NGO responds to the government position on merging Section 1 and 2 firearms licensing

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The National Gamekeepers’ Organisation responds to the Government’s reply to the petition calling for section 1 and section 2 firearms licensing to remain distinct.

The petition, supported by more than 100,000 signatories, reflects widespread concern among those who lawfully own and use shotguns as essential tools of work within rural and land-based industries.

This response sets out why proposals to strengthen or merge shotgun licensing must be evidence led, proportionate and targeted at genuine risk, and why reclassification alone does not improve public safety.

Lawful use and rural impact

The petition reflects legitimate concern among farmers, land managers, pest controllers and gamekeepers who rely on shotguns for lawful purposes including wildlife management, livestock protection, pest control, food production and conservation.

For gamekeepers in particular, shotguns are not recreational items but regulated tools used daily in the course of employment. These activities underpin rural livelihoods, animal welfare, habitat management and the wider rural economy.

Public safety and licensing framework

“Public safety is about behaviour, judgment and competent licensing, not whether a shotgun sits in section 1 or section 2. Reclassification changes labels, not risk,” said Livia Brynin, Firearms Advisor for the National Gamekeepers’ Organisation.

The Government states that public safety underpins its intention to consult on strengthening shotgun controls. However, the statutory test for public safety already applies equally to shotgun and firearms certificate holders.

From a licensing and risk assessment perspective, reclassification addresses categorisation rather than capability, behaviour or warning indicators. Licensing decisions must remain individualised, proportionate and evidence led, based on risk, suitability and ongoing assessment rather than weapon category alone.

Keyham and systemic licensing failures

The repeated reliance on the Keyham tragedy as justification for policy change is deeply concerning. That case exposed long-standing and serious systemic failures within police firearms licensing, including poor decision making, inadequate training and an inability to apply existing risk assessment processes effectively.

These failures occurred within the current legal framework and would not have been prevented by altering the legal classification of shotguns. Policy attention should instead be directed towards improving licensing consistency, decision auditability, information sharing and professional competence within police firearms licensing units.

Misplaced association with knife crime

The inclusion of knife crime within the Government’s response to a petition about lawful shotgun ownership is misplaced. It conflates fundamentally different issues and risks reinforcing a narrative that wrongly associates compliant certificate holders with criminality.

Farmers, pest controllers and gamekeepers are law abiding, vetted and subject to ongoing scrutiny under one of the most stringent firearms licensing regimes in the world. Treating them as part of a broader criminal problem which they have no connection to undermines trust, damages confidence in the licensing system, and unfairly tars responsible people with a criminal brush.

A proportionate and evidence-based approach

If the Government is serious about improving public safety, the priority must be to address an inconsistent and under-resourced firearms licensing system rather than impose blanket changes that penalise responsible people while leaving systemic weaknesses untouched. Evidence consistently shows that risk lies not with lawful ownership itself, but with failures in assessment, information sharing and decision making.

The National Gamekeepers’ Organisation supports proportionate, evidence based licensing and has always been clear that firearms must not fall into the wrong hands. However, proposals must be targeted at genuine risk, grounded in evidence and conscious of unintended consequences for rural work, conservation and food production.

We will engage constructively with the forthcoming consultation, but we will strongly oppose any proposals that seek to solve the wrong problem, lack evidential foundation or disproportionately harm lawful rural communities and the rural economy. Public safety is best served by competent, consistent licensing, not by symbolic legislative change.

ENDS

Notes to Editors:

The National Gamekeepers’ Organisation: The National Gamekeepers’ Organisation (NGO) represents the gamekeepers of England and Wales. The NGO defends and promotes gamekeeping and gamekeepers and works to ensure high standards throughout the profession. The National Gamekeepers’ Organisation was founded in 1997 by a group of gamekeepers who felt that keepering was threatened by public misunderstanding and poor representation. Today, there are 13,000 members of the National Gamekeepers’ Organisation.  www.nationalgamekeepers.org.uk