A reform of the national firearms licensing system could improve public safety and end the postcode lottery

National reform could improve public safety and end the postcode lottery, but further controls must be evidence-led and proportionate.

The National Gamekeepers’ Organisation (NGO) has welcomed the publication of a major inspection into firearms licensing in England and Wales by His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS). If carried through to its ultimate conclusion, this will be the biggest shakeup of firearms legislation and licensing since 1968.

The report concludes that the present system is not fit for purpose and makes 23 recommendations covering the structure of firearms licensing, consistency of decision-making, governance, training, medical monitoring, technology and firearms law.

The NGO contributed to the inspection and held discussions with HMICFRS, sharing evidence and the practical experiences of gamekeepers and other responsible certificate holders. We are pleased that our members had a voice in the process and that many of the concerns we raised are reflected in the report. Our involvement does not, however, mean that we agree with every recommendation.

HMICFRS inspected six firearms and explosives licensing units serving eight police forces. It reviewed 377 licensing case files and received 11,135 responses to its public survey. The report also records that at least 39 people were murdered during the ten years to March 2025 in shootings involving legally held firearms.

Every one of those deaths is a tragedy and we all recognise that public safety must remain at the heart of firearms licensing. The report also clearly recognises that most certificate holders comply with the law and use their firearms responsibly. It makes the point that there must be a good service provided to the shooting community. The NGO believes both points must be kept firmly in view when the recommendations are considered.

A national firearms licensing authority

HMICFRS’s principal recommendation is that the Home Office should establish a single firearms licensing authority for England and Wales by 1 September 2029.

The proposed authority would bring decision-making, standards, training, audit and performance oversight under central control, while retaining locally based staff to carry out local enquiries and suitability visits. HMICFRS believes this would provide the consistency, resilience and accountability which the present force-by-force arrangements have failed to deliver.

The NGO believes there is a strong case for this model. Our members have experienced the postcode lottery in firearms licensing for many years. Many forces provide a professional and timely service, while others are affected by inconsistent decisions, poor communication and unacceptable delays.

A national authority could improve public safety and provide a fairer and more efficient service to certificate holders. But simply changing the name above the door will not be enough. It must be properly funded, professionally staffed and developed with meaningful input from those who understand the lawful use of firearms. Local knowledge must also be retained where it is genuinely needed.

Governance, consistency and training

The inspection found significant weaknesses in the oversight of firearms licensing. There was a lack of effective supervision and oversight in 51 per cent of the cases examined, while five of the six licensing units lacked effective monitoring. In more than half of the units, the written arrangements setting out who was authorised to make decisions did not match what was happening in practice.

HMICFRS also found inconsistent approaches to background checks, referees, home visits, medical evidence and risk assessment. In practice, this means applicants and certificate holders can be treated differently depending on the force dealing with their case, or in some cases which member of staff is dealing with the application.

The NGO supports the report’s recommendations for stronger governance, effective audit and nationally consistent training. The recent introduction of national training for firearms enquiry officers is a welcome step, but managers, decision-makers and administrative staff must also be properly trained and supported. They make high-risk decisions and must meet the highest professional standards at every level.

Modern technology and certificate verification

HMICFRS found that the National Firearms Licensing Management System is at the end of its operational life and is not fit for purpose. This system is already scheduled for replacement with the selected contractor having been appointed earlier this year. 

The report recommends a secure and integrated national register and case-management system, together with real-time verification of certificates before firearms are sold or transferred.

The NGO supports modernising the technology behind firearms licensing. A reliable national system will improve the accuracy of records, reduce duplication, help prevent the use of fraudulent certificates and allow applications and transfers to be handled more efficiently.

Technology will not correct poor judgment on its own, but the present system is clearly no longer adequate. The shooting community should be involved as the replacement system and its practical processes are developed.

Medical information and firearms markers

The report examines the use of digital firearms markers on GP records. The marker has been rolled out to GP surgeries in England and has helped doctors alert the police to relevant medical concerns, but its use is not mandatory and serious gaps remain. Wales is due to introduce a digital marker during 2026.

HMICFRS recommends an in-person medical assessment by an approved clinician for every grant and renewal. It also proposes a legal duty requiring certificate holders to notify the licensing authority within seven days of any relevant change in their medical circumstances.

The NGO supports reliable medical information-sharing and consistent use of the firearms marker. However, compulsory in-person assessments for every applicant and every renewal could create considerable additional cost, pressure and delay.

Before introducing such a requirement, the Government must show that it would deliver a clear public-safety benefit, that enough suitably qualified clinicians would be available and that certificate holders would not face unreasonable charges. The risk of discouraging certificate holders from seeking medical help must also be taken seriously.

Firearms law and further controls

HMICFRS recommends simplified and modernised firearms legislation and legally enforceable licensing rules. It also proposes removing what it describes as the conditional presumption in favour of granting a certificate, requiring new applicants to pass a standardised competence assessment and aligning the section 1 firearm and section 2 shotgun regimes, including ammunition controls.

The NGO accepts that firearms law has developed over many years and can be unnecessarily complex. There may be a case for simplification and for correcting genuine gaps or ambiguities in the law.

However, the report’s evidence of inconsistent police administration does not automatically justify placing further controls, cost and bureaucracy on responsible certificate holders. Each proposal must be considered separately and shown to be necessary, effective and proportionate.

In particular, any proposal to align section 2 shotguns with the section 1 regime must take proper account of the practical effect on certificate holders, the gun trade and already stretched licensing services. Compulsory competence testing, which is proposed for new applicants only and changes to medical requirements must be subject to the same careful scrutiny.

The NGO is not opposed to change. Effective firearms licensing protects the public and supports the continued lawful use of firearms. But new legislation is not a substitute for administering the existing law properly.

The NGO’s position

The report provides strong independent evidence that firearms licensing needs structural reform. The NGO supports the direction of travel towards a consistent, properly governed and professionally delivered national service.

We particularly welcome the emphasis on:

● consistent national decision-making and standards;

● properly trained staff at every level;

● effective governance, supervision and audit;

● modern digital systems and real-time certificate verification;

● reliable medical information-sharing; and

● continued local capability for visits and suitability assessments.

We will examine the more far-reaching legislative proposals carefully and judge each one on the evidence. Where a recommendation addresses a demonstrated risk and improves public safety, the NGO will engage constructively and support sensible reform. Where the evidence points to a failure of administration, the priority must be to correct that failure rather than transfer its consequences onto lawful firearms users.

The NGO will continue to work with Government, HMICFRS, policing, the British Shooting Sports Council and other shooting organisations as the report is considered.

It is important for members to understand that these are HMICFRS recommendations. They are not yet Government policy and they do not change the law.

Livia Brynin JP, LLB

Alan Barrell

NGO Firearms Licensing Team