Few areas of federal gun law have changed direction as often as unfinished frames and receivers, the “80% lowers” and build kits that let people finish a firearm at home. Here is where things stand as of October 2026.
The 2022 rule
In April 2022, ATF finalized a rule, often called the frame-or-receiver rule, that redefined what counts as a firearm frame or receiver. It treated some unfinished frames, receivers and weapon parts kits as firearms when they could be “readily” completed, which brought serial numbers, dealer sales and background checks to products that had been sold like parts.
The Supreme Court’s ruling
In March 2025, in Bondi v. VanDerStok, the Supreme Court ruled 7–2 that the rule was not invalid on its face under the Gun Control Act. That decision answered one narrow question: whether ATF could regulate at least some kits and unfinished frames as firearms. It did not decide whether the rule is valid as applied to specific products, or whether it violates the Second Amendment. Those questions went back to the lower courts.
ATF decided to keep the rule
After a February 2025 executive order directed a review of Biden-era firearms regulations, many expected ATF to rewrite or withdraw the rule. Instead, in April 2026, plaintiffs’ lawyers in the ongoing cases were told that no replacement rule would be issued. The 2022 rule remains in effect.
The August 2026 ruling in Texas
In August 2026, Chief U.S. District Judge Reed O’Connor in the Northern District of Texas ruled for Defense Distributed and the Second Amendment Foundation, finding that two provisions of the rule violate the Second Amendment and are unconstitutionally vague, as applied to the plaintiffs.
The relief is narrow. It protects Defense Distributed, the Second Amendment Foundation and SAF’s members, and only for specific Defense Distributed products. It does not strike down the rule for everyone else. The government may appeal to the Fifth Circuit.
What this means if you build
- Federal law still lets you make a firearm for your own use if you are not prohibited from possessing one, and generally does not require a serial number on a personal build. Making firearms to sell is different and requires a license.
- Buying kits and unfinished frames: under the rule, products that qualify as firearms are sold through licensed dealers with a background check. The Texas ruling only changes that for the protected parties and products.
- State law matters most. A growing number of states ban unserialized firearms, require home-built guns to be serialized or registered, or restrict sales of unfinished frames and receivers. Your state’s law can be far stricter than federal law.
- Prohibited persons cannot build any firearm, under any of these rules.
What to watch
Whether the government appeals the Texas ruling, what the district court does with the remaining VanDerStok claims, and new state laws. We will update this story as the cases move.
This article explains rules and court decisions. It is not legal advice. Check your state’s law before buying, building or selling.
