S00745 (Chap. 116): Ammunition Dealers Excluded from Firearm Merchant Category Code Requirements

What the Law Does

Chapter 116 of the Laws of 2025 amends New York's merchant category code (MCC) law to exclude dealers of ammunition from the provisions requiring payment card networks to use a dedicated firearm-specific MCC^[1]. New York enacted its MCC tracking law as part of a broader effort to use financial transaction data to identify suspicious bulk purchases of firearms. However, the original statute swept in ammunition-only retailers — businesses that do not sell firearms themselves. S00745 narrows the MCC requirement to actual firearms merchants, removing ammunition dealers from the mandate^[2].

The Assembly companion A00439 was substituted by S00745, which passed both chambers and was signed by Governor Hochul on the same day as the pistol converter and consumer warning bills.

Current Status

Signed into law as Chapter 116 of the Laws of 2025. The law is now in effect.

What to Watch

This is a technical refinement rather than a policy shift. The core MCC requirement for firearms dealers remains intact. Ammunition-only retailers who were uncertain about their compliance obligations under the original law now have clarity that they are excluded. Watch for the broader MCC framework to face continued legal challenges from firearms industry groups who argue the tracking system infringes on consumer privacy.