Government doubles shotgun licence referees requirement

Following their February 2025 response to the 2023 consultation firearms licensing, the Home Office published on Tuesday (5 August 2025) a raft of revisions to the Statutory Guidance to Chief Officers of Police on firearms licensing. That consultation was launched following the inquest into the tragic Plymouth shooting in 2021, which was attributed by an inquest jury to police failure. The most notable change to the statutory guidance is that applicants for shotgun certificate grants and renewals will now be required to give details of two referees rather than one. Such a revision is an alignment of Section 2 shotgun licensing with Section 1 firearms licensing and this alignment is at a sensible and acceptable level, but critically does not address the real reason that guns end up in the wrong hands – the inconsistent and, places, ineffective licensing system with 43 disparate licensing authorities in England and Wales.

A summary of the main changes to the Statutory Guidance is set out below:  

• Increasing the number of referees for a shotgun application from one to two. There is also more detail in the Statutory Guidance regarding the information the police should obtain from referees, including where the referee has changed between grant and renewal, and ensuring that the referee knows who to contact if they have concerns about the applicant in the future.  

• Strengthening the Statutory Guidance in relation to evidence of domestic abuse or other violence, providing further guidance to the police on when to carry out additional checks and concerning the interviewing of partners and household members, and making clear that evidence of dishonesty is relevant to suitability.  

• Explaining the application of the balance of probabilities test and the weight to be applied to evidence to ensure that the police are able to consider all of the information available to them.  

• Providing greater clarity about police powers to refuse or revoke certificates in cases involving violence and other offences or where a person admits guilt and has an out of court disposal.  

• Updating the Statutory Guidance to recognise that an out of court disposal may be the sanction given for serious matters, such as violent incidents, disorder and possession of drugs, which are relevant to a person’s suitability.  

• Requiring the police to provide identification during an unannounced visit, to carry out a full review as soon as possible following surrender or seizure of firearms and advise the certificate holder of the result, and to return firearms promptly if there is no danger to public safety.  

Tim Bonner, Chief Executive of the Countryside Alliance said:

“None of this will make any difference where the licensing system fails as it did in Plymouth and has done far too often elsewhere. Whilst we support these changes, there can be no justification for further restricting gun ownership and the government must address the fundamental question of why we have an antiquated system with 43 separate licensing authorities too many of which are not fit for purpose.” 

The Countryside Alliance supports government proposals to require two referees for shotgun licences as they could help reduce risk to public safety, albeit to a small degree, without doing unnecessary harm to the legitimate use of shotguns for both work and recreation. However, the government also plans to re-open a consultation into further restrictions on firearms licensing by even greater alignment of shotgun certificates with those for other firearms like rifles. This would serve only to harm legitimate use of shotguns by farmers, keepers, pest-controllers, game shooters, clay shooters and more. What is needed is root and branch reform of the licensing system.  

Let us not forget that the inquest into the 2021 Plymouth shooting found that there was “a serious failure within the [Devon and Cornwall Police] Firearms and Explosives Licensing Unit (FELU) to heed and apply the 2016 Home Office guidance”, confirming that the existing law is sufficiently stringent already and needs only to be applied properly. That is why the Countryside Alliance is campaigning for the creation of a single, centralised licensing authority in England and Wales, which delivers a safe, consistent, effective and efficient service for all – a far cry from the postcode lottery currently in place. 

Policing Minister Dame Diana Johnson said: “Only those who meet the highest standards of safety and responsibility should be permitted to use shotguns or firearms, and it is crucial that police have full information about the suitability of all applicants for these lethal weapons.” It is disappointing that the minister continues to refer to shotguns as ‘weapons’ in this context – a matter that we will seek to raise directly. Her comments did not address the ability (or lack thereof) of police firearms licensing departments to implement the legislation in practice. 

The refreshed Statutory Guidance will come into effect from today and will replace the previous Statutory Guidance which was issued in February 2023. The firearm and shotgun application form and the registered firearms dealer application form are also being revised to reflect the changes in the Statutory Guidance, and they will be published at the same time. 

The new statutory guidance can be read in full here.