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BDS Guidance on the Government Open Consultation on Firearms Licensing

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Article by:
David McAuley, CEO, British Deer Society

Guidance on the Government Open Consultation on Firearms Licensing

This Governments consultation seeks views on recommendations made to the government by:

  • the Senior Coroner for Plymouth, Torbay, and South Devon, following the inquest into the deaths of those shot and killed by a licensed shotgun owner in Keyham on 12 August 2021
  • the Independent Office for Police Conduct (IOPC), following its investigation into Devon and Cornwall Police’s decision-making in relation to the possession of a shotgun and shotgun certificate by the shooter in Keyham
  • the Scottish Affairs Select Committee, following its review of firearms licensing regulations in Scotland, which followed a fatal shooting on the Isle of Skye on 10 August 2022

The following article seeks to provide readers with some guidance on how you may choose to answer each question in the consultation. Many questions will only allow for a Yes or No response which may limit your opportunity to express your point of view in full.

It has been noted by the British Deer Society that several questions in the consultation might give the impression that the police do not have existing powers to address some areas of concern. However, this is not the case and where a no response is suggested this is mainly because:

  1. Sufficient powers already exist
  2. Sufficient checks or procedures are already in place to ensure public safety

The BDS feels that in general the current checks and processes, if followed correctly, are extremely robust.  This is reflected by the low rate of legally owned firearms related incidents across the UK.

However, any loss of life is a tragedy and we do see opportunities to improve firearms licensing within the framework of this consultation. In particular we have included potential improvements to firearms licensing in our suggestions for the open comments box at the end of the consultation.

The current consultation will close at 11:59 pm on 23 August 2023 so make sure to get your responses in before the deadline.

Consultation Guidance

(a) A power of immediate seizure of firearms, shotguns, and ammunition

Q1. Do you consider that the police should be granted a specific power of entry (without a warrant issued by a magistrate or sheriff) to be able to seize shotguns, firearms, and ammunition where there is a risk to public safety, or the peace and the certificate holder does not cooperate with the police and agree to voluntary surrender?

Response: No
Adequate powers already exist to seize firearms, shotguns, and ammunition.

(b) Mandatory prohibitions

Q2. Do you consider that the prohibition on possessing firearms should be changed from one that is based solely on length of a custodial sentence following conviction, to one based more on the nature of the offence?

Response: No
Adequate powers already exist.

(c) Length of certificate before renewal required

Q3. Do you consider that the renewal period (currently every five years) for a certificate should be kept under review? If so, is renewal every five years the right period of time or should it be changed to a shorter or longer period of time?

Response: Yes, more than 5 years

Recommendations relating to referees

Q4. Do you consider that people applying for shotgun certificates should provide two referees?

Response: No
The current system provides suitable referee input.

Q5. Do you consider that at least one of the referees should be a person of certain standing in the community (e.g., of a professional background)? This could include public officials (both elected and Civil Servants or Local Government officers), members of a regulated profession (including doctors, nurses, solicitors, barristers, accountants and FCA regulated finance professionals), officers of registered shooting clubs, National Farmers’ Union representatives, landlords, land managers, vets, or surveyors.

Response: No
The process should focus on the referee being of good character and having sufficient knowledge of the applicant. A focus on public officials could be seen as discriminatory and is not a guarantee that the referee can provide the reassurances being requested.

Q6. Do you consider that referees should be able to demonstrate a good knowledge of the applicant’s circumstances, relevant to their suitability to possess a firearm or shotgun?

Response: Yes

Q7. Do you consider that the application form should include a checklist for referees on the information that they should provide to the police, and require referees to provide a written declaration that they have disclosed all relevant facts to the police?

Response: No
It is felt that liability on checking suitability should sit with the police and that this responsibility is not transferred to the referee.

Q8. Do you consider that the Statutory Guidance should include more detailed guidance for the police on the information they should be looking to elicit from referees?

Response: No
The current guidance is sufficient.

Q9. Do you consider that the police should look at the circumstances when individuals change referees between application and renewal, and between subsequent renewals?

Response: No
There are many legitimate reasons why an applicant might change referee and it is common for referees to change given the time period between applications.

Q10. Do you consider that the sharing of the unique application reference number by the applicant with their referees would make it easier for referees to report concerns they have about applicants to the police, or to decline to give references, or, for those who give references but subsequently become concerned that the applicant may no longer be suitable to have access to a firearm or shotgun, to report this later to the police.

Response: No
This would create an unnecessary extra level of bureaucracy and it is unlikely that anyone raising concerns will know or remember the reference number.

Other recommendations

Q11. Do you consider that the content in the Statutory Guidance should be expanded and made more prescriptive in relation to the suitability checks carried out by the police for firearm and shotgun applicants and certificate holders?

Response: No
The police should be allowed to continue to use their judgement.

Q12. Do you consider that the balance of probabilities test is the correct test to apply in the Statutory Guidance to information about a person’s suitability to hold a certificate? This is the test that the police have been using for many years and is applied in weighing the evidence and information in any individual case.

Response: Yes

Q13. Do you consider that neurodevelopmental disorders should be added to the list of relevant medical conditions in the Statutory Guidance (and application form)?

Response: No
This area is widely diverse, and its introduction could be discriminatory with individuals who pose no risk being excluded unfairly.

Q14. Do you consider that GPs’ engagement with the firearms licensing process should be made mandatory?

Response: Yes

Q15. Do you consider that interim medical checks should be made on licensed firearms holders between the grant of the certificate and any application to renew?

Response: No

Q16. Do you consider that the digital marker for use by GPs on the medical records of licensed firearms holders should be visible to other health professionals?

Response: Yes

Q17. Do you consider there should be more mental health advice and support for licensed firearms holders through, for example, advice leaflets and other such support?

Response: Yes

Q18. Do you consider a specific phoneline should be introduced in addition to the services already available to report concerns about a licensed firearms holder?

Response: No

Q19. How in principle should any specific phoneline be funded?

Response: No Response as the phoneline is not needed

Q20) Do you consider that it would be better to raise awareness of existing avenues open to raise concerns about a licensed firearms holder (999, 101, Crimestoppers, force firearms licensing contacts) than create a new phoneline service?

Response: No Response as it is widely understood how to raise concerns and the methods available

Q21) You should use this box to make any points that you feel are important, and especially to elaborate on any previous answers you felt were restricted by the Yes or No options allowed.

You may also wish to comment on other matters that the Review might usefully consider, such as:

  • ‘By exception’ reporting by GPs to licensing authority requests (in addition to the mandatory engagement under Q14)
  • Removing licensing requirements for sound moderators.
  • The case for centralised national licensing (supported by regional teams for interviews, home visits, case reviews etc).
  • The need for standardised, fair, and timely processing of applications, and appropriate accountability for when this is not achieved.
  • The use of firearms by under 17 should be brought into line with that of shotguns, enabling young people to be carefully trained in the safe use of firearms whilst under supervision by a certificate holder.

This article has aimed to provide guidance on the consultation, but ultimately your response should be your own and these are provided purely to give you an insight into the charity’s position.

If you have any additional questions about the consultation and our guidance you can email these to

The current consultation will close at 11:59 pm on 23 August 2023 so make sure to get your responses in before the deadline.

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