The 4473 Draft Is Public. The Comment Window Is Open.
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The comment window is open until July 7. Here's how to use it.
When I wrote about the proposed Form 4473 changes last month, the rule was still in proposal stage — real enough to be alarmed by, not final enough to act on. That changed on May 8.
The ATF published the draft revised form as a formal 60-day Paperwork Reduction Act notice. The non-binary option is gone. The instructions now read: select the sex you were assigned at birth. Male or Female — no third option, no guidance for what to do if your documents say otherwise.
The Catch-22 I described before hasn't changed — it's just closer. If your ID reflects your gender identity and not your birth sex, you're already in the gap the form creates. There's no instruction for how to resolve the conflict — you're left to guess, and guessing wrong on a federal firearms form carries federal consequences.
The difference now: the 60-day public comment period is open until July 7, 2026.
This is the formal rulemaking process. Comments go into the record. They're not a petition — they don't automatically stop anything — but they are the legal mechanism that exists right now, and skipping it means the record shows no opposition.
How to submit
Email FIPB@atf.gov with the subject line referencing OMB Control Number 1140-0020 and Federal Register Document No. 2026-09183.
A comment that describes one specific, real situation — your ID situation, your counter situation, your customer situation — does more than a hundred identical emails. The record is built from distinct testimony. Restated form letters get counted once.
Below are four guided starting points based on different situations. Use whichever fits, rewrite it in your own words, and add any details that are true for you. The more specific, the better.
If you're trans or nonbinary and this affects how you'd answer the question
Describe the actual situation you'd be in at the counter. Do your IDs match? Would you have to choose between answering with your birth sex and answering consistently with your legal documents? What does that feel like in practice — not in the abstract, but at a gun counter, with someone watching? The comment doesn't need to be emotional. It needs to be true and specific.
Example opening: "I am a transgender [man/woman/person] and I am a legal gun owner. Under the proposed revision, I would be required to list a sex that does not match my [driver's license / state ID / passport]. There is no instruction on the form for how to resolve that conflict. This is not a theoretical problem — it is the situation I would face the next time I purchase a firearm."
If you're intersex
The form offers two options based on a binary that doesn't describe your biology. That's worth saying plainly. If you've ever had to navigate legal sex designations that felt arbitrary or inconsistent with your actual biology, that's directly relevant.
Example opening: "I am intersex. The proposed form requires me to select a biological sex — male or female — as though that designation is unambiguous for everyone. It is not unambiguous for me. The sex I was assigned at birth was a medical decision made without my input, and it does not reflect the complexity of my actual biology. This form provides no mechanism for that reality."
If you're not personally affected but someone you know is
You don't need to be trans to submit a comment. If you're a parent, partner, friend, or someone who works with trans gun owners — describe what you've seen, and name your relationship to it. Observed impact is still impact.
Example opening: "I am submitting this comment on behalf of people in my community who are directly affected by this proposed change and who may not feel safe submitting comments under their own names. I have [a family member / close friends / community members] who are transgender gun owners. The proposed revision would place them in a position where there is no legally safe answer available to them on a federal form."
If you're an FFL dealer or work at a gun counter
You're the one who has to administer this form. If the proposed change creates ambiguity or puts you in a difficult position when a buyer's ID doesn't match what the form requires, that's operational feedback the ATF actually needs to hear.
Example opening: "I am a Federal Firearms Licensee and I administer Form 4473 as part of my regular business operations. The proposed revision creates a situation I do not know how to handle: a buyer whose legal identification lists a sex that differs from their sex assigned at birth. The form provides no guidance for this scenario. I need clarification on what I am required to do, and what liability I carry, when a buyer's documents and the form's instructions are in conflict."
Comments are due by midnight, July 7, 2026.
Email: FIPB@atf.gov
Subject line: OMB Control Number 1140-0020 / Federal Register Document No. 2026-09183
The original post breaking down what's proposed, what's real, and what hasn't changed yet is here.