It is ATF's position that a combination of documents may be used to satisfy the Brady Act's
requirement for an identification document. The prospective transferee must present at least one
valid document that meets the statutory definition of an identification document; i.e., it must bear
the transferee's name and photograph, it must have been issued by a governmental entity, and it
must be of a type intended or commonly accepted for identification purposes. ATF recognizes,
however, that some valid government-issued identification documents do not include the bearer's
current residence address. Such an identification document may be supplemented with another
valid government-issued document that contains the necessary information.

Thus, for example, a licensee may accept a valid driver's license that accurately reflects the
purchaser's name, date of birth, and photograph, along with a vehicle registration issued by the
State indicating the transferee's current address. Licensees should note that if the law of the State
that issued the driver's license provides that the driver's license is invalid due to any reason (i.e.,
the license is expired or is no longer valid due to an unreported change of address), then the
driver's license may not be used for identification purposes under the Brady Act. If a licensee has
reasonable cause to question the validity of an identification document, he or she should not
proceed with the transfer until those questions
can be resolved.

The licensee must record on the Form 4473 the type of identification document(s) presented
by the transferee, including any document number. Examples of documents that may be accepted
to supplement information on a driver's license or other identification document include a vehicle
registration, a recreation identification card, a fishing or hunting license, a voter identification
card, or a tax bill. However, the document in question must be valid and must have been issued
by a government
agency

Supplemental Government Issued Documentation for ATF 4473
by National Gun Trusts August 29, 2025

Can item 26.b. on Form 4473, “Supplemental Government Issued Documentation,” be used to document a transferee’s additional government-issued documentation that establishes the transferee’s full legal name and/or current residence address?

Yes. Item 26.b. on Form 4473 (formerly item 18.b. on the 2016 Form 4473) is used in instances where a single government-issued identification document is not endorsed with the transferee’s full legal name and/or current residence address as recorded in items 9 and 10, respectively, and the transferee presents a combination of valid government-issued documents satisfy the identification document requirement.

An example of this may include an individual who recently changed his/her name due to a change in marital status. ATF Ruling 2001-5 states that federal firearms licensees (FFLs) may accept a combination of valid government-issued documents to satisfy the identification document requirements of the Brady Act. The required valid government-issued photo identification document bearing the name, photograph, and date of birth of the transferee may be supplemented by another valid, government-issued document showing the transferee's residence address or full legal name.

These supplemental documents must be issued by a government entity. Documents that will typically meet these requirements include a tax bill, vehicle registration, and voter identification card.

Documents issued by private companies or individuals (rental documents, leases, cable bills, phone bills, credit card bills, bank documents, etc.) may not be used as supplemental identification documents for the purchase or acquisition of a firearm.

[18 U.S.C. 922(t)(1)(C), 27 CFR 478.102(a)(3) and 478.124(c)(3)(i)]

Source:

“Bureau of Alcohol, Tobacco, Firearms and Explosives.” Can Item 26.b. on Form 4473, “Supplemental Government Issued Documentation,” Be Used to Document a Transferee’s Additional Government-Issued Documentation That Establishes the Transferee’s Full Legal Name and/or Current Residence Address? | Bureau of Alcohol, Tobacco, Firearms and Explosives, www.atf.gov/firearms/qa/can-item-26b-form-4473-%E2%80%9Csupplemental-government-issued-documentation%E2%80%9D-be-used-document. Accessed 27 Aug. 2025.