing there are multiple ways to require that dealers secure a highly portable and dangerous inventory from theft.

Several states specify the required security methods in statute or regulations. For example, in California, when not open for business, dealers must either store firearms in a secure part of their premises, secure firearms with a rod or cable through the trigger, or store firearms in a locked fireproof safe.²¹Cal. Pen. Code § 26890(a)(1-3). In Washington, D.C., dealers must keep all firearms and ammunition in “a securely locked place affixed to the premises” when they are not being shown to a customer, being repaired, or otherwise worked on.²²D.C. Code § 7-2504.07(a). Connecticut requires a burglar alarm connected to the local police department or monitored by a central station.²³Conn. Gen. Stat. § 29-37d(a).

Other states instead require security plans to be submitted to and approved by regulators. In New Jersey dealers must submit a plan of their security system to the Superintendent of State Police. The plan must be approved prior to the system’s installation and before the dealer can have any sales inventory.²⁴N.J. Admin. Code § 13:54-6.2(a), (b). Firearms dealers in Delaware are required to establish “reasonable procedures, safeguards and business practices that are designed” to prevent firearm theft.²⁵10 Del. C. § 3930(a)(6). They are also required to provide a description of their theft and loss prevention policies to the Department of State as a condition of licensure.²⁶24 Del. C. § 902(b)(1).

Illinois requires both a video surveillance and alarm system and also the submission of a safe storage plan to the state police.²⁷430 ILCS § 68/5-55. The plan must address, among other things, removing or replacing firearms to show to customers, structural security, and employee training on theft prevention measures.²⁸20 Ill. Admin. Code 1232.80(a)(3),(7), and (9). State Police credit the physical storage law with thwarting attempts to steal guns from Illinois retailers.²⁹Illinois State Police News Release, “Guns Stolen from Firearms Dealers Drops Following Illinois State Police Inspections,” January 23, 2025, https://isp.illinois.gov/Media/CompletePressRelease/2104.

B. Employee Background Check and Training Laws

Federal law is silent on the qualifications for firearm dealer employees. Indeed, until 2022, FFLs were not even statutorily permitted to use the federal background check system to run voluntary checks on their employees to ensure they are not legally prohibited from having guns. But many states have wisely required gun dealers to perform due diligence on their workers. This commonsense measure requires employees—who are entrusted with handling firearms on a dealer’s behalf—to be screened to ensure they are not legally prohibited from possessing them. Several states go one step further by requiring training for dealer employees, an effort that can help educate gun owners about their obligations under the law. 

Several states require employees to pass a background check as a condition of employment, including Massachusetts³⁰Mass. Gen. Laws. ch. 6, § 172M. and Delaware, which also requires annual background checks for employees.³¹24 Del. C. § 904(b). In Connecticut, employees of certain dealers must submit to state and national criminal history record checks and take a course on firearms safety and statutory procedures around gun sales.³²This requirement applies only to dealers whose principal business is the retail sale of goods other than firearms. Conn. Gen. Stat. § 29-37f. Washington requires every dealer employee to be eligible for a concealed pistol license.³³ARCW § 9.41.110(5)(b).

In Washington, D.C., dealer employees must also meet a high bar, including that they have not been convicted of a weapons offense or felony, do not have a recent history of violent behavior, and have completed a firearms training and safety class.³⁴D.C. Code Ann. § 7-2504.07(b) (stating that no firearm dealer shall employ a person who would not be eligible to register a firearm themselves under D.C. Code § 7-2502.03(a)). Illinois law requires dealers to notify authorities of new employees, owners, or agents within 30 days, and requires employees to receive at least annual training on dealers’ legal requirements and responsible business practices.³⁵430 ILCS § 68/5-30. One state requires new employees to go through the same process as dealers themselves: in New Jersey, gun store workers must get their own state dealer licenses.³⁶N.J. Stat. Ann. § 2C:58-2(a). 

Whether through a background check or permit process, these states fill a critical public safety gap that helps to ensure that all gun store workers can be trusted to safely, responsibly, and legally transfer guns.

Failure to vet or train employees—the norm in states without these licensing requirements—can have devastating consequences.

• A former employee of a gun shop in West Virginia was sentenced to federal prison for fraudulently filling out federal firearms forms and directing others to do so in connection with the straw purchase and transfer of more than 30 firearms.¹United States Attorney’s Office, Southern District of West Virginia, “Former Logan County Gun Shop Employee Sentenced to Prison for Federal Firearms Charge,” July 28, 2016, https://www.justice.gov/usao-sdwv/pr/former-logan-county-gun-shop-employee-sentenced-prison-federal-firearms-charge.
• The Minnesota Attorney General filed a civil lawsuit against a large retailer for negligently selling dozens of firearms later involved in crimes to straw purchasers within a 16-month period.²Dana Ferguson, “Minnesota Sues Fleet Farm Over ‘Dangerous’ Firearm Sales,” MPRNews, October 5, 2022, https://www.mprnews.org/story/2022/10/05/minnesota-sues-fleet-farm-over-dangerous-firearm-sales. The complaint alleges that the retailers ignored obvious signs of straw purchasing.³State v. Fleet Farms LLC, No. 27-CV-22-14473 (4th Jud. Dist. filed Oct. 5, 2022).
• An investigation of one former manager at a Florida gun dealer revealed that he had engaged in various illegal firearms-related activities during his employment, including falsifying paperwork relating to the acquisition and disposition of firearms in the dealer’s inventory.⁴United States Attorney’s Office, Middle District of Florida, “Naples Man Sentenced to Federal Prison for Possessing Illegal Machineguns and Unregistered Firearm Silencers,” November 7, 2022, https://www.justice.gov/usao-mdfl/pr/naples-man-sentenced-federal-prison-possessing-illegal-machineguns-and-unregistered.
• In Montana, an FFL employee pleaded guilty to federal charges after an ATF sting investigation of the pawnshop where he worked. The employee had felony convictions that federally prohibited him from possessing firearms; he subsequently ignored obvious signs of straw purchasing and helped steal ammunition.⁵United States Attorney’s Office, District of Montana, “Helena Pawn Shop Employee Sentenced to Three Years in Prison for Firearm Crime,” June 27, 2022, https://www.justice.gov/usao-mt/pr/helena-pawn-shop-employee-sentenced-three-years-prison-firearm-crime.
• In New Mexico, an FFL employee caught the eye of ATF after 13 guns recovered in suspected criminal activity were traced to him as the buyer, 10 with a short time between retail purchase and recovery—a sign that a gun was likely purchased for the purpose of trafficking.⁶Matthew Reisen, “guns on the Streets: Straw Buying Happening ‘Every Single Day’ in ABQ,” Albuquerque Journal, November 6, 2022, https://www.abqjournal.com/2546819/new-federal-law-to-address-straw-buying.html.

C. Clarifying Who Must Obtain a License

While the federal system is not as strong as it should be, licensed dealers do have important obligations, including running background checks on purchasers and keeping records of gun sales. Under federal law, every person who is “engage[d] in the business” of selling firearms is required to obtain a federal firearms license from ATF.³⁷S. 2938 (BSCA) § 12002. But for decades, until the enactment of BSCA in 2022, there had been a lack of clarity around the “engaged in the business” standard that made it unusually difficult to prosecute high-volume gun sellers for failing to get licensed.³⁸Though introduced in the law in 1968, the phrase “engaged in the business” was not defined until 1986, in the Firearm Owners’ Protection Act, and even then, the definitions provided were vague enough to, in the words of ATF, “give certain people a basis to contend that their firearm activities do not rise to a level that requires them to obtain a license and be regulated by the Federal government.” Bureau of Alcohol, Tobacco and Firearms, “Commerce in Firearms in the United States,” Washington, DC: U.S. Department of the Treasury, 2000, at C-3. In April 2024, the ATF finalized a new rule making it clear that anyone who offers a gun for sale at a gun show or pursuant to an advertisement—including online—is presumptively “engaged in the business,” and making it easier for ATF to compel sellers to get licensed when the law requires and to crack down on unregulated, no-background-check sales. However, the gun industry is vehemently opposed to the rule and as of this writing it is imperiled. There are several legal challenges to the rule that have stymied enforcement, the Trump Department of Justice has not shown an interest in defending it,³⁹In a Kansas court challenge, DOJ has agreed not to enforce the law in 21 states. See https://storage.courtlistener.com/recap/gov.uscourts.ksd.152714/gov.uscourts.ksd.152714.226.0.pdf. and the new Administration has already announced its intention to dismantle the rule altogether.⁴⁰ATF Press Release, “DOJ, ATF Repeal FFL Inspection Policy and Begin Review of Two Final Rules,” April 7, 2025, https://www.atf.gov/news/press-releases/doj-atf-repeal-ffl-inspection-policy-and-begin-review-two-final-rules.

The story is quite different on the state level, where lawmakers have historically provided clearer standards for who is required to obtain a state license. Indeed, a few states even place numerical limits on the number of firearms an individual may sell before they are required by law to obtain a state dealer license. In California, for example, individuals who conduct more than “infrequent” firearm sales must obtain licenses—with “infrequent” defined as both fewer than six transactions and 50 total firearms per year (or, for secondhand firearms at gun shows or events, 12 gun shows per year, 15 firearms per show, and the sale of up to 75 guns).⁴¹Cal. Pen. Code §§ 26530, 26535, 26560. Connecticut’s licensing requirement applies to all individuals who sell 10 or more firearms per calendar year.⁴²Conn. Gen. Stat. § 29-28(a). In Massachusetts, a dealer license is required for sales or transfer of more than four firearms in a year.⁴³Mass. Gen. Laws ch. 140 § 128A. Exceptions exist for sales or transfers to persons or entities other than federal firearms licensees, federal state or local historical societies, museums or institutional collections open to the public. These thresholds coexist with the federal “engaged in the business” standard: in these states, an individual must obtain a federal license if they meet the standard for engaging in the business of dealing firearms—as well as a state license if they meet the thresholds set forth in state law. 

Numerical limits such as these can provide greater certainty to firearm sellers, who can easily understand the point at which their conduct rises to a level requiring a state license. They also enhance regulators’ ability to enforce a licensing system by providing a simple and objective test of when a person is engaged in the business of firearm selling. More states that license dealers should consider adding these provisions.

D. Compliance Inspections

Federal law significantly hinders the ability of ATF to inspect licensed dealers, permitting inspections only under limited circumstances. ATF may inspect licensees when determining the disposition of a firearm in the course of a criminal investigation or (if they have a warrant) where there is reasonable cause to believe that a violation of federal law has occurred and that evidence of the violation may be found on licensed premises.⁴⁴18 USC § 923(g)(1)(A), (B). Otherwise, ATF is only permitted to inspect a licensed dealer for compliance once in any 12-month period.⁴⁵18 USC § 923(g)(1)(B).

In practice, ATF is only able to inspect a small percentage of licensees each year. In fact, in every year between 2019 and 2023, less than 15 percent of FFLs were inspected by their federal regulator.⁴⁶ATF Report Vol. 1, at 132. Part of this enforcement breakdown can be attributed to the sheer number of FFLs across the country (as of February 2025, there were over 78,000 FFLs nationwide⁴⁷Type 3 licenses are not engaged in sales and thus are not included in this figure.) and ATF’s limited resources in light of its other responsibilities.⁴⁸ATF lacks the resources to even reach its informal goal of inspecting FFLs for compliance once every 3 years and admits that to do so would require a 130 percent increase in personnel. ATF Report Vol. 1, 162-63. For example, ATF has 60 days from receipt to approve or deny an FFL application.⁴⁹18 U.S.C. § 923(d)(2). This time-sensitive requirement draws ATF’s resources away from compliance inspections in favor of “qualification inspections” of these applicants. 

Fortunately, several states have filled gaps in federal law by giving state or local officials the authority to regularly conduct compliance inspections. In Hawaii and Pennsylvania, authorities may inspect licensed dealers without limitation.⁵⁰HRS § 134-32(4); 37 Pa. Code § 33.116(c). Authorities in Illinois are allowed a maximum of one licensed dealer inspection each year, though more frequent inspections are permitted in Illinois if they are part of an investigation into potential violations or to follow up when dealers enter into remediation plans to cure violations unearthed in an earlier inspection.⁵¹430 ILCS § 68/5-35; Mass. Gen. Laws ch. 140, § 123; Ill. Admin. Code tit. 20, § 1232.5(a)(1). And several states prioritize inspections by setting a maximum period between these visits: Maryland authorities are required to inspect licensed dealers at least once every two years while authorities in California and New York are required to inspect state dealers at least once every three years.⁵²Md. Pub. Safety Code Ann. § 5-145(f); Cal. Pen. Code § 26720(a)(1) (commencing January 1, 2024); NY CLS Gen Bus § 875-g(2)(a) (Effective Dec 3, 2022).

Several states separately authorize state or local law enforcement to review licensed dealers’ records at any time.⁵³Cal. Pen. Code § 26900(a) (register of transactions); Conn. Gen. Stat. § 29-31 (sales records); 24 Del. C. §§ 904(a),(b) (sales records, employee lists and records of criminal history checks); D.C. Code § 7-2504.04(b) (records); 720 ILCS §§ 5/24-4(a)-(c) (sales and gift register); Mass. Gen. Laws ch. 140 § 123 (sales record book); N.J. Stat. § 2C:58-2(b) (sales register); N.Y. Penal Code § 400.00(12) (record book). Rhode Island requires law enforcement to inspect licensed dealers’ registers of sale monthly.⁵⁴11 R.I. Gen. Laws § 47-40(a).

E. Centralized Records

ATF is prohibited from establishing any system or register of firearms transactions or centralizing dealers’ records.⁵⁵18 U.S.C. § 926(a). As a result of these restrictions, when tracing a crime gun, ATF’s National Tracing Center is required to call individual dealers identified as part of the distribution chain to get specific purchaser information. When a dealer goes out of business, it is required to submit all of its business records to the ATF for purposes of facilitating future crime gun traces. But ATF is blocked from “consolidating or centralizing” these records, ultimately delaying the time in which law enforcement can solve gun crimes—and there is danger in the Trump era that the requirement for out-of-business records to be sent to ATF could be partially repealed.  

According to ATF, “routine” traces are completed within seven to ten days on average,⁵⁶ATF, National Tracing Center, https://www.atf.gov/firearms/national-tracing-center. but recent reporting suggests that it actually takes 12 to 14 days, due to an increase in shootings across the country and more agencies seeking gun trace assistance, as well as limited ATF staff resources.⁵⁷Simone Weichselbaum, Andrew Blankstein, Yasmine Salam and Frank Thorp V,“‘It’s just insanity’: ATF Now Needs 2 Weeks to Perform a Routine Gun Trace,” NBC News, August 19, 2022, https://www.nbcnews.com/news/s-just-insanity-atf-now-needs-2-weeks-perform-routine-gun-trace-rcna39606. 

This antique and sluggish system means that violent crimes go unsolved far too frequently. Thankfully, states can make better policy that allows them to quickly identify firearms retrieved at crime scenes within their borders. Indeed, a handful of states require all gun dealers to regularly submit certain sales records to local and/or state law enforcement.

In California, firearm purchaser information must be transmitted to the California DOJ on the same date the application to purchase a firearm is made.⁵⁸Cal. Pen. Code § 28215(d). In Connecticut, copies of the records of sale must be sent to both a state agency and the chief of police of the municipality in which the transferee resides within 48 hours for handguns, or 24 hours for long guns.⁵⁹Conn. Gen. Stat. §§ 29-33(e), 29-37a(d). Maryland and D.C. require submission of certain sales records to police within seven days.⁶⁰D.C. Code § 22-4510(a)(5) (pistols, machine guns, sawed-off shotguns, and blackjacks); Md. Pub. Safety Code Ann. §§ 5-123; § 5-101(r) (“regulated firearms,” defined as a handgun or certain semi-automatic weapons). In Washington, licensed dealers must send a record for every pistol or semi-automatic assault rifle to local law enforcement.⁶¹ARCW § 9.41.110(9)(b). Pennsylvania dealers must send completed applications and records of sale to the state police within 14 days of sale.⁶²18 Pa.C.S. § 6111(b)(1).

F. Disciplinary Powers

Federal law details a limited and cumbersome process for ensuring that dealers comply with the law.  In order to revoke a dealer license, ATF must find that the dealer “willfully” violated a law.⁶³18 USC 923(e). This means that simply violating the law is not sufficient; rather, ATF must prove that the dealer knew they were acting illegally, often by showing a record of warnings issued to the dealer. Less severe violations can result in a report, letter, or warning conference with the licensee.⁶⁴ATF, “Firearms Compliance Inspections,” last reviewed August 3, 2021, https://bit.ly/3HZCPSj. ATF data shows that dealer inspections generally result in a large number of violations—for example, in 2020, ATF inspectors found violations in almost half of inspections,⁶⁵ATF, “Firearms Compliance Inspection Results FY 2020,” last reviewed May 9, 2023, https://bit.ly/3VWJtP8. and from 2016 through 2020, ATF issued more than two million citations.⁶⁶ATF, “NFTCA, Volume I: Firearms in Commerce,” https://www.atf.gov/firearms/docs/report/national-firearms-commerce-and-trafficking-assessment-firearms-commerce-volume/download. Yet ATF has historically demonstrated little appetite for pursuing meaningful disciplinary measures against these dealers, such as suspending or revoking their federal license. 

Despite decades of chronic underfunding and underenforcement, the ATF under the Biden-Harris Administration implemented a zero-tolerance policy for rogue gun dealers and cracked down on willful violations by gun dealers.⁶⁷In August 2024, ATF issued an Order to provide “fair and consistent guidelines for administrative remedies for violations” committed by FFLs. ATF, “Federal Firearms Administrative Action Policy and Procedures,” ATF O 5370.1G,  https://www.atf.gov/resource-center/docs/foia/redacted-copy-atf-o-53701g508c2/download. Under the zero-tolerance policy, the ATF sought to revoke the licenses of dealers the first time that they violated certain federal laws. In the 2022 fiscal year, ATF revoked 88 licenses—more than triple the number of licenses revoked in 2021 and a higher rate of license revocation than in any year since 2006.⁶⁸ Everytown for Gun Safety Press Release, “New ATF Inspection Data Shows the Biden-Harris Administration is Holding Rogue Gun Dealers Accountable,” https://www.everytown.org/press/new-atf-inspection-data-shows-the-biden-harris-administration-is-holding-rogue-gun-dealers-accountable/ October 6, 2022. An additional 69 dealers ceased operations after inspections revealed violations that could result in license revocation. These figures climbed even further, with 157 revocations and 80 cessations in 2023 and 147 revocations and 74 cessations in 2024.⁶⁹ATF, “Enhanced Regulatory Enforcement Policy,” last reviewed February 5, 2024, https://bit.ly/44Jat8J. But on April 7, 2025, the Trump-Vance Administration eliminated the zero-tolerance policy entirely.⁷⁰ATF Press Release, “DOJ, ATF Repeal FFL Inspection Policy and Begin Review of Two Final Rules,” April 7, 2025, https://www.atf.gov/news/press-releases/doj-atf-repeal-ffl-inspection-policy-and-begin-review-two-final-rules. 

Several states also have made it easier for authorities to ensure that dealers comply with the law. For example, New York⁷¹NY CLS Penal § 400.00(11). and Hawaii⁷²HRS § 134-32(5). law provide that a dealer license may be revoked for any violation of the law. In Washington, dealers who deliver a firearm to an ineligible person are subject to mandatory permanent revocation of their license and permanent ineligibility for a dealer’s license.⁷³Rev. Code Wash. (ARCW) § 9.41.110(8)(b). This critical authority ensures that dealers cannot evade their legal obligations and put public safety at risk.

II. State dealer licensing helps to enforce state and local gun laws and promote responsible gun ownership.

Gun dealers are ubiquitous—the US has nearly 78,000 licensed gun dealers and 99 percent of Americans live within ten miles of one—and state and local governments have an important stake in regulating their operation to prevent theft, ensure we do not have trafficking targets in our community, and stop malfeasance. But dealers can also be critical partners in reducing gun violence, especially in ensuring purchaser compliance with gun laws. Indeed, policymakers can aim even higher: because of their daily interactions with buyers, dealers are convenient and credible messengers of policy that promotes responsible firearm ownership.

A. Gun Buyer Education

All FFLs are required by regulation to deliver written notifications to purchasers regarding handgun misuse, firearm storage, and the prohibition against giving handguns to people under 18.⁷⁴ 27 CFR § 478.103(b). But several states have pushed further with buyer education,⁷⁵Cal. Pen. Code § 26835(a)(9); Colo. Rev. Stat. § 18-12-405(2); Conn. Gen. Stat. § 29-37b(a); Fla. Stat. § 790.175(1); 430 ILCS § 68/5-20(b)(C); 15 M.R.S. § 455-A(1); Mass. Gen. Laws ch. 140, § 123; MCL § 28.435(3) and (6); Minn. Stat. § 624.7162(1-2); Neb. Rev. Stat. Ann. § 69-2426(1); N.J. Stat. § 2C:58-16(a); N.Y. Gen. Bus. Laws § 396-ee(1-2); NY CLS Penal § 400.00(20) (effective 1/7/2025); N.C. Gen. Stat. § 14-315.2(a); 18 Pa. Cons. Stat. § 6125; ARCW § 9.41.365(2); Tex. Penal Code § 46.13(g); Utah Code Ann. § 76-10-526(15); ARCW § 9.41.365(2); Wis. Stat. Ann. § 175.37(1). requiring dealers to post suicide prevention materials⁷⁶Cal. Pen. Code § 26835(b); Mass. Gen. Laws ch. 140, § 123; N.J. Stat. § 2C:58-2.12(c). or information about the state-level obligations to report lost or stolen firearms to officials.⁷⁷Cal. Pen. Code § 26835(a) (5 days); 430 ILCS § 68/5-20(b) (72 hours); Md. Pub. Safety Code Ann. § 5-146(a) (72 hours). California gun dealers must inform customers, among other information, of state laws limiting purchasers to one concealable firearm every 30 days.⁷⁸Cal. Pen. Code § 26835(a)(8). In Illinois, dealers are required to tell the public about the state’s background check laws, i.e. that it is unlawful to transfer a gun without a background check and state police approval. 

More states should expand the type of information shared with firearm purchasers at the time of sale. A recent Everytown study revealed that people die by gun suicide nearly four times more frequently in cities with the most gun shops (compared with cities that have the fewest shops), signaling the importance of incorporating dealers in gun safety efforts.⁷⁹Everytown Research & Policy, “Gun Suicides in Cities,” September 8, 2022, https://everytownresearch.org/report/gun-suicide-city-gun-violence/. States should require dealers to include robust suicide prevention materials—including, e.g., information about extreme risk laws and other tools for disrupting gun access by people in crisis, such as out-of-home firearm storage. 

B. Legal Accountability for Dangerous Practices

Several states have passed laws in recent years that require gun industry members, including dealers, to take greater care in how they sell and market firearms. As with most items covered in this paper, they are filling in major federal gaps—with laws that set expectations for how the gun business should be conducted and empower civilians and government actors alike to take industry players to court for dangerous practices.

Since 2005, the federal Protection of Lawful Commerce in Arms Act (PLCAA) has protected the gun industry from liability for irresponsible, reckless, and negligent practices that contribute to the flow of illegal guns—and indeed failing to follow the most basic tech innovations to make guns safer. No other industry enjoys such blanket federal immunity for the harm it causes—and indeed many states have since passed their own analogous laws. These nine state laws push back against this regressive trend, utilizing a PLCAA exception permitting legal action against gunmakers who violate state sales and marketing laws.

In most of the states leading in this area—California, Colorado, Delaware, Hawaii, Illinois, Maryland, New Jersey, New York, and Washington—the laws require that firearm industry members establish and implement “reasonable controls,” which are policies and procedures designed to ensure compliance with the law, prevent loss or theft, and prevent the sale of firearms to straw purchasers, traffickers, prohibited people, or other would-be buyers who appear to be a substantial risk to themselves or others.⁸⁰See, e.g., Cal Civ Code § 3273.50(h); 10 Del. C. § 3930(a)(6); N.J. Stat. § 2C:58-34; N.Y. Gen. Bus. Law § 898-a. Most also provide that dealers and other industry members must not create, maintain, or contribute to a public nuisance through the sale, manufacture, import, or marketing of a firearm.⁸¹See, e.g., Cal Civ Code § 3273.51(c); 10 Del. C. § 3930(b); N.J. Stat. § 2C:58-35(a)(1); N.Y. Gen. Bus. Law § 898-b(1).

PLCAA provides no incentive for firearm manufacturers to pay attention to the ultimate disposition of their products. And dealers have little incentive under federal law to take care in their own practices to avoid the diversion of firearms from lawful commerce. State laws aim to correct this imbalance, establishing a minimal threshold for lawful conduct by gunmakers and dealers—and exposing dealers to civil liability if their firearms cause harm. As such, these new state provisions force industry players to consider how to run businesses that do not cause widespread harm. The nine trail-blazing states will hopefully inspire many more to enact this critical legislation.

State dealer licensing regimes keep adapting

Recent legislation shows the innovative ways that states are bolstering dealer requirements:

• As of April 23, 2026, firearm dealers in Massachusetts must complete a firearm training program offered by the executive office of public safety and security. The training is required to cover standards of security for business premises, the requirements for employee background checks and training, and other information on firearm dealer licensing requirements and conditions.¹Massachusetts House Bill 4885, sec. 38, enacted July 25, 2024.
• As of July 1, 2025,  licensed dealers in Washington must secure their premises with specified security features to prevent unauthorized entry as well as install an alarm and a video surveillance system, secure firearms during business and non-business hours, and conduct monthly inventory checks, among other requirements.²Washington House Bill 2118, enacted March 26, 2024.
• California requires specific reporting of firearms dealer inspections conducted each year and any violations of important gun safety laws discovered during those inspections, beginning with the annual report due by July 1, 2025.³California Senate Bill 965, enacted September 24, 2024.
• As of October 2022, licensed dealers in Maryland must equip their premises with detailed security features, including video surveillance, security measures for exterior doors and windows, a burglar alarm system, and barriers that prevent a person from plowing a car into the building.⁴2022 Md. HB 1021. Dealers are also required to lock firearms in a vault, safe, or secured room when closed for business.⁵Md. Public Safety Code Ann. § 5-145.1(a)(2).
• As part of its 2022 legislative response to mass shootings in Uvalde and Buffalo, New York bolstered its program by requiring dealers to have an alarm system, provide training to all new employees. submit sales, purchase, and inventory records to state police twice annually, conduct monthly inventory checks, and maintain records of criminal firearm traces.⁶NY CLS Gen Bus § 875-b, e, and f.

III. States can regulate dangerous behavior—even without a full licensing regime.

While only 16 states have full-fledged dealer licensing laws, several more states have regulated dealers in valuable policy areas—making life-saving policy even without a requirement to apply for a license.

Many states require dealers to provide notices to purchasers regarding state and local firearms laws, information about the risks associated with guns, or gun safety information. In several states, these purchaser notices must describe the laws around gun access by minors, and risks to minors, including in Florida,⁸²Upon the retail commercial sale or transfer of any firearm, Florida law requires the seller to conspicuously post and deliver purchasers a warning that it is unlawful to store or leave a firearm in any place within the reach of an individual less than 18 years old or to knowingly sell or transfer ownership or possession of a firearm to a minor or person of unsound mind. Fla. Stat. § 790.175(1). Michigan,⁸³FFLs in Michigan must conspicuously post notice that firearms transferors may be criminally and civilly liable for any harm caused by a person younger than 18 years old who lawfully gains unsupervised access to an unlawfully stored firearm. MCL § 28.435(6). Nebraska,⁸⁴Nebraska’s only statutory requirement for FFLs in the state is that they must distribute information to purchasers regarding the dangers of leaving loaded firearms unattended around children. Neb. Rev. Stat. Ann. § 69-2426(1). North Carolina,⁸⁵In North Carolina, retail sellers of firearms must conspicuously post at each purchase counter, and provide to each purchaser, a warning regarding the unlawfulness of storing or leaving a dischargeable firearm in a manner that a reasonable person should know is accessible to a minor. N.C. Gen. Stat. § 14-315.2(a) and (b). Oregon,⁸⁶Dealers in Oregon must prominently post a notice setting forth a firearm purchaser’s obligation to store firearms in a safe manner and to prevent unsupervised access to a firearm by a minor. ORS § 166.405. Texas,⁸⁷Texas firearms dealers must conspicuously post on the premises a sign warning that it is unlawful to store, transport or abandon an unsecured firearm in a place where a child is likely to be and can obtain access. Tex. Penal Code § 46.13(g). and Wisconsin.⁸⁸All retail firearms dealers in Wisconsin must deliver a written warning upon transfer about leaving a loaded firearm within the reach or easy access of a child. Wis. Stat. Ann. § 175.37(1); Wis. Adm. Code Jus. § 10.10(1)(c). Other states require information on firearm safety or training programs, including Maine,⁸⁹ FFLs in Maine must post information on the availability of known local voluntary firearm safety programs. 25 M.R.S. §§ 2012(2)(c). Michigan,⁹⁰In Michigan, firearm sales by FFLs must be accompanied by a brochure or pamphlet with safety information regarding the use and storage of firearms in a residential environment. MCL § 28.435(3). Ohio,⁹¹Ohio FFLs must post and make available to all firearms purchasers a brochure regarding safe firearms practices. Ohio Rev. Code Ann. §§ 2923.25, 5502.63. and Utah.⁹²Utah dealers must make a firearm safety brochure available to customers at the time of firearm purchase. Utah Code Ann. § 76-10-526(15). 

Among states without dealer licensing regimes, Minnesota has the most extensive security requirements for dealers.⁹³Minn. Stat. § 624.7161(3). Small firearms dealers—those with no more than 50 pistols displayed at any time—must place all pistols in a locked safe or steel gun cabinet or on a locked steel rod or cable after business hours and when the business is unattended.⁹⁴Minn. R. 7504.0200. Larger firearm dealers must harden their building perimeter by securing doorways and windows and installing vehicle-resistant barriers.⁹⁵Minn. R. 7504.0300(A). All dealers, regardless of size, are required to install and maintain an electronic security system.⁹⁶Minn. R. 7504.0400. Exemptions from these requirements are available upon written request provided other security measures are identified as being used instead of the requirements and the Commissioner of Public Safety determines that the suggested measures will provide a similar degree of security. Minn. R. 7504.0600. Local law enforcement in Minnesota is also permitted to inspect firearms dealers to check on the required security measures without advance notice.⁹⁷Minn. R. 7504.0500.

Vermont and Oregon require dealers to maintain records relating to secondhand firearms accepted into inventory.⁹⁸In Oregon, FFLs are required to keep a register of all used firearms accepted into inventory and report the same to local law enforcement on the same day of trade or purchase. Or. Rev. Stat. Ann. § 166.427(1)-(2). In Vermont, retail firearm sellers are required to keep a record of secondhand revolver and pistol purchases only. 13 V.S.A. § 4006. This requirement aids local and federal law enforcement by facilitating the tracing of secondhand guns. Typically, a crime gun trail goes cold after the firearm’s first retail sale to a non-licensee, because that is where recordkeeping ends. By requiring dealers to keep records of used guns they acquire, these states are often able to create an up-to-date paper record for many older weapons.

Forward-thinking states without full licensing systems can still require compliance inspections, transaction reporting, and employee regulation. North Carolina and Wyoming each require retail sellers of firearms to keep sales records open at all times to inspection by law enforcement.⁹⁹C.R.S. § 18-12-402; N.C. Gen. Stat. § 14-406(a); Wyo. Stat. § 6-8-203. Authorities in Michigan¹⁰⁰MCLS §§ 28.422(5), (6); 28.422a(2), (3). and Oregon¹⁰¹Or. Rev. Stat. §§ 166.435(3)(c); 166.412(7); Executive Order No. 16-12; 2022 Ballot Measure 114. are required to keep records of all handgun and all firearm sales, respectively, and handgun dealers in Wisconsin must send all handgun transfer forms to the state Department of Justice within 24 hours.¹⁰²Wis. Adm. Code Jus. § 10.06(1)(c). Virginia does not license gun dealers but does bar dealers from hiring any employee prohibited from having guns; state law requires all prospective employees to pass a criminal background check.¹⁰³Va. Code Ann. § 18.2-308.2:3(A), (B).

IV. Conclusion

State policymakers have far more latitude to regulate gun dealers than ATF does, and state leaders in gun safety are actively using their authority to regulate the gun industry and fight for public safety. Indeed, this work provides a major opportunity for innovators and leaders facing a new federal Administration dead-set on unwinding common-sense protections—and they should make it an imperative to ramp up oversight of gun dealers and the gun sale process.   

While existing state dealer programs vary in their content, the strongest systems clearly delineate which sellers must obtain licenses, they allow frequent inspections, they impose thorough security requirements, and they carefully regulate dealer employees. Prioritizing the work of state and local officials to conduct inspections helps not only with enforcement of dealer laws, but also with state law compliance generally—and prevents diversion of firearms into the illicit market. And because state regulatory powers are not broadly hindered like ATF’s, state programs can incorporate modern crime-solving tools, such as requiring dealers to submit inventories and centralizing sales records for law enforcement purposes.

States continue to innovate, as lawmakers regularly add new features to their dealer laws. Nine states have adopted laws expanding legal accountability for the gun industry, aiming to stop dealers from engaging in business practices that endanger the public. Even as the American public faces a reckoning with the high stakes of unregulated gun sales, dramatic obstacles to major federal progress, and the outsized role our inadequate federal dealer licensing system plays in the broader gun violence crisis, state actors can push forward now—and meet this core public safety challenge head-on.

Appendix

Table 1. State Dealer Licensing Programs

Jurisdiction (# dealer FFLs)104Number of Type 01 (dealer) federal firearms licensees as of January 2025, available at https://www.atf.gov/firearms/docs/undefined/0125-ffl-list-completepdf/download. If multiple license holders have a single address they are treated as a single entity.	Term	Must Obtain If	Security	Employee Reqs	Legal Accountability for Gun Industry	Open to Inspection…	Centralized Records Kept
Federal Law (51,581)	3 years	“Engaged in the business” (EITB) of dealing firearms	N/A	N/A		In the course of criminal investigation + compliance 1x per 12 mos
Alabama (828)	1 year	Sell pistols at retail
California (1,689)	1 year	Sell, lease, or transfer firearms	Physical; Reasonable controls	18+, background check (“BGC”), and training105Training requirements take effect July 1, 2026. California Penal Code § 26920.	Yes	Permissive; Required 1x per 3 years	Yes
Colorado106The requirement takes effect on July 1, 2025. See Colorado House Bill 1353 (2024). (1,367)	3 years	EITB selling any firearm	Secure firearm storage	BGC, training	Yes	Periodic unannounced inspections permitted; sales records open at all times; 10% of dealers must be inspected each year
Connecticut (398)	5 years	Sell >10 firearms per calendar year or who is an FFL	Alarm	18+, BGC, & training		Upon request	Yes
Delaware (119)	1 year (June 1)	EITB selling any pistol or revolver	Reasonable controls	BGC	Yes	In furtherance of open criminal investigation + course of criminal prosecution
D.C. (4)	1 year	EITB selling any firearm	Physical	18+, BGC			Yes
Hawaii (97)	1 year (June 30)	Desiring to EITB of selling firearms	Reasonable controls		Yes	Of inventory firearms only	Yes
Illinois (1,098)	3 years	EITB of selling, leasing, or transferring firearms	Physical & Alarm; Reasonable controls	21+, BGC, training	Yes	Upon demand + not more than 1x per business year w/o good cause
Indiana (1,226)	6 years	Hold self out as buyer and seller of handguns regularly and continuously
Maryland (521)	1 year (June 30)	EITB selling, renting, transferring “regulated firearms”	Physical & Alarm; Reasonable controls		Yes	Required 1x per 2 years + at any time during normal business hours	Yes (handguns and other “regulated firearms”)
Massachusetts (297)	3 years	Selling, renting, or leasing firearms, rifles, shotguns, or machine guns	Physical	BGC		At all times + required 1x per calendar year + valid search warrants	Yes
New Hampshire (352)	3 years	Sell pistols or revolvers at retail
New Jersey (272)	3 years	Retail dealers of firearms + employees	Alarm & Plan; Reasonable controls	18+, BGC	Yes	At all reasonable hours	Yes (handguns)
New York (1,635)	3 years	Dealer in firearms	Alarm & Plan; Reasonable controls	21+, training	Yes	At all reasonable times + 1x per 3 years	Yes (handguns and semiautomatic rifles)
Pennsylvania (2,402)	3 years	Retail dealer of any firearm					Yes (handguns)
Rhode Island (67)	1 year	Retail dealer of any firearm	Secure firearm storage			Monthly
Washington107Certain requirements take effect July 1, 2025. (810)	1 year	Dealer in pistols or any firearm	Physical, Alarm, Reasonable controls	21+, BGC	Yes		Yes (handguns, semiautomatic assault rifles)

Table 2. Regulation of Firearms Dealers in States without Dealer Licensing

State (# dealer FFLs)	Notice to Purchasers	Open to Inspection…	Security	Centralized Records	Other
Florida (2,233)	Yes	Upon request during business hours			Dealers must keep unapproved transfer records for 5 years
Louisiana (882)		As the Dept of Public Safety requires, for records
Maine (382)	Yes	Upon formal written request
Michigan (1,776)	Yes			Yes (handguns)
Minnesota (1,215)	Yes	During normal business hours	Yes		Electronic security system required for all firearms dealers
Nebraska (622)	Yes
North Carolina (1,811)	Yes	Upon request
Ohio (1,834)	Yes
Oregon (1,473)	Yes	With dealer’s consent in course of reasonable inquiry during criminal investigation or authority of a subpoena /search warrant		Yes	Used firearm transaction records reported to local LE
Tennessee (1,145)		During a criminal investigation or under authority of a subpoena or search warrant
Texas (4,597)	Yes
Utah (683)	Yes
Vermont (264)		At all reasonable times			Must keep records of all purchased secondhand revolvers/pistols
Virginia (1,332)		In the course of a bona fide criminal investigation			Employees must not be prohibited from purchasing or transporting firearms
Wisconsin (1,290)	Yes	Normal business hours and as otherwise reasonably requested
Wyoming (505)		At all reasonable times