Firearms - Guides - Importation & Verification of Firearms, Ammunition and Implements of War - Record Keeping Requirements

General Information

Record Keeping Requirements
Records of Importation (27 CFR § 478.122)

Licensed firearms importers are required to maintain records of acquisition and disposition according to 27 CFR § 478.122. This record takes the form of a bound book in which entries are written; however, a licensee may apply for a variance to maintain the required records on a computer by filing a request under the provision of 27 CFR § 478.22.

Computerized Acquisition and Disposition Records

Before a Federal firearms licensee can use a specific computer program for record keeping in lieu of the required bound book format, it is necessary to get prior approval from ATF. The Bureau does not issue blanket approvals for commercially available software programs nor does it endorse any particular product.

All requests for a computerized recordkeeping variance must be sent to the Director of Industry Operations in your area. These procedures are outlined in 27 CFR § 478.125(h) in the ATF P 5300.4 — Federal Firearms Regulations Reference Guide – 2014 Edition (Revised 3-7-15).

See the document below to access and view the Requesting procedures to have ATF review a computerized recordkeeping system for approval in your operation:

Importers Firearms Acquisition Record

A licensed importer is required to record the type, model, caliber or gauge, manufacturer, serial number, country of manufacture and the date of importation or acquisition, of each firearm imported or otherwise acquired within 15 days of the importation or acquisition.

Importers Firearms Disposition Record

A record of firearms disposed of by a licensed importer, to another licensee and a separate record of armor piercing ammunition dispositions to governmental entities for exportation, testing, or experimentation authorized under the provisions of 27 CFR § 478.149 shall be maintained by the licensed importer on the licensed premises.

In reference to firearms, the record shall show the quantity, type, manufacturer, country of manufacture, caliber or gauge, model, serial number, name and license number of licensee to whom the firearms was transferred, and the date of the transaction. For armor piercing ammunition, the record shall show the date, manufacturer, caliber or gauge, the quantity of projectiles, and the name and address of the purchaser.

Information required by 27 CFR § 478.122 must be entered in the proper record book no later than the seventh day following the date of the transaction.

The record of acquisition and disposition should mirror the following format:

Importer's Firearms Disposition Records
Quantity Type Manufacturer Country of Manufacture Caliber or Gauge Model Serial No. Name & License No. of Transferee Date of Transaction
Importer’s Armor Piercing Ammunition Disposition Records



Caliber or Gauge

Quantity of Projectiles

Name & License No. of Purchaser


Per 27 CFR § 478.122(d), each licensed importer shall maintain separate records of the sales or dispositions made of firearms to non-licensees. Such records shall be maintained in the form and manner as prescribed by 27 CFR § 478.124 and § 478.125 in regard to firearms transaction records and records of acquisition and disposition of firearms. This includes the completion of ATF F 4473 (5300.9) and applicable background checks. Importers are required to maintain permanent records of importation, manufacture, or other acquisition of firearms. Unlike records of sale or other disposition, records of acquisitions may not be discarded after 20 years.

  • All records pertaining to the sale or disposition of firearms after December 15, 1968 and Forms 6 and 6A are required to be maintained for 20 years. 27 CFR § 478.122(d).
  • Firearms that are returned to foreign sellers need to be recorded in the licensee’s disposition record. An export license from the State Department’s Office of Defense Trade Controls or the Commerce Department (sporting shotguns only) may be needed. A copy of any export licenses should be maintained with the required records.
  • Importers requiring and disposing of NFA weapons must complete and submit all required transfer forms, including Form 5320.2, Form 5320.3, Form 5320.5, and Form 5320.9. Questions regarding NFA transfers should be directed to the NFA Branch.

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Last Reviewed April 9, 2020