Urgent Alert for California Firearms Dealers & 2A Supporters California DOJ Bureau of Firearms Proposes New Civil Fines Regulations – Your Comments Are Due by 5:00 p.m. on Monday, March 30, 2026

By Jason Davis, Esq. The Davis Law Firm – calgunlawyers.com March 24, 2026

The California Department of Justice Bureau of Firearms has released modified proposed regulations titled “Civil Fines for Firearms Dealers.” These rules would create a new four-level fine schedule, allow inspectors broad discretion to classify violations using vague and subjective factors, and impose fines up to $3,000 per violation on licensed firearms dealers.

While the DOJ claims these regulations simply “implement” Penal Code § 26800, the proposed rules go far beyond what the statute actually authorizes. They create an entirely new graduated penalty system, incorporate an external “violation list” by reference, limit corrective-action protections, and impose a burdensome full Administrative Procedure Act appeal process — all without clear legislative backing.

In plain English: these regulations would turn routine compliance inspections into a potential revenue stream for the state while placing small and family-owned gun shops at serious financial risk. Many of our dealer clients already operate under some of the strictest regulations in the country. These new rules would add another layer of vague, unpredictable, and expensive enforcement that the Legislature never intended.

Why These Proposed Regulations Are Problematic

• They exceed the strict statutory caps and triggers in Penal Code § 26800(b).
• They violate the Administrative Procedure Act (Government Code § 11342.2) by creating rules that are not “consistent with the statute” and not “reasonably necessary.”
• They give Bureau inspectors unchecked discretion through subjective classification factors that are nowhere in the law.
• They will disproportionately harm small businesses and reduce lawful access to firearms for California consumers.

It’s time for you — dealers, shooting ranges, gun owners, and Second Amendment advocates — to make your voice heard.

The public comment period on the modified regulations closes THIS MONDAY at 5:00 p.m. on March 30, 2026. Comments submitted after the deadline will not be considered.

How to Submit Your Opposition Comment (Simple Step-by-Step)

1. Read the key documents (takes only a few minutes): • Main Regulations Page (all documents): https://oag.ca.gov/firearms/regs/cf • Notice of Modifications to Text (March 12, 2026): https://oag.ca.gov/system/files/media/cf-notice-of-proposed-rulemaking-03122026.pdf • Full Text of the Modified Proposed Regulations: https://oag.ca.gov/system/files/media/cf-text-of-proposed-regulations-03122026.pdf
2. Write a short comment (even one paragraph is effective). You can:
   • Simply state that you oppose the regulations as written, explain why they will hurt small businesses or exceed the DOJ’s authority, and request that the DOJ withdraw the proposal and re-notice revised regulations that stay strictly within Penal Code § 26800.
     • Strong Points You Can Include in Your Comment include:
     • The proposed regulations exceed the Department’s statutory authority under Penal Code § 26800(b), which limits fines to a maximum of $1,000 for any breach and $3,000 only under very specific conditions involving written notice and failure to correct or knowing/gross negligence.
     • The four-level fine schedule ($100 / $500 / $1,000 / $3,000) and the use of Form BOF 1050 with subjective classification factors (nature and gravity, potential harm, pattern or practice, etc.) are not authorized by the statute and violate Government Code § 11342.2.
     • The regulations improperly restrict corrective-action safe harbors to only Levels 1 and 2, contrary to the plain language of Penal Code § 26800.
     • The vague and subjective criteria in proposed § 4017(b) will lead to arbitrary and inconsistent enforcement across different inspectors and regions.
     • The mandatory full Administrative Procedure Act hearing for appeals is unnecessarily burdensome for small dealers and goes beyond the simple appeal process contemplated by the statute.
     • These rules will impose significant financial burdens on small and medium-sized firearms businesses, many of which already operate with thin margins under heavy state and federal regulation.
     • The Department has not adequately analyzed the cumulative economic impact on California’s firearms retail industry as required by the APA.
3. Submit your comment by 5:00 p.m. Monday, March 30, 2026Email (fastest):[email protected]Mail (must be postmarked by deadline): A. Mendoza California Department of Justice Bureau of Firearms P.O. Box 160487 Sacramento, CA 95816

Important: In the subject line of your email, write: “Comment re: Civil Fines for Firearms Dealers – Notice File Number Z-2025-0527-01”

Every single comment counts. The DOJ is required to respond to all timely submitted comments in the Final Statement of Reasons. A strong showing of opposition from the firearms community can force meaningful changes — or even cause the Bureau to pull the entire proposal.

Deadline: 5:00 p.m. Monday, March 30, 2026 That is only six days away.

If you own or work at a California firearms dealership, please take five minutes today to submit a comment. If you are a gun owner who values access to lawful firearms retailers, urge your local dealer to comment and share this alert.

The Davis Law Firm is continuing to fight these overreaching regulations on behalf of the industry. If you are a dealer and would like a copy of our full formal opposition letter to use as a template, or if you need help drafting your own comment, simply reply to this email or call our office.

Together we can push back against unnecessary and unlawful regulation.

Stay vigilant and stay armed (legally, of course).

Jason Davis, The Davis Law Firm www.calgunlawyers.com Serving California firearms dealers and gun owners since 2008

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Please share this article widely — forward it to every California FFL you know. The deadline is fast approaching, and silence will be taken as consent.

Questions? Contact us at [email protected] or visit https://calgunlawyers.com.