No sir, you will not need an FFL for the new gun they send you. You will have to establish a consumer waiver account which proves your identity and age. This allow Century Arms to send you your original pistol repaired or a replacement directly to you as a non-FFL. Just like if you used warranty at Glock and they sent a replacement. It would come right back to your door, even if it was a completely different gun with a completely different SN. I know this because I've used warranty for firearms in the past and almost sent in my Stingray for the barrel before knowing my barrel's freebore was normal. I had gone through the set-up process with CIA and they explained all that to me. Hope that helps.