New York requires credit and debit card networks to assign a dedicated merchant category code to firearms dealers, enabling financial institutions to identify firearm purchase transactions. This article covers the MCC requirement, the 2025 chapter amendment, enforcement provisions, and the controversy surrounding the law.
Overview
New York enacted legislation requiring credit and debit card networks to use a dedicated merchant category code (MCC) for firearms dealers, making it one of the first states to mandate the use of the International Organization for Standardization (ISO) firearms-specific MCC.[1] The original law was passed in 2024 as Senate Bill S8479, and Governor Kathy Hochul signed a chapter amendment (S.745/A.439) on April 3, 2025, refining the scope of the requirement.[2]
What Is a Merchant Category Code
A merchant category code is a four-digit number assigned under ISO 8583 standards that classifies a business by the type of goods or services it provides. Before the creation of a firearms-specific MCC, gun stores were typically classified under general "sporting goods" or "miscellaneous retail" codes, making firearm purchases indistinguishable from other retail transactions in financial records.[3] The ISO approved a new firearms-specific MCC in September 2022, and New York's law mandates its adoption within the state.
Requirements for Issuers and Processors
The law imposes obligations on two categories of financial entities:
- Card issuers (banks and credit card companies that issue cards to consumers) must make the firearms MCC available to processors.[1]
- Payment processors (companies that handle transaction processing between merchants and card networks) must assign the firearms MCC to dealers of firearms.[1]
The 2025 chapter amendment (S.745/A.439) refined the original law by removing ammunition dealers from certain provisions, narrowing the MCC assignment requirement to focus on dealers of firearms.[2]
Enforcement
The New York Attorney General is authorized to bring an enforcement action on behalf of the people of the state if violations are not cured within 30 days after written notice.[1] Compliance became enforceable by May 2025.[2]
Purpose and Controversy
Supporters of the law argue that the firearms MCC provides financial institutions with a tool to detect suspicious purchasing patterns that might indicate illegal firearms trafficking or potential mass violence. Senator Zellnor Myrie, the bill's sponsor, stated that the merchant category code gives financial institutions "a critical tool to help detect suspicious activity before it becomes a tragedy."[3]
Critics contend that tracking lawful purchases by category creates a de facto registry of gun buyers and raises privacy and Second Amendment concerns. The Congressional Sportsmen's Foundation and other opponents have argued that the MCC does not distinguish between lawful and unlawful purchases, and that the data could be used to discourage legal firearm purchases or be subject to government surveillance requests.[4] Several other states have passed laws prohibiting the use of the firearms MCC within their borders, creating a patchwork of competing state regulations on the issue.
Practical Impact on Dealers
For firearms dealers in New York, the MCC requirement does not impose a direct operational burden -- the merchant category code is assigned by the payment processor, not by the dealer. However, dealers should confirm with their payment processing provider that the correct MCC has been assigned to their account to avoid potential enforcement actions. Cash transactions and transactions conducted through methods other than credit or debit cards are not affected by this law.[2]