Filing a National Firearms Act (NFA) application with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)? Form 1, Form 4, Form 5 and Form 5320.23 all call for a 2 × 2 in photograph. Here is what ATF states about the photo and how to submit it through eForms or on paper.
The ATF Form 1 photo requirements and the Form 4 photo requirements come from ATF’s regulations: 27 CFR 479.63 for Form 1 (application to make and register) and 27 CFR 479.85 for Form 4 (application to transfer and register) and Form 5320.23. Both ask for a 2 × 2 in photograph clearly showing a full front view of your features with your head bare, with the distance from the top of your head to the point of your chin approximately 1¼ in.
| Requirement | What ATF states |
|---|
| Size | 2 × 2 in |
| Pose | Full front view of your features, head bare |
| Head size | About 1¼ in from the top of the head to the point of the chin |
| How recent | Within six months (current Form 4); within 1 year (the regulation and the older Form 1 and Form 5320.23 editions) |
| Head covering | Older paper forms: full face view, without a hat or head covering that obscures the hair or hairline |
| eForms file | JPG, JPEG or PNG, up to 3 MB |
| Not stated by ATF | Background color, glasses, expression, pixel size |
The current Form 4, revised in December 2025, asks for a photo taken within six months before the application, while the regulation and the older Form 1 and Form 5320.23 editions say within 1 year. A photo taken within the last six months meets both, whichever form you file.
ATF eForms. According to ATF, only two percent of NFA applicants currently submit paper documents; most file online. In eForms you attach a digital photo in the Photo function, and the upload takes JPG, JPEG or PNG files up to 3 MB. ATF does not state a pixel size. The digital file from IDPhotoBy is a JPEG under the 3 MB limit.
Paper forms. The regulation says to securely attach the photograph to each copy of Form 1 or Form 4, and Form 4 goes to ATF in two copies. The older paper forms have a photo box and add two instructions: tape the sides of the photo instead of stapling it, and print your full name and the last 4 digits of your Social Security number on the back.
Fingerprints. Fingerprints are a separate requirement: FBI Form FD-258 cards or an electronic fingerprint file in eForms. IDPhotoBy prepares the photo only.
When a trust or other legal entity applies, each responsible person completes Form 5320.23, the NFA Responsible Person Questionnaire, with their own 2 × 2 in photograph. The questionnaire is not required when the applicant is an individual. On paper, the photo goes on the ATF copy only. In eForms, the applicant attaches each responsible person’s photograph together with a scanned, signed questionnaire, so make a separate photo for each person.
Just as important is what the NFA photo requirements leave out. ATF does not state a background color, a rule on glasses, an expression rule or a pixel size for this photo, so we don’t present any of those as ATF rules. ATF’s revision of Form 4 also allows cell phone photographs, and ATF says electronic filers can already submit a self-generated digital photo. IDPhotoBy crops and sizes the photo you upload; it does not retouch or beautify your face. No online tool can promise approval: the decision on your application is ATF’s.
On July 6, 2026, ATF proposed letting applicants, both individuals and responsible persons, send a copy of a photo ID instead. The 2 × 2 in photograph would remain an option, and ATF could still ask for one where necessary. The proposal has a comment deadline of October 5, 2026, and was not in force as of October 1, 2026, so plan on the 2 × 2 in photo for now.
For other U.S. documents, see all U.S. document photos. ATF’s photo rule for Form 4 and Form 5320.23 is published in 27 CFR 479.85, and most applications go through ATF eForms. Check the official application portal before submitting.