San Francisco Rewrites Its Firearm Procurement Ordinance After Its Own Rules Shrank the Vendor Pool

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• 26 Oct
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October 2026

San Francisco is amending the firearm and ammunition procurement rules it adopted in 2024. The reason is not a change of heart on policy. The City wrote vendor rules that too few dealers could meet, and its own police department had trouble buying the equipment it needs. The amendment (Board File No. 260838) is scheduled for first reading before the full Board of Supervisors on October 27, 2026. 

Any dealer that sells, or wants to sell, to the San Francisco Police Department, Sheriff’s Department, or any other City agency should read on. That includes dealers outside San Francisco and outside California.

The 2024 Ordinance: A Vendor Screen Built on Weak Metrics 

In May 2024, San Francisco added Chapter 21H to its Administrative Code. The City claimed that a “small number of firearms dealers are responsible for a larger percentage of sales of guns that are used in crimes.” Chapter 21H barred the City from buying from any supplier that failed five “minimum qualifications.” Two of those qualifications were:

• No “unresolved” ATF violations in the past five years
• An average of no more than five ATF trace requests per year over five years

The firearms community warned that these metrics measured nothing useful. A trace request does not mean a dealer did anything wrong. And ATF violations range from paperwork errors to serious misconduct.

San Francisco’s City Administrator now agrees. Its September 2026 analysis concedes:

• • On ATF violations, “the City cannot objectively measure whether a supplier’s violations have been resolved.”
  • The violation standard “may inadvertently treat suppliers who are transacting in good faith the same way as those who willfully violate the law.”
  • Trace requests “would then correlate to sales performance but not necessarily to safety adherence.” In practice, the trace test punished dealers for selling more firearms.

The Result: San Francisco Couldn’t Buy Its Own Guns 

San Francisco has had no retail gun store for years, so every City purchase goes to an outside vendor. Once the ordinance took full effect, the City says, it ran into “unexpected challenges in implementation, and a limited supplier pool.” In 3 of the City’s 12 firearm and ammunition purchases since the grace period ended, no supplier qualified, and the City had to waive its own law. 

What the Amendment Changes 

• ATF standard narrowed. Only an ATF warning letter or worse in the past five years disqualifies a supplier, and only if it has not taken “appropriate corrective action.”
• Trace-request test repealed. It is replaced with a new requirement: no fines from the California Department of Justice under Penal Code section 26800 in the past five years.
• More ways around the rules. The City Purchaser could waive Chapter 21H in five situations: sole source, only one qualified bidder, no compliant bidders, adverse impact on services or City finances, and cooperative purchasing.
• Suppliers must still keep written public safety policies, have no more than five thefts in five years, and hold all required licenses.

The Catch: A New DOJ Tripwire 

The amendment is not purely relief. One DOJ fine under section 26800 would bar a dealer from City contracts for five years. Unlike the ATF standard, there is no exception for corrective action. The City notes that DOJ begins assessing tiered fines in October 2026 and is publishing dealer inspection results online. That ties your eligibility for City contracts directly to the outcome of DOJ inspections.

What Dealers Should Do 

1. Check your ATF history. Pull your inspection results from the past five years. For any warning letter or warning conference, document your corrective action.
2. Take DOJ inspections seriously. Respond fully to every DOJ inspection finding. Under this ordinance, a single fine can cost you City business for five years.
3. Put your policies in writing. Keep written policies on straw-purchase prevention, prohibited-person screening, theft prevention, employee training, and cooperation with law enforcement.
4. Read the attestation before you sign it. San Francisco requires bidders to attest under penalty of perjury that they meet every qualification. Confirm each item is accurate first.
5. Watch for copycats. Brady says other cities have followed San Francisco’s lead. Expect the revised version to become the new model. 

The Takeaway

San Francisco built a vendor screen on metrics its own administrators now admit were unverifiable and punished legitimate sales volume. The ordinance did little to stop crime. What it did was make it harder for the City’s own officers to get equipment. Dealers should expect more of these “responsible procurement” ordinances, and they should know that they are hard to administer even for the cities that pass them.