MODERATOR REFORM MOVES FORWARD – BUT QUESTIONS REMAIN

The UK Government has confirmed its intention to remove sound moderators from the legal definition of a firearm, following overwhelming support from the shooting community in a recent public consultation.

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First outlined in early 2024, the proposal seeks to reduce the administrative burden on both certificate holders and police forces by no longer requiring a variation to a firearms certificate in order to acquire or possess a moderator. A total of 19,277 responses were received during the six-week consultation, with 94% of respondents in favour of deregulation.

Currently, sound moderators, devices used to reduce noise and muzzle flash, are classified as components under section 57(1)(d) of the Firearms Act 1968. As such, they are treated as firearms in their own right, requiring police authorisation for possession or acquisition. The Government now proposes legislative reform to remove that requirement, recognising that moderators pose no inherent danger to public safety.

In its formal response, the Home Office stated: “This would meet the original objective of removing the administrative burden on the police and shooters of having to apply for a variation of a firearms certificate in order to acquire or own a sound moderator while at the same time helping to ensure that they were only held by those with a legitimate purpose, as demonstrated by the possession of a valid firearms certificate.”

GTA’S ROLE IN ACHIEVING REFORM

The Gun Trade Association (GTA) played a significant role in pushing for this change over a sustained period, engaging directly with policymakers, civil servants and the wider shooting community. The issue has been under discussion for several years, with the GTA consistently making the case that moderators, being inert and non-lethal, should not be subject to the same licensing controls as firearms. Stephen Jolly, chief executive of the Gun

Trade Association, told Gun Trade Insider (GTI):

“It’s important for the trade and for certificate holders to understand that this is not yet law, but it’s a clear step in the right direction. We welcome the Government’s recognition that moderators pose no public safety risk and that their continued licensing is a needless bureaucratic burden.”

The British Shooting Sports Council played a central role in coordinating engagement with officials over a sustained period.

“The British Shooting Sports Council has worked extensively, alongside other partner organisations, to bring this issue to the government’s attention and press for reform,” said Jeremy Hinde, secretary, British Shooting Sports Council. “While this announcement is a welcome step forward, there remain technical details that require further clarification. We look forward to continuing to work with the Home Office to ensure the implementation is clear, proportionate and effective for all stakeholders.”

PRIMARY LEGISLATION OVER REFORM ORDERS

Despite calls for swift action via a Legislative Reform Order (LRO), the Government confirmed it would instead pursue change through primary legislation. While a slower route, the Home Office argues this approach allows the Firearms Act 1968 to be updated more comprehensively. It also paves the way for a new offence: possessing a moderator without a valid firearm certificate, ensuring only licensed individuals have access.

Stephen added: “It’s not the complete deregulation many of us had hoped for, moderators will still only be legally available to certificate holders, but it’s progress. It cuts unnecessary paperwork for the police and shooters alike, and that’s a win for the whole sector.”

TRADE VIEW: FRUSTRATION OVER DELAY AND GREY AREAS

Barry Johnson, chairman of the Deactivated Weapons Association (DWA), and another trade organisation that has been campaigning for regulatory reform through the British Shooting Sports Council (BSSC), welcomed the Government’s announcement but voiced concern over the legislative direction and slow progress.

“We were literally three or four days away from the last policing minister removing moderators via some form of statutory instrument,” he said. “Everyone was in agreement; the Home Office, police chiefs, National Crime Agency, and the trade, that the current situation was bureaucratically and technically absurd. Then the election was called, and everything froze.”

While Barry acknowledged that the Government’s intention to act is a positive step, he questioned why the route had changed. “The question people should be asking their MPs is this: if the last government could do this with the stroke of a pen, why does it now require full primary legislation? It seems like an overly bureaucratic route to fix something that everyone agrees is outdated.”

He also highlighted the inconsistencies and legal ambiguities that have long plagued suppressor regulation. “You can buy a moderator for your air rifle without a licence, no problem. But use that exact same suppressor on a .22 rimfire, and suddenly you need an FAC. It’s the same piece of kit. That’s the kind of inconsistency that makes the system look ridiculous.”

Beyond moderators, Barry warned that the current legislative framework leaves many technical grey areas unaddressed. “What about flash hiders? These are inert pieces of steel fitted to the end of a barrel and designed to reduce muzzle flash on firearms. Currently, they are classed the same as sound moderators, i.e. firearms in their own right. Given that they are often confused with muzzle brakes, which are not controlled, it really makes little sense if they are not also included in this legislative reform”.

Asked what the trade can do next, Barry urged businesses and individuals to raise the issue with MPs. “This change was promised. Everyone - government, law enforcement, Home Office - agreed it was sensible. So why the delay? The only way to keep pressure on is to keep raising our voices.”

Looking ahead, he was candid about the likely pace of reform. “Yes, it could take years. Everything takes years. I’ve been involved in initiatives that started over a decade ago and we’re still waiting. That’s just the way these things go.”

Health, safety, and community confidence The Government acknowledged overwhelming support for the change on health and safety grounds. Some 95% of respondents said moderators played an important role in protecting hearing and reducing noise pollution, while 98% agreed that removing licensing controls posed no public safety risk.

Nonetheless, a minority raised concerns about possible criminal misuse, particularly in relation to poaching. The Government concluded such risks were minimal and would be mitigated by the continued requirement to hold a firearm certificate.

AIRGUNS

Although the reform applies across the UK, moderators for airguns in Scotland will remain regulated under the Air Weapons and Licensing (Scotland) Act 2015. The Scottish Government has indicated it is reviewing this position in light of the Home Office’s decision.

Airguns classified as Section 1 in England and Wales may also present challenges under the licensing framework.

NEXT STEPS

Within the trade, there is already growing frustration over the lack of clarity around implementation. GTA Council members have raised concerns about the speed at which the proposed reform will be implemented. While the Home Office has stated that changes will be made “when parliamentary time allows”, members believe this phrasing highlights an unacceptable lack of urgency. The GTA is calling for stronger pressure to be applied to the Government to confirm when, and how quickly, the reform will be enacted.

The Home Office will launch a public consultation this summer covering a broad range of firearms regulatory issues, including the convergence of section 1 and section 2 licensing, the private sale of firearms and testing and import controls for blank-firing guns, raising concerns within the trade that moderator reform may be deprioritised amid these wider legislative priorities.

Stephen also highlighted some remaining uncertainties: “There are still grey areas. What about muzzle brakes or flash guards, will those be caught by the new definition? These are technical points that need to be addressed in the draft legislation.”

The GTA will be commenting further on the implications of this reform in due course.

You can read the full government report here: https://www.gov.uk/government/consultations/firearms-licensing-sound-moderators