Laura Saunsbury, our in-house firearms law expert, gives her analysis of the revised Statutory Guidance to the Police on Firearms Licensing published by the Home Office on 5th August 2025.
The Statutory Guidance governs how the police should assess the suitability of applicants for firearm and shotgun certificates or to become a registered firearms dealer. The new edition came into effect immediately, and therefore the police must apply it to all firearms licensing decisions made from 5th August onwards, including applications for grant or renewal submitted before that date. It makes a number of significant changes to the previous version of the guidance, dating from February 2023.
Overall, the updated Statutory Guidance introduces a stricter regime, which is going to make it even harder than before for the shooting community to obtain and keep certificates. Key changes which have been introduced include;
1. Applicants for grant and renewal of shotgun certificates will now require two referees rather than just one, aligning them with firearm certificate applications. There will also be more in depth questioning of referees.
2. Routine interviewing in all cases of the applicant’s partner and other household members, to be done in the absence of the applicant.
3. Additional checks to be carried out by the police where there have been any allegations of violent behaviour or domestic abuse, including following up on any intelligence or reasonable suspicion.
4. Tighter guidance generally in relation to domestic abuse, the net effect of which is likely to mean that where there are any concerns at all of such behaviour, whether by a certificate holder or another member of their household, it is virtually inevitable now that the guns will be removed and the certificates revoked, even where no offence is proven.
5. The list of relevant medical conditions remains unchanged, but doctors are also now directed to consider when completing medical proformas any ‘neuro developmental’ as well as mental or physical conditions which may affect the individual’s safe possession of firearms. The addition of neuro developmental conditions, an umbrella term which covers a wide variety of different conditions, may lead to further questioning of applications and ultimately refusals.
6. Closed material procedure is now permitted in certain cases, meaning that in an appeal to the Crown Court, the police may be permitted to present evidence to the court which is not shared with the applicant or their lawyers, but only in those cases where the non-disclosure of that information can be justified.
However, it is not all doom and gloom. Amongst the negatives, there are also a few positives. There are a number of improvements made by the updated Guidance which now expressly confirms;
1. With the exception of where there is an immediate threat to life, there is no power for the police to enter premises in order to seize firearms and ammunition for the purposes of reviewing the certificate holder’s suitability. The police will need to rely on either voluntary surrender or a warrant from a Magistrate.
2. When making unannounced visits to a certificate holder, the police officers should produce identification and also provide a receipt for all property seized or surrendered. The requirement for a receipt was contained in the previous version of the guidance, but was frequently not followed by the police, so it remains to be seen how much difference this will make.
3. Before deciding how much weight or reliance should be placed upon an allegation made about the applicant’s conduct, the police should first investigate the facts to allow them to make findings on the truthfulness of the allegation or conduct. This is a valuable addition to the Guidance, as there has often been a tendency to accept at face value any allegation against a certificate holder or applicant, with little or no investigation. The only downside is that this requirement may lead to further delays with suitability reviews and applications.
4. It is now confirmed that medical checks are not generally required for firearms dealers’ servants. This will put paid to attempts by certain police forces to introduce this as an additional requirement.
It’s early days yet, and it remains to be seen what the practical impact will be of the updated Statutory Guidance.