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Shotguns aren’t the problem

Shotguns aren’t the problem 2560 1707 Chris Downs

Summary

The Home Office may soon collapse two distinct licensing regimes into one. This move risks undermining public safety, destabilizing lawful ownership, and ignoring the true lessons of Keyham.

Introduction

On 29 June 2023, the Home Office launched a public consultation on proposed changes to UK firearms licensing. These proposals stem from high-profile reviews, including:

  • The Prevention of Future Deaths report following the tragic shooting in Keyham, 2021
  • The Independent Office for Police Conduct’s assessment of Devon and Cornwall Police’s handling of the case
  • The Scottish Affairs Committee’s inquiry into regional firearm regulations
  • The Coroner’s Warning—and Government Response

In his report, Senior Coroner Sir Ian Arrow expressed concern over the statutory presumption that certificates “shall be granted” unless specific criteria are not met. He recommended reversing this—requiring applicants to first prove their suitability.

The Home Office replied:

We have carefully considered your point… but do not agree… Sections 27 and 28 are drafted to support consistency in police decision-making and give certainty to the applicant… This supports public safety…

This exchange reveals a tension between professional opinions that we now see changed under the current UK Government.

Why Do We Have Two Regimes?

Shotguns were historically treated as culturally distinct from pistols and rifles, due to their use in agriculture and sport. As such, they were not originally subject to the same controls.

In fact, the law specifically states that shotgun possession should not be restricted to those who intend to use them or lend them to others to use (See Sec 28(1B) Firearms Act 1968). This enables possession of heirlooms, antiques and for other diverse reasons.

The History

  • Firearms Act 1920: Targeted pistols and rifles feared to be misused by revolutionaries. Shotguns, which were commonplace, were excluded.
  • Firearms Act 1937: Mentioned shotguns for the first time, defining them as having barrels at least 20 inches long (now 24″).
  • Firearms Act 1968: Consolidation: In response to rising crime involving “sawn-off” shotguns, this Act introduced Section 2 shotgun certificates with less stringent requirements than Section 1 firearms.

This historical position reflects not just convenience, but public consensus—recognising practical and cultural differences.

The likely affects of alignment

The proposal to require shotgun holders to justify each firearm (as under Section 1) would:

  • Overwhelm disposal channels: If holders relinquish shotguns en masse, lawful disposal pathways (RFDs & Police) may fail—raising risks of diversion.
  • Put shooting at risk: Thousands may surrender certificates, not due to risk but because of increased red tape.
  • Strain police capacity: Additional scrutiny means more checks, longer processing times, and resource reallocation.
  • Fail to address root causes: Keyham and similar tragedies involve failures of assessment and enforcement—not regime design.

Importantly, none of the past incidents cited would likely have been prevented by the proposed alignment. Legislation should be evidence-led, proportionate, and practical.

Conclusion:

Public Safety Must Lead—Not Political Optics

Shotgun and firearm regimes are different for good reason. Reform should enhance actual safety, not just the appearance of control. That means assessing holder suitability, ensuring enforcement consistency, and supporting lawful ownership—not destabilizing it.

The Home Office is expected to launch a second consultation later in 2025. Every stakeholder—shooting organisations, legal experts, certificate holders, and the public—must engage.

This isn’t administrative tidying. It’s a fork in the road for UK shooting culture. Reform must serve real safety—not just the illusion of control.

A variety of firearms licensing resources

Firearms Licensing – Resources

Firearms Licensing – Resources 1709 2560 Vicky Downs

This guide to firearms licensing resources includes reference to:

  • Statutory Guidance (2023): A mandatory reference for police decision-making, focused on consistency and public safety.

  • Home Office Guide (2024): A detailed, non-statutory companion for interpreting firearms law.

  • Firearms Security Handbook (2020): Practical requirements for safe storage, transport, and display of firearms.

  • College of Policing APP: Operational guidance for police forces in line with legal and ethical obligations.

  • Firearms Act 1968: The legal foundation defining certification, prohibitions, exemptions, and enforcement mechanisms.

Introduction

This guide is intended for certificate holders, FEOs, legal professionals, and anyone seeking a structured understanding of UK firearms law.

It brings together the most authoritative materials that shape firearms licensing into one place.

It covers everything from statutory guidance and operational practice to foundational legislation and security expectations.

Each section provides a brief overview and direct access to primary documents, helping everyone navigate the often too complex world of Firearms Licensing.

The order in which I have presented these might seem wrong. Many would argue that the Firearms Act should be at the top as it represents the key legislation in this area. To be honest – they have a point, but I have arranged these in order of those most likely to help you address any issues you might experience.

Subscribers to firearmslicensing.net can access tailored breakdowns and interpretation tools.

This supports our key goal to Support Responsible Shooting and empower everyone to better understand their rights and obligations within the system.

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1) Statutory Guidance

The Statutory Guidance for Chief Officers of Police on Firearms Licensing—revised in February 2023—was introduced to ensure greater consistency across police forces in the application of firearms licensing law. The need for this was first highlighted in 2015 by the “Targeting the Risk” review conducted by His Majesty’s Inspectorate of Constabularies (HMIC) but not implemented until November 2021 (Post Keyham).

The guidance outlines the processes and criteria for assessing an applicant’s suitability to possess firearms or become a Registered Firearms Dealer (RFD). It covers a wide range of checks, including background and medical checks, home visits, referee assessments, and—newly added—social media reviews. It also addresses continuous assessment, unannounced visits, and the handling of renewals, revocations, and appeals.

Importantly, while chief officers retain discretion, any departure from the guidance must be clearly justified on a case-by-case basis.

https://www.gov.uk/government/publications/statutory-guidance-for-police-on-firearms-licensing

2) Home Office Guide on Firearms Licensing Law

The Home Office’s Guide on Firearms Licensing Law (originally published in 2012 and most recently updated in December 2024) provides a comprehensive, non-statutory reference for police forces, firearms licensing professionals, and interested parties. It’s designed to explain the complex framework of UK firearms legislation and should be read alongside the statutory guidance for chief officers of police.

The key areas covered are:

  • Licensing Framework: It outlines the legal basis for firearm and shotgun certificates under the Firearms Acts, including eligibility, suitability, and good reason requirements.
  • Application Process: Guidance on background checks, interviews, home visits, and the role of medical information and referees.
  • Conditions and Revocations: Explains standard and discretionary conditions, revocation procedures, and appeals.
  • Firearms Dealers and Clubs: Covers registration, record-keeping, and compliance expectations for dealers and shooting clubs.
  • Specialist Topics: Includes sections on antique firearms, prohibited weapons, museum collections, and exemptions (e.g. Section 11(6) clay shoots).
  • Recent Updates: The 2024 revision reflects changes such as updated departmental names, guidance on remote sales by dealers, and reinstated exemptions for race starters and clay pigeon shoots.

https://www.gov.uk/government/publications/firearms-law-guidance-to-the-police-2012

 

3) The Firearms Security Handbook

The Firearms Security Handbook 2020 offers detailed guidance on the secure storage and transport of firearms, shotguns, and ammunition. It’s aimed at certificate holders, firearms dealers, museums, clubs, and police forces.

The key areas covered are:

  • Security Principles: Emphasises layered security and proportionality based on risk. It introduces three levels of security, with Level 1 being the baseline for most certificate holders.
  • Cabinet Standards: Provides specifications for gun cabinets, safes, and armoury rooms, including construction materials, fixings, and locking mechanisms.
  • Special Environments: Offers tailored advice for mobile homes, garages, and shared dwellings.
  • Section 5 and Business Use: Covers additional requirements for dealers, auctioneers, and those storing firearms for professional purposes.
  • Museums and Clubs: Sets out expectations for secure display and storage in public collections and cadet corps premises.
  • Transport Guidance: Details safe carriage of firearms and ammunition, including black powder, with reference to relevant transport regulations.
  • Annexes: Include illustrations of cabinet construction, standards references, and good practice for transporting ammunition.

https://www.gov.uk/government/publications/firearms-security-handbook

 

4) The Police Authorised Professional Practice – Firearms Licensing

The Authorised Professional Practice (APP) on Firearms Licensing from the College of Policing provides operational guidance for police forces in England and Wales (Last updated April 2024). It complements the Home Office statutory and non-statutory guidance and is designed to ensure consistency, transparency, and public safety in firearms licensing decisions.

The key areas covered are:

  • Purpose and Principles: The APP aims to prevent foreseeable harm, manage risk decisively, and deliver a fair, proportionate, and consistent service. It emphasises professional judgment and effective governance.
  • Legal Framework: Licensing activity is governed by the Firearms Act 1968 and related legislation. Chief constables are legally responsible for granting, renewing, or revoking certificates.
  • Suitability Assessment: Applicants must demonstrate a good reason and be assessed as suitable. The main test is whether they can possess firearms without danger to public safety or the peace. Suitability checks include criminal history, mental health, domestic circumstances, and more.
  • Application Process: Applications are logged on the National Firearms Licensing Management System (NFLMS). Enquiries begin immediately and include background checks, home visits, and interviews. Firearms Enquiry Officers (FEOs) play a key role in assessing security, competence, and any safeguarding concerns.
  • Decision Making: Decisions to grant, refuse, or revoke certificates must be evidence-based and made by appropriately authorised personnel. The APP encourages forces to document rationale clearly and act swiftly on identified risks.
  • Alignment and Accountability: Forces are expected to align with this APP and the Home Office guidance. If they choose not to, they must notify the national policing lead and provide justification.

https://www.college.police.uk/app/firearms-licensing 

5) The Firearms Act 1968

The Firearms Act 1968 is the cornerstone of firearms legislation in Great Britain. It consolidates earlier laws and sets out the legal framework for the possession, acquisition, and use of firearms and ammunition.

The key areas covered are:

  • Section 1 – Firearm Certificates: Requires individuals to hold a firearm certificate to possess, purchase, or acquire most firearms and ammunition. Applicants must demonstrate a good reason and be assessed as suitable.
  • Section 2 – Shotgun Certificates: Establishes a separate, slightly less intrusive certification process for shotguns. It could be said that the Police have to justify a refusal rather than the applicant proving themselves.
  • Section 3 – Transactions: Regulates the sale, transfer, and repair of firearms and ammunition. Only certificate holders or registered dealers may engage in such transactions.
  • Section 5 – Prohibited Weapons: Lists weapons that are generally prohibited (e.g. automatic firearms, certain handguns). Possession of these items requires special authority from the Home Secretary.
  • Section 7 – Police permit – Gives police the option to issue a permit to enable rather than a full Certificate.
  • Section 11 – Exemptions: Provides exemptions for certain activities, such as clay pigeon shooting under supervision or use at approved clubs, where a certificate may not be required.
  • Section 20 – Creates the offence of trespassing while in possession of a firearm.
  • Section 26A & 26B – Rules around the application process for Firearms and Shotgun Certificates.
  • Section 27 & 28 – Describe when a Firearms and Shotgun Certificate may be granted.
  • Section 29 – Enables variations to Firearms Certificates.
  • Section 33–39 – Firearms Dealers: Requires dealers to be registered with the police and maintain records of transactions. These sections also cover inspections and revocation of registration.
  • Section 44 – Appeals: Allows applicants to appeal refusals, revocations, or conditions imposed on certificates to the Crown Court.
  • Section 46 – 52 – Provides Police powers and rules for the punishment of offences

https://www.legislation.gov.uk/ukpga/1968/27/contents

Firearms & Shotgun Regimes compared

Firearms & Shotgun Regimes compared 2560 1537 Chris Downs

This article provides a detailed comparison of Firearms Certificates (FAC) and Shotgun Certificates (SGC) under UK law, highlighting key differences in requirements, restrictions, and police assessments. It explains how the SGC regime was introduced in 1968 as a less stringent form of control compared to the FAC, but recent trends show police forces tightening their stance on renewals.

Key points include:

  • Legal wording differences
  • Good reason requirement
  • Ownership and conditions
  • Increasing Police scrutiny

The document also discusses potential future alignment of the two regimes and advises SGC Holders to prepare for more intrusive scrutiny.

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