MA AG Handgun Sales Rules: What Dealers Must Follow

940 CMR 16.00^[1] is a set of consumer protection regulations promulgated by the Attorney General under authority of MGL Chapter 93A. These regulations impose safety and design standards on handguns sold in Massachusetts that operate independently of both federal law and the state Approved Handgun Roster.

The Three-Layer Purchasing System

Massachusetts handgun purchasers face three distinct regulatory layers. The first layer is federal law: any handgun sold through a licensed dealer must comply with ATF import and manufacturing requirements. The second layer is 940 CMR 16.00, which imposes additional consumer protection testing standards. The third layer is the Approved Handgun Roster maintained by the Executive Office of Public Safety and Security (EOPSS) under 501 CMR 7.00^[2]. A handgun must pass all three layers to be lawfully sold by a dealer in the Commonwealth.

Specific Testing Requirements

940 CMR 16.00 requires that handguns sold in Massachusetts meet the following consumer safety standards:

Drop test: The handgun must not discharge when dropped from a specified height onto a hard surface in multiple orientations
Childproofing: The handgun must include a mechanism that effectively precludes an average five-year-old child from operating it. Acceptable methods include a trigger resistance of at least 10 pounds, a firing mechanism too small for a child's hands, or a design requiring multiple motions to fire (940 CMR 16.05(2)). The 10-pound trigger pull is one acceptable childproofing method, not a blanket minimum for all handguns.
Load indicator or magazine safety disconnect: Semiautomatic pistols must include either a load indicator (a device that plainly indicates when a cartridge is in the firing chamber) or a magazine safety disconnect (a mechanism that prevents the firearm from discharging when the magazine is removed) (940 CMR 16.05(3)). The regulation requires one of the two, not both.

Interaction with the Approved Handgun Roster

A handgun may meet all AG consumer protection requirements under 940 CMR 16.00 and still be ineligible for dealer sale if it is not listed on the EOPSS Approved Handgun Roster. Conversely, a rostered handgun could theoretically be removed from compliance if the AG updates the consumer protection standards. In practice, the two systems overlap substantially, but they are legally independent. This dual-layer approach means that Massachusetts dealers carry a narrower selection of handguns than most other states.

Practical Impact

Several popular handgun models fail the AG requirements. The loaded chamber indicator and magazine disconnect requirements eliminate many striker-fired pistols from the market. Manufacturers who wish to sell in Massachusetts must either design compliant variants or accept that their standard models cannot be sold through dealers. Private sales between LTC holders are not subject to 940 CMR 16.00, which creates a secondary market for handguns that meet roster requirements but not AG requirements, or vice versa.

Granata v. Campbell: Constitutional Challenge

The AG handgun sales regulations and the Approved Handgun Roster face an active constitutional challenge in Granata v. Campbell (formerly Granata v. Healey).^[3]

On August 29, 2025, the U.S. District Court for the District of Massachusetts granted summary judgment for the Commonwealth for a second time, holding that the handgun roster and AG regulations do not substantially impair access to arms because the plaintiffs owned multiple handguns and could acquire additional models through lawful channels.^[4]

Plaintiffs -- the Firearms Policy Coalition (FPC) and individual Massachusetts gun owners -- appealed to the First Circuit on September 9, 2025.

On January 28, 2026, the Trump administration's Department of Justice filed an amicus brief siding with the plaintiffs and arguing that the Massachusetts handgun roster violates the Second Amendment under the Bruen framework.^[5] Federal government intervention of this kind is unusual and significantly increases the profile of the case. If the First Circuit reverses the district court, the Approved Handgun Roster and potentially the AG's consumer protection standards could be struck down.

Oral arguments are scheduled for April 4, 2026, before the First Circuit Court of Appeals.^[6] The FPC has drawn parallels between this case and its similar California challenge, Renna v. Bonta, where a federal district court granted a preliminary injunction (now stayed pending appeal) against key provisions of California's handgun roster in March 2023. A favorable First Circuit ruling could effectively dismantle the Massachusetts handgun sales regulatory framework.

940 CMR 16.00:
AG Handgun Sales Regulations