WHEN AN INSPECTOR CALLS…

Are you ready for your RFD renewal? Specialist firearms licensing solicitor Laura Saunsbury guides readers through preparing for the all-important police inspection that is central to the RFD certificate renewal process.

As readers will be aware, every three years you need to apply to your local police licensing authority for the renewal of your certificate of registration as a firearms dealer. If your renewal date is approaching later this year, a good place to start in preparing for your renewal and the associated police inspection is to read the Annex to the Home Office Statutory Guidance on Firearms Licensing Law. This contains a clear and concise summary of the various factors the police are required to evaluate when determining whether to grant or renew an RFD certificate.

In order to complete that assessment, the police will arrange for at least one or two firearms enquiry officers (FEOs), and possibly more, depending on the size and scale of your business, to carry out a personal visit to your business premises. Their inspection will encompass a detailed examination of your stock of firearms and ammunition currently on the premises, your registers of transactions, and the security of the premises, taking into account any previous theft or burglaries at your premises and current crime levels in your local area. Consequently, dealers with commercial shopfront premises in large cities such as London, Manchester or Birmingham, where higher levels of violent and organised crime are recorded, could be required to have significantly greater levels of security than dealers operating from a more discrete premises in affluent suburban or rural areas where recorded crime rates are generally lower. If you have a difference of opinion with the police regarding the security measures required at your premises, you might also wish to consult the Home Office Firearms Security Handbook 2020, which provides detailed guidance for police and others on securely storing and moving firearms.

The inspection visit on renewal could take a couple of hours to complete, so it should not be carried out as an unannounced visit or at short notice. It should be prearranged with you well in advance, and at a mutually convenient time, so that you are not required to close your shop and turn away customers at a time when you would normally be open. There is therefore no excuse for not being organised and prepared for this police visit.

Perhaps the most important element is the inspection of your stock and your record keeping. This will normally involve a full stock take to check that every firearm and all ammunition present on the premises have been entered into your registers of transactions to record when you received it and who from, although in the case of larger dealerships the officers could select a series of random samples of stock to cross-check against the registers if it is not practical to do a 100 percent full audit due to the volume of stock involved.

The stock and register inspection is also the area where it’s most common for queries or anomalies to be identified, which can then lead to problems with your renewal, and potentially even a criminal investigation for the offence of failing to maintain properly your register of transactions. It’s therefore worth spending some time before the police visit to do a full stock audit yourself, if necessary with the help of another person, to check that all firearms and ammunition listed in your registers as being on the premises can readily be located.

If the FEO forms the impression that there is a lack of systems for the management of firearms or ammunition stored at the premises, or that they are being stored in such a way as to make it difficult to account for them in your records, this could signal trouble for your renewal. So unless you are operating on a very small scale, it’s generally good practice to have different storage areas for section 1 firearms, section 2 shotguns, and unlicensed air weapons (and section 5 firearms if you have a Home Office authority to trade in prohibited firearms), as this should assist in locating any given firearm more easily. Consider also using a system of colour coded tags or labels to attach to the firearms.

In recent years, the Home Office and the Police have been keen to encourage a shift towards dealers keeping electronic registers that are stored digitally or in the cloud, although it is still perfectly permissible to keep a paper register, in which case large format register books specifically designed for this purpose should be used. In either case, as part of your preparation for the renewal visit, you should go through all entries in the registers since they were last inspected to check there are no gaps and that all entries are accurate and complete, and where handwritten, are legible. Again, it’s good practice to have separate registers, or at least separate sections of the register, for firearms, shotguns, air weapons, and ammunition. Sound moderators and other controlled component parts are also required to be recorded in the register of firearms.

In the past, police advice was generally that dealers do not need to keep a record of their sales of shotgun ammunition. However, more recently police views on this issue seem to have changed somewhat. Under the requirements of the Explosives Regulations 2014, you are obliged to record to whom you sell explosives, and on a strict interpretation this includes shotgun cartridges. If you are not already recording your sales of shotgun ammunition, it is highly recommend that you should start doing so.

The FEO might also want to discuss during the renewal inspection how your business has developed and grown, including any changes in core business areas or clientele, and the financial stability of the business These are all aspects of the review of your suitability to remain a firearms dealer which the police are directed by the Statutory Guidance to consider as part of the renewal process. You should therefore be open to answering questions on such matters.

First impressions are important – while the police cannot dictate how you store or record stock which is not subject to any firearms licensing control, if the premises appear well organised and presented, the police are likely to be reassured that a fairly light touch inspection of your stock and registers will be sufficient, whereas if your shop or workshop has an air of being rather untidy which suggests you might struggle to find things, they will probably be inclined to conduct a far more in-depth inspection. It seems obvious, but don’t invite a more thorough inspection which could easily have been avoided by a bit of general housekeeping.

Finally, readers should be aware that the long anticipated increase in fees for all types of firearms certificates has very recently been announced. With effect from 5 February, 2025, the fee for the grant or renewal of an RFD goes up from £200 to £466.