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Vicky Downs
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The Tower
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The Tower

On 3 June, we broke the news that the much‑anticipated National Firearms Licensing Management System (NFLMS or Flimsy) procurement process had moved to its next stage, with Palantir announced as the successful supplier.

This development came as a surprise not only to major shooting organisations, but to several police forces as well. That absence of communication is disappointing, though perhaps not unexpected. It undermines the principle of collaborative reform that should underpin any national transition affecting lawful shooting.

The Tower exists to document, analyse, and support the shooting community as questions and concerns inevitably arise around this potentially controversial contract award. It is a free resource for everyone in the shooting community – trade, clubs and individual certificate holders – offering clear, evidence‑based insight into what is happening and why it matters.

Our work here is funded entirely by membership, yet we believe it is too valuable to hide behind a paywall. If you value our efforts and want to help keep this resource open and accessible to all, please consider joining us. Membership packages start at £12 for the entire year and your support ensures we can continue providing the clarity and accountability our community deserves.

https://firearmslicensing.net/register/

What is NFLMS?

The National Firearms Licensing Management System (NFLMS) – often referred to as Flimsy – is the central database used by police forces across England and Wales to manage some aspects of firearms and/or shotgun licensing. It underpins the licensing process: applications, renewals, revocations and the recording of certificate holders and their firearms.

NFLMS was implemented circa 2006 and despite its critical role, the system is widely regarded as outdated, fragmented and increasingly unfit for purpose. Its limitations, combined with rising demand and scrutiny, prompted the Home Office to pursue a full replacement through a national procurement programme.

What NFLMS doesn’t do?

NFLMS is not a case‑management system. This means police forces must operate at least two systems in parallel to complete the firearms licensing process.

The result?

  • Inefficiencies
  • Duplication of effort
  • Variations in process between forces
  • Delays and inconsistencies experienced by certificate holders

A system capable of combining both the database and case‑management functions would represent a significant operational improvement for policing.

What information does it hold?

Local practices vary but this is what Statutory Guidance to Police says:

5.1 Chief officers should record the following on the relevant national firearms licensing database:

  • (i)  the nominal details of all applicants and certificate holders and the status of those certificates including firearms possessed;
  • (ii)  any information relevant to the suitability of the applicant, including intelligence and allegations or concerns raised even if not proven;
  • (iii)  the reasons for each grant/renewal decision, whether approval or refusal;
  • (iv)  details of any review of suitability, including the reasons for the review and its outcome;
  • (v)  details of any appeal, including the outcome;
  • (vi)  details of storage of firearms;
  • (vii)  dates of visits and inspections, and types of inspection (including RFD inspections);
  • (viii)  whether a medical marker has been added by the GP (if known);
  • (ix)  whether the certificate holder is an officer, former officer, or police staff or former police staff (if known);
  • (x)  the outcome of any checks relating to periods of residence abroad;
  • (xi)  details of the applicant’s GP and referees; and
  • (xii)  any other information the chief officer considers useful.

5.2 Records should not be deleted due to the applicant moving to another force area.

5.3 Records of applicants and certificate holders on the relevant national firearms licensing database should be kept up to date at all times, so that accurate information on possession of firearms is available to local police via the PNC.

5.4 For RFDs, in the event of a variation of a condition, removal from the register or surrender of a dealer’s certificate of registration, an appropriate notification should be sent to all other forces.

In short: NFLMS holds a significant volume of sensitive personal and suitability‑related data and its replacement will have major implications for both policing and the shooting community.

The Replacement Process

The procurement for the NFLMS replacement first surfaced in late 2023, when the Home Office issued early market engagement material outlining its intention to replace the ageing system. Initial documentation described a platform capable of handling national firearms licensing data, integrating with policing systems and supporting improved decision‑making. However, after this early activity, the programme appeared to stall with little visible progress through 2024.

Momentum returned in 2025, when the Home Office reinvigorated the project and issued a more formal Invitation to Tender (ITT). This specification set out a broad ambition: a modern, secure, cloud‑based platform capable of managing national firearms licensing data, supporting operational workflows and enabling improved analytics. The ITT emphasised interoperability with existing policing systems, strong data‑governance controls and the ability to scale nationally across all forces.

What stands out is the limited transparency surrounding the process. Shooting organisations were not consulted and several police forces reported being only partially briefed, informed late in the cycle or not at all. Despite the system’s direct impact on every certificate holder and every licensing team in England and Wales, the communication appears to have been limited.

The announcement of Palantir as the preferred supplier marks a significant shift toward a high‑end, data‑driven platform. While this may offer technical advantages, it also raises important questions about:

  • long‑term governance and data stewardship
  • integration with force‑level case‑management systems
  • cost and contract structure
  • the degree of centralisation the Home Office intends
  • how the system will support -or reshape- local licensing practice

These issues will form a core part of The Tower’s ongoing analysis as more information becomes available.

For more detail see https://pds.police.uk/welcome/about-us/our-expertise/national-firearms-licensing-management-system-replacement/

Why does it matter?

The replacement of NFLMS is not a routine IT upgrade – it is a fundamental redesign of the national infrastructure that governs firearms licensing. The system chosen, the data it holds and the way it integrates with policing will shape how certificate holders are assessed and managed for many years.

But this is not a moment for panic. Nothing changes overnight and no new system can be switched on without extensive testing, governance, and scrutiny. What matters now is understanding the direction of travel: how the new platform may affect processing times, consistency between forces, data handling and the balance between national oversight and local discretion. When a project of this scale progresses with limited consultation, the shooting community is right to ask questions – calmly, constructively, and with an eye on ensuring that any new system improves public safety without eroding fairness, proportionality, or trust.

Palantir in the News

Palantir’s expanding role across UK public services has attracted sustained scrutiny from mainstream media, parliamentary committees, and civil society groups. The reporting below provides wider context for understanding why the NFLMS award is likely to draw attention.

Sky News: Parliamentary committee brands Palantir’s role “unacceptable”

Sky News reports that MPs have warned the UK is becoming over‑reliant on Palantir, calling this an “unacceptable point of weakness” that could leave citizens’ data “at the mercy” of foreign actors. The committee highlighted Palantir’s involvement with the NHS and Financial Conduct Authority, raising concerns about privacy, ethics, and dependency on a small number of US‑based providers.

https://news.sky.com/story/palantirs-role-in-uk-public-services-branded-unacceptable-by-committee-report-13154127

Sky News: Doctors and campaigners urge NHS hospitals to reject Palantir platform

A separate Sky News report describes how doctors, analysts, and human‑rights groups have urged NHS bodies to reconsider adopting Palantir’s £330m Federated Data Platform. Critics argue the rollout is “not going to plan”, with concerns about privacy, spiralling implementation costs, and the displacement of trusted local data solutions.

https://news.sky.com/story/nhs-hospitals-urged-to-reject-330m-data-platform-part-owned-by-trump-ally-13519263

The Guardian: Officials warn Palantir’s reputation could hinder NHS rollout

The Guardian reveals that internal briefings to ministers warned Palantir’s reputation — including its work with ICE and the Israeli military — could undermine public trust and hinder the rollout of the NHS data platform. MPs have described the company as “ghastly” and “highly questionable”, calling for greater transparency around its public‑sector contracts.

https://www.theguardian.com/society/2026/feb/12/nhs-deal-with-ai-firm-palantir-called-into-question-after-officials-concerns-revealed

LBC: Why Palantir is controversial

LBC summarises the core concerns: Palantir’s widening reach across UK public services, its origins in US security and immigration operations, and ethical questions surrounding its work with the Israeli military. MPs warn reliance on the company creates a “clear vulnerability” for the UK.

https://www.lbc.co.uk/article/what-palantir-uk-why-controversial-5Hjdb68_2/

Business Chief: Public backlash over £600m UK government contracts

Business Chief reports that more than 229,000 people have signed petitions calling for the government to terminate all Palantir contracts, citing concerns about data handling, surveillance, and the company’s work with ICE and the Israeli military. Palantir currently holds around £600m in UK public‑sector contracts across the NHS, MoD, and policing.

https://businesschief.com/news/palantir-faces-backlash-over-600m-uk-government-contracts

Key Points – Next Steps

For certificate holders, the most important message is that nothing changes immediately. The procurement announcement does not alter the law, the licensing process, or your current certificate conditions. Any new system will take years to design, build, test, and implement and will require extensive governance, scrutiny and operational validation before it affects anyone in practice.

What matters now is simply staying informed. Certificate holders should be aware that a more centralised, data‑driven system is being developed and that this may eventually influence how information is shared between forces, how suitability is assessed and how renewals are processed.

But this is a long‑term transition, not an overnight shift. The best next step is to follow developments calmly, understand the direction of travel and ensure your own records, medical arrangements and contact details remain accurate and up to date. The Tower will continue to monitor the process and provide clear, factual updates as more detail emerges.

Open Letter to Home Office and Police

The following letter has been shared with Police Digital Services, the National Police Chief’s Council and the Home Office, with key shooting organisations copied in for transparency.

As the only UK organisation focused exclusively on firearms licensing, FirearmsLicensing.Net is using this space to ensure the community can see the same information being provided to decision‑makers.

The aim is simple: to support clear, consistent communication during the transition to the new NFLMS system and to help reduce uncertainty across the sector.

Sector Comms NFLMS2
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City of London Police
City of London Police 600 600 Vicky Downs

Introduction

The following update has been provided directly by the City of London Police Firearms and Explosives Licensing Unit (FELU).

It is published here exactly as supplied, in line with our commitment to support clear communication between police forces and the certificate‑holding community.

This initiative is designed to strengthen collaboration, improve understanding of local and national developments and help reduce avoidable delays or misunderstandings in the licensing process.

Content is hosted within our free information section, ensuring there is no commercial benefit and maintaining full transparency.

If any material appears likely to cause difficulty or confusion for certificate holders, we will always raise this with the Force first for discussion.

Firearms and Explosives Licensing Unit (FELU)

Newsletter – June 2026

Dear Reader,

You are receiving this Newsletter as a you have been identified as a key stakeholder in relation to management and processing of Firearms and Explosives Licensing by the City of London Police.

This Newsletter is the first of its kind for the City of London Police and is being distributed with the intention of providing key information to stakeholders, as well as to build and maintain relationships with all parties who have a vested interest in Firearms and Explosives Licensing matters.

The City of London Police Firearms and Explosives Licensing Unit is committed to safeguarding the public whilst providing high levels of customer service for our Certificate Holders.

Local Updates

 

A full review into the working practices and policies of the City of London Police Firearms and Explosives Licensing Unit was undertaken in 2025. As a result, significant amendments have been made to local working practices, in line with updates made to the Statutory Guidance for Chief Officers of Police, in relation to Firearms Licensing.

 

National Updates

Lead Ban

The Government has confirmed when restrictions on the sale and use of lead ammunition will come into force in England, Wales and Scotland, as listed below:

Shotgun Cartridges:

The use and sale of lead shot for live quarry shooting will be banned from 1 April 2029.
The use and sale of lead shot for indoor and outdoor recreational target shooting will also be banned from 1 April 2029, with exemptions for elite athletes.

Rifle Ammunition:

The use and sale of lead bullets for live quarry shooting in calibres 6.17 millimetres and above will be banned from 1 April 2029.
Small calibre rifles below 6.17 millimetres, including commonly used pest control calibres, are not affected by the restrictions.
The use of lead bullets for outdoor target shooting will be restricted from 1 April 2028, except at ranges that meet the required risk management measures.

Airguns:

There are no restrictions on the sale or use of lead airgun pellets for either target shooting or live quarry shooting.
The City of London Police FELU understand that these restrictions may impact certain Firearm and Shotgun Certificate Holders. We strongly advise you to speak with a gunsmith to ensure that your shotgun is appropriately proofed for certain non-lead ammunition, and to explore what alternatives are available.

In addition, we understand that certain calibres of firearm may be less suited to non-lead ammunition at this stage, as such we advise you to seek advice on this matter. However, if you do wish to submit a variation we will aim to process this as efficiently as possible.

Please don’t forget to check-zero your rifle if you are changing ammunition type.

Sound Moderators

The Home Office have announced amendments to the Crime and Policing Bill which removes Sound Moderators from their current classification as Section 1 Firearms. This would mean that Sound Moderators would not need to be individually authorised, and a variation would not be needed to add them. However, a new offence of possessing a sound moderator without a Firearm or Shotgun Certificate will be created. This proposed legislation is not expected to effect Sound Moderators used for low powered air rifles and pistols.

In the meantime, Sound Moderators remain classed as Section 1 Firearms.

Consultation into Firearms Licensing

The Home Office is due to publish a consultation into Firearms Licensing which was originally expected to be published in late 2025 but at the time of writing is yet to be published.

This matter has recently been debated in Parliament following a public petition, opposing proposals to merge Section 1 and Section 2 licensing.

The City of London Police FELU does not have any further information regarding this consultation at this stage.

Fees

The Home Office have announced that Firearms Licensing Fees are set to be increased by 3% as of 04th June 2026.

The City of London Police FELU are committed to providing Certificate Holders and Applicants with the high level of customer service.

Upcoming Events  

The City of London Police FELU are not due to attend any specific events within the next three months.

Feedback

If you have any feedback in relation to this Newsletter or you have suggestions for information that you would like to see included then please contact the Firearms and Explosives Licensing Unit via email.

If you have any questions or concerns in relation to Firearms and Explosives Licensing matters, then please contact the Firearms and Explosives Licensing Unit via email.

Our email address is: firearmsexplosiveslicensing@cityoflondon.police.uk

Thank you,

Firearms and Explosives Licensing Unit
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Behind the Numbers 3
Behind the Numbers 3 2560 1708 Vicky Downs

Introduction

Firearms licensing performance doesn’t grab your attention but it quietly shapes the stability of the entire shooting sector. When forces fall behind, clubs feel the pressure, certificate holders lose confidence and organisations end up spending more time dealing with licensing problems than developing the sport.

It isn’t glamorous, but it matters and it matters more now than ever.

For years, the data behind firearms licensing has been difficult to access, inconsistently presented and in some cases fundamentally flawed. We’ve challenged the National Police Chief’s Council (NPCC) on these issues before, particularly around the way forces report timeliness but little has changed. The published figures still allow forces to appear more efficient than they really are – for example by delaying the point at which applications are entered onto NFLMS or by marking certificates as granted before they are actually issued. These practices distort the picture and make it harder for the shooting community to understand what is really happening.

And yet, despite these flaws, this is the first time that this level of information has been made publicly available. That alone is a step in the right direction. Transparency in firearms licensing has never been more important and even imperfect data can reveal meaningful patterns when analysed properly.

This article looks beyond the headline SLA figures and focuses instead on the measures that genuinely reflect operational performance: true productivity, revocation and refusal activity, and temporary permit usage. When viewed over time, these indicators show a system that is becoming increasingly uneven with some forces performing exceptionally well and others struggling with delays, backlogs and inconsistent decision‑making.

Understanding these trends isn’t just an administrative exercise. It’s about fairness, confidence and the long‑term health of shooting in the UK.

And that’s why it’s worth paying attention.

If you’re hungry for more detail check out:

Behind the Numbers 1 and 2 via these links –

Behind the Numbers

Behind the Numbers 2

At a Glance

In the last 18 months:

Certificate Holders – We started with 506,343 and at last count now have 476,079. That’s a loss of 30,264.

Temporary Permits – We started with 1,501 and at last count now have 3,092. That’s double and shows the strain the system is under.

Across Q4 25/26:

  • The same forces repeatedly appear in the top group across productivity and low permit usage (Cheshire, Lincolnshire, Cumbria, Derbyshire, Nottinghamshire).
  • The same forces repeatedly appear in the bottom group (Bedfordshire, Cambridgeshire, Hertfordshire, Humberside, Surrey, Sussex, West Yorkshire).
  • Forces who show high usage of their refusal and revocation powers (Devon & Cornwall, West Mercia, South Yorkshire) remain consistently high.
  • Temporary permit usage is the clearest indicator of stress and the Q4 data reinforces that pattern.

What all the numbers tell us is that UK firearms licensing is not a single system; it’s a patchwork of very different local realities. Some forces are delivering consistent, high‑quality work, while others are struggling with delays, backlogs, and heavy reliance on temporary permits.

True productivity varies dramatically and the published service level agreement (SLA) figures often mask deeper workflow problems.

Revocations and refusals remain low nationally, but intervention rates differ sharply between forces, reflecting local policy rather than national direction.

Overall, the system is stable in parts, fragile in others and increasingly defined by where you live rather than by national standards.

Q4 2025/26 – Where does your Force rank?

The following image is not perfect but it is designed to enable the average interested shooter to look at their Force and see what their performance is like in comparison to others.

Each Force is ranked from 1 to 43.

For revocation and refusal.

Ranking 1 is the area you are least likely to be refused / revoked.

Ranking 43 is the area where you are most likely to be refused / revoked.

Rank 43 is owned by South Yorkshire where you are almost 18 times more likely to be refused or revoked than if you lived in Staffordshire.

High rates do not necessarily indicate poor practice but it should ask the question – Is the shooting community of South Yorkshire really that different to the shooting community of Staffordshire?

For productivity

Ranking 1 is the Force that completes the most applications per year (Relative to their total number of certificate holders)

Ranking 43 is the Force that completes the least.

As a Force South Wales is almost twice as efficient as Durham.

References:

To see the data in full please visit –

https://www.npcc.police.uk/publications/All-publications/

and look in “Operations Coordination Committee”

Temporary Permits – Change Over Time

Transparency is not a luxury. It’s a duty.
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Sec 1 Shotguns West Mercia
Sec 1 Shotguns West Mercia 2560 1859 Vicky Downs

Introduction

Across England and Wales, Section 1 shotguns are a normal, lawful part of shooting, pest control, gamekeeping and practical disciplines. They are authorised routinely by most police forces where the applicant demonstrates good reason and meets the expected security standards.

However, in recent months a number of certificate holders and applicants in West Mercia have reported difficulties obtaining authorisation for Section 1 shotguns.

Some have been told that:

  • Section 1 shotguns are “not normally authorised”,
  • A Section 2 shotgun is “sufficient”, or
  • An applicant must demonstrate an “exceptional need”.

These positions do not reflect the Firearms Act, the Home Office Guide, or the Statutory Guidance to Chief Officers. West Mercia have now confirmed that they will review any decisions where applicants feel aggrieved, and this article explains how to do that effectively.

Email Template

To support applicants, FirearmsLicensing.net has produced:

  • A Template Review Letter that anyone can use when asking West Mercia to reconsider a decision
  • A Position Statement setting out the correct legal and guidance framework

The template is free for anyone to use but the position statement is for our membership only and accessible with any of our membership offers which start at £12 for a whole year’s access and benefits.

Why this matters?

Section 1 shotguns are a normal part of lawful shooting and land management.

The licensing system must remain:

  • Fair
  • Transparent
  • Evidence‑based
  • Consistent with national guidance

Where applicants encounter decisions that appear to apply a higher threshold than the law requires, it is entirely appropriate to request a review.

Our aim is simple:  

To support responsible certificate holders in navigating the system confidently, lawfully and with the correct information.

West Mercia’s Email address is – firearmslicensing.cjsd.hq@westmercia.pnn.police.uk

Or you can use the online form found here –

https://www.westmercia.police.uk/ar/applyregister/fao/adf/v1/contact-fal/general-enquiry/?tid=408566&lid=&cid=&rid=5&stepid=1

Template Email

Template Letter – Request for Review of Section 1 Shotgun Decision

(For public use – suitable for any applicant in West Mercia)

[Your Name]

[Your Address]

[Certificate Number – if applicable]

[Date]

Firearms Licensing Unit

West Mercia Police

Dear Sir or Madam,

Re: Request for Review of Decision Relating to Section 1 Shotgun

I am writing to request a review of the recent decision concerning my application/renewal/variation* for a Section 1 shotgun. I understand that West Mercia Police have invited applicants who feel aggrieved by such decisions to seek a review, and I am grateful for the opportunity to do so.

I remain fully cooperative and willing to provide any further reasonable information required.

1. Basis for requesting a review

I am concerned that the decision may not fully reflect the statutory framework set out in:

  • The Firearms Act 1968,
  •  The Home Office Guide on Firearms Licensing Law, and
  • The Statutory Guidance to Chief Officers.

These documents make clear that:

  • The legal test for authorising a Section 1 shotgun is good reason,
  • Blanket policies are not permitted, and
  • All decisions must be made on a case‑by‑case basis, considering the specific firearm, purpose and circumstances.

I respectfully request that my application be reconsidered in light of these principles.

2. My stated good reason

My application sets out a clear, evidenced and continuing good reason for the Section 1 shotgun, namely;

[Insert your intended use here and why this is supported by a Sec 1 shotgun – e.g., pest control requiring rapid follow‑up shots,]

This is a recognised, lawful purpose and is consistent with national practice across England and Wales.

3. Security arrangements

My security arrangements meet or exceed the standards set out in the Home Office Guide and Statutory Guidance.

4. Crime and risk considerations

National crime data shows no evidence that legally‑held Section 1 shotguns are used in crime with any measurable frequency. Shotgun offences overwhelmingly involve illicit or shortened shotguns, not firearms held on certificate.

Crime data provides no evidence base for treating Section 1 shotguns as requiring a higher threshold of justification.

5. Right of appeal

If, following review, the decision is maintained, I would be grateful for:

  • A clear written explanation of the reasons for refusal, and
  • Confirmation of my statutory right of appeal under the Firearms Act 1968.

This ensures transparency and allows me to consider my next steps appropriately.

Closing

I appreciate your time and consideration. My intention is simply to comply with the law, meet the statutory tests, and continue my shooting activities safely and responsibly. I remain fully willing to provide any further information required.

Yours faithfully,

[Your Name]

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Paul Quinton
Paul Quinton 1536 1024 Vicky Downs

Paul Quinton joins FirearmsLicensing.Net as a Consultant and Subject Matter Expert, bringing with him more than 21 years of frontline firearms licensing experience with Essex Police, alongside a distinguished earlier military career.

A nationally recognised authority in firearms licensing, Paul is widely respected for his strategic insight, operational leadership, and unwavering commitment to public safety, lawful shooting, and countryside advocacy.

Paul’s Career

Paul spent over two decades with Essex Police’s Firearms, Shotgun & Explosives Licensing Department, beginning his career as a Firearms Enquiry Officer and progressing to Deputy Firearms Licensing Manager. During this time, he led on complex and high‑risk suitability assessments, provided specialist internal technical advice, supported the implementation of new legislation, and engaged extensively with national stakeholders and partner agencies.

His leadership was instrumental in transforming Essex Police’s firearms licensing function, overseeing improvements that saw the force rise from the bottom to the top tier of national firearms licensing performance. Paul also played a key role in reinstating and strengthening advisory forums, improving constructive engagement with Registered Firearms Dealers (RFDs), shooting clubs, and representative bodies, and fostering a more transparent, collaborative approach to licensing.

Prior to joining Essex Police, Paul served in the British Army from 1981 to 2004, including operational roles as a Coldstream Guards sniper and later as Warrant Officer Class 1 Staff Assistant (Custodial) for the Provost Marshal. His military service included responsibility for high‑level inspections, tri‑service custodial oversight, complex logistics, and contributions to the rewrite of key custodial policy publications.

A decorated marksman, Paul represented the British Army internationally and earned selection for the elite Army 100.

Interests

A lifelong ambassador for lawful shooting and countryside conservation, Paul remains actively involved in shooting syndicates, deer management, and clay sports. He is a CPSA Safety Officer and is passionate about education, proportional regulation, and the promotion of responsible firearms ownership and access.

In his role with Firearms Licensing.net, Paul brings unrivalled practical experience from inside a major police firearms licensing unit. As a consultant and SME, he is committed to supporting forces, organisations, and individuals with pragmatic, evidence‑based advice, helping to raise standards, improve consistency, and strengthen trust across the firearms licensing landscape.
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Dunblane – 30 Years
Dunblane – 30 Years 1707 2560 Vicky Downs

Introduction

On 13th March 1996 the nation suffered profound shock and loss as the actions of a single individual robbed so many of their lives and loved ones.

Any discussion of Dunblane must begin with respect for that grief. But remembering Dunblane also means remembering it truthfully. And truth, in this case, is uncomfortable.

This is a highly emotive subject no matter what side of the debate you fall on but the 30-year anniversary must call for some considered reflection. In the space available I will not do justice to all the issues but there is one theme that remains particularly relevant today.

Narrative

A narrative that followed the tragedy was simple: the law was inadequate.

Yet the evidence presented to the subsequent Cullen Inquiry shows something entirely different. By 1996, the police already had the powers to refuse or revoke a firearm certificate if a person was not fit to be entrusted with a gun or if public safety was at risk.

They had the discretion to impose conditions, restrict access, and intervene early. These powers were not theoretical but rather they were well‑established and routinely used elsewhere.

Missed Opportunities

What Police also had was information. Complaints about the individual’s behaviour around boys’ clubs. Concerns raised by members of the public. Internal unease among officers. A pattern of conduct that, taken together, should have triggered review. The Cullen Report documents these warnings in detail.

One of the most striking pieces of evidence came five years before the shooting. In November 1991, Detective Sergeant Paul Hughes submitted a written recommendation access to firearms be removed. His assessment was stark:

 “He is a scheming, devious and deceitful individual who is not to be trusted… He has an extremely unhealthy interest in young boys.”

This was not rumour. It was a formal, internal warning from a child‑protection specialist. Yet the certificate was renewed. The tragedy is not that the police lacked the tools. It is that they did not use them.

That distinction matters. It matters because when institutions misdiagnose the cause of a failure, they repeat it.

A Consistent Message

I see this pattern often in my work. People sometimes assume that because I spent years in policing, I will instinctively defend the institution.

But in July 2024, I delivered a presentation to a room including police licensing managers, shooting organisations,  and opposition groups. In this I used Dunblane and other tragedies as examples of what happens when a licensing system has the powers, has the information, and still fails to act. The silence in the room wasn’t discomfort. It was recognition.

Everyone there understood that the most dangerous failures in licensing are rarely legislative. They are operational: poor information handling, inadequate resourcing and a lack of focus on the core work.

As Relevant Now

That brings us to today’s debate about aligning Section 1 and Section 2. On the surface, it is presented as an enhancement to public safety. But beneath that sits a familiar instinct: when the system struggles, change the law.

For the shooting community, misdiagnosis doesn’t just distort public debate – it shapes the regulatory pressures they live with for years afterwards.

The lesson of Dunblane is not that Britain needed different laws. It is that the police needed (and still need) the confidence, competence, and support to use the laws they already have.

Reform

As we mark another anniversary, we honour the victims by remembering the truth, not the myth. Dunblane was preventable under the law as it existed. The tragedy was not legislative failure. It was institutional inaction. And if we forget that, we risk repeating it.

That is why, if we want a safer, more resilient licensing system, we must insist on accuracy – in memory, in diagnosis, and in reform.

 

 
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Rejected, Closed, Cancelled
Rejected, Closed, Cancelled 2560 1707 Vicky Downs

Most shooters assume that if their firearms application doesn’t proceed, it’s because the police have formally refused it. In reality, thousands of applications every year never reach that stage at all. They are quietly “cancelled”, “rejected”, or “closed” long before any lawful decision is made and because cancellations are not a statutory outcome, they are not reported to the Home Office, not included in national statistics, and not monitored by any oversight body.

The result is a hidden postcode lottery where some forces cancel hundreds of applications a year, others cancel almost none, and applicants are left with no appeal rights, no scrutiny, and no explanation.

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Young People and Firearms
Young People and Firearms 2560 1703 Vicky Downs

We clarify the legal landscape surrounding young people and firearms in the UK—covering certificate eligibility, age-related restrictions, supervision, and practical pathways into shooting sports.

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Intelligence Ahead
Intelligence Ahead 2560 1706 Vicky Downs

The document explores the strengths and limitations of AI in relation to Firearms Licensing

Introduction:

If I’m lucky, someone might say I’m a thinker and a tryer.

Less charitable voices might call it obsession… but let’s talk about AI and the results of my experimentation in this area.

The Rise of the Machines

The recent explosion in Artificial Intelligence (AI) has been fascinating to watch and potentially terrifying in equal measures.

Recent figures from employment search engine Adzuna suggest that vacancies for graduate roles, apprenticeships, internships and junior positions with no degree requirement have fallen by 31.9 per cent since November 2022, when ChatGPT was released.

The Beginnings of firearmslicensing.net

When I first thought about creating this resource my technology consultant asked me if AI would render the idea redundant.

As a result, we experimented with several available systems with initially very promising results.

But then I started noticing some things.

Hallucinations and Misdirection

Caselaw – Some of the references I was being provided with were brilliant but didn’t actually exist.

On this subject The Solicitors’ Regulation Authority (“SRA”) recently said this:

“All computers can make mistakes. AI language models such as ChatGPT, however, can be more prone to this. That is because they work by anticipating the text that should follow the input they are given, but do not have a concept of ‘reality’. The result is known as ‘hallucination’, where a system produces highly plausible but incorrect results.”

Looking Elsewhere – I would ask AI a question, tell it where to find the answer and then it would look somewhere else and come back with something else entirely.

For example, I was researching the use of mentor conditions on Firearms Certificates and asked

“Are there any mentor conditions found in Appendix 3 to the Home Office Guide to Firearms Licensing Law?”

The system confidently answered yes, presented me with a direct quote of the wording and a summary of when the use of these conditions might be applicable.

This would have been fine but it’s completely incorrect.

In Conclusion

AI is a fantastic tool, I use it frequently most days but for now there are some areas that are still outside of its reach.

So where does that leave us?
🛠️ AI is a powerful toolkit—but it’s not a compass.
⚖️ For personal, procedural or high-stakes matters, always pair tech with trusted expertise.
👥 The trick is knowing when to ask… and who to ask.
(That last advice? Courtesy of AI, ironically.)
  • Vicky Downs
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Final Chapter for Lead
Final Chapter for Lead 1024 1024 Vicky Downs

The UK is phasing out lead ammunition by 2029. With a 3-year transition ahead, shooters must adapt to new rules.

Here’s what this shift means for the future of UK shooting.

Introduction:

On 10th July 2025 the Department for Environment, Food & Rural Affairs (DEFRA) announced a ban on “Toxic lead ammunition”.

Environment Minister Emma Hardy said:

“Britain is a proud nation of nature lovers, but our rivers are heavily polluted, and majestic birds are declining at an alarming rate.

 

This new ban on lead in ammunition for most uses will help reverse this – rejuvenating pride in our countryside by protecting precious birdlife and cleaning up rivers.

 

Non-lead alternatives are readily available, and we’ll continue to work closely with the shooting sector throughout this transition.”

🧑‍⚕️ This policy is driven by strong evidence of health risks, especially for children and wildlife.

🔄 A major transition away from lead is coming— use the 3-year transition period to plan ahead for alternative ammunition.

🧭 Enforcement is likely at retail level, so supply chains will feel the change first.

The Message – in Brief:

The UK Government plans to introduce legislation restricting sale and use of lead ammunition by summer 2026, followed by a three-year transition period ending in 2029.

It rejected earlier proposals for a five-year transition saying that this extended time period had taken impact to supply chains from Covid-19 into consideration.

  • 🗓️ Legislation introduced: Summer 2026
  • ⏳ Transition period: 2026–2029
  • 🚫 Full ban effective: 2029 – covering sale and use of lead shot and large-calibre bullets

Exemptions will remain for:

  • Military and police use
  • Elite athletes – proof will be required
  • Indoor Ranges
  • Outdoor ranges – provided control measures are present.
  • Small-calibre ammunition
  • Air weapon pellets
  • Collectors (Not for firing)
  • Academic and forensic work

Further detail:

Small Calibre – All calibres above 6.17mm (includes .243 and everything larger) intended for live quarry shooting will be restricted.

Packaging – All lead ammunition above 6.17 (.243) sold for target shooting will be labelled “must not be used for live quarry”.

Indoor use of lead shot – This will be formally restricted to ensure that the ban on lead shot generally can be effective at point of sale. This removes the possibility that any lead shot labelled for “indoor use only” would be used outdoors and closes this potential loophole.

Outdoor Target Ranges – Must be “permanent” – The detail of how this will be defined is unclear.

In conclusion:

Lead use can be traced back over 6,000 years in the widest variety of applications. It’s density, malleability and cost-effective nature are significant contributors to the longevity of its use.

Given the breadth of evidence, few would contest the rationale behind a transition away from but it seems as if the changes impacting on UK Shooting are happening almost monthly.

Having said this there is one section of the announcement that we would highlight:

“Alternatives to lead shot have become more efficient and widely available in recent years, with steel and tungsten-based shot being two popular options.

 

The government will continue to engage with the shooting industry to support the transition to alternative ammunition types.”

While non-lead alternatives are improving, uptake and availability remain varied.

We’d encourage the Home Office to remember that UK Shooting offers real benefits to both participants and the wider population. Moving forward meaningful consultation and engagement will be critical to ensure that this to ensure this shift does not feel disproportionate for UK shooting communities.

We’ll continue to monitor and update what this means for shooters, clubs, and retailers.

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