PC 27535:
California's Firearm Purchase Limit (Three-in-30)

As of April 1, 2026, California Penal Code Section 27535 limits all firearm purchases to three within any 30-day period. This new limit, enacted through AB 1078 ^[4], replaced the one-firearm-per-30-days restriction that the Ninth Circuit struck down in June 2025 (Nguyen v. Bonta). The new limit applies to all firearm types: handguns, rifles, and shotguns alike.

Ninth Circuit Strikes Down the One-in-30 Limit

On June 20, 2025, the United States Court of Appeals for the Ninth Circuit unanimously struck down California's one-firearm-per-30-days law in Nguyen v. Bonta ^[2]. The three-judge panel affirmed the district court's summary judgment, holding that PC 27535 and PC 27540(f) facially violate the Second Amendment. The court found that "possession of multiple firearms and the ability to acquire firearms through purchase without meaningful constraints are protected by the Second Amendment" and that California's law lacked any comparable historical analog under the framework established in NYSRPA v. Bruen (2022) ^[3].

Between June 20, 2025 and March 31, 2026, California had no firearm purchase limit in effect as a result of the Nguyen ruling. AB 1078, signed in 2025 and effective April 1, 2026, restored a three-in-30 firearm purchase limit that is now actively enforced (see AB 1078 section below).

AB 1078: Three-in-30 Replacement (Effective April 1, 2026)

In response to the Nguyen decision, the California legislature enacted AB 1078, signed by Governor Newsom on October 10, 2025 ^[4]. Beginning April 1, 2026, AB 1078 replaces the struck-down one-in-30 limit with a new three-in-30 limit that applies to all firearm types, including handguns, rifles, and shotguns. Under the new Section 27535(a), a person may not make an application to purchase one or more firearms that would result in the purchase of more than three firearms cumulatively within any 30-day period. If the DOJ notifies the dealer that the purchaser's applications would exceed three firearms cumulatively within the preceding 30-day period and did not involve any entity or circumstance exempted under Section 27535(b), the dealer may not complete delivery under Section 27540(f) ^[5].

Exemptions

Section 27535(b) enumerates 14 specific exemptions from the three-in-30 limit ^[4]:

- Law enforcement agencies and agencies authorized to perform law enforcement duties
- State or local correctional facilities
- Licensed private security companies
- Full-time paid peace officers properly identified as such and authorized to, and who do, carry a firearm during the course and scope of employment as peace officers
- Motion picture, television, or video production companies or entertainment or theatrical companies whose production by its nature involves the use of a firearm
- Persons claiming waiting period exemptions under Articles 2, 3, or 4 (Sections 27600 et seq.)
- Private party transactions where the seller is required at the time of the transaction under state law or by court order to relinquish all firearms
- Estate and trust transfers: Private party transactions where the seller is the personal representative of a decedent's estate transferring firearms to heirs or beneficiaries under the will or intestate succession, the holder of the decedent's property transferring firearms under Probate Code Section 13101 to the successor defined in Section 13006 or under Section 13500 to the surviving spouse, or a trustee transferring firearms to trust beneficiaries upon a settlor's death
- Licensed federal firearms collectors (Type 03 FFL) holding a valid California Certificate of Eligibility (COE) issued by the DOJ
- Firearm exchanges where the dealer purchased that firearm from the person seeking the exchange within the 30-day period immediately preceding the exchange or replacement
- Replacement firearms for lost or stolen weapons that were previously reported to law enforcement
- Return of firearms to their owners
- Community colleges certified by the Commission on Peace Officer Standards and Training for law enforcement training programs

CCW-Related Changes in AB 1078

AB 1078 modifies CCW disqualification criteria and requires more thorough background investigations for CCW applicants. Under PC 26185(b)(2), the licensing authority must submit fingerprint images and related information for each renewal notification submitted to the DOJ on or after September 1, 2026. Submission follows issuance of the notice described in PC 26202(d)(1). Under PC 26185(c)(3), the licensing authority may not issue a renewal license until the DOJ confirms eligibility to possess, receive, own, or purchase a firearm.

Current Status Summary

| Period | Rule | Authority |
| Before June 20, 2025 | One firearm per 30 days | PC 27535 / PC 27540(f) |
| June 20, 2025 to March 31, 2026 | No purchase limit | Nguyen v. Bonta |
| April 1, 2026 onward | Three firearms per 30 days | AB 1078 (new PC 27535) |

Enforcement Mechanism

AB 1078 enforces the three-in-30 limit primarily through the DROS system. Under Section 27540(f), delivery is prohibited when the DOJ notifies the dealer that the purchaser's applications would exceed three firearms cumulatively within the preceding 30-day period and did not involve an entity or circumstance exempted under Section 27535(b). Under Penal Code Section 27590, a first violation of Section 27535 is an infraction punishable by a $50 fine, a second violation is an infraction punishable by a $100 fine, and a third or subsequent violation is a misdemeanor. DOJ identifies an application exceeding the purchase limit as a reason for rejecting a DROS application.

CA DOJ Bulletin 2026-DLE-03 (March 24, 2026)

On March 24, 2026, the California Department of Justice issued Information Bulletin 2026-DLE-03 advising CCW licensing authorities about AB 1078's requirements. DOJ's Information Bulletin 2026-DLE-13 superseded that bulletin on August 7, 2026 and provides amended guidance on CCW licensing requirements, including nonresident applications, fingerprints, disqualification determinations, and denial or revocation procedures ^[99].

As of April 12, 2026, the three-in-30 limit under AB 1078 is operative from April 1, 2026, subject to the exemptions in PC 27535(b).