The UK Government’s intention to consult on merging Section 1 and Section 2 licensing represents one of the most significant developments for the gun trade in a generation. As the Home Office prepares to open a consultation on the proposal, the trade will need to be ready to respond quickly and with detailed evidence.
1. HOW A CONSULTATION BEGINS
Consultations sit at the heart of the policymaking process. Before Government departments settle on a final position, they are expected to gather views from those likely to be affected. Consultations provide a structured way to do this. They normally begin with the publication of a consultation document outlining the scope of the proposal, the Government’s reasoning, and a series of questions designed to guide responses.
Although past consultations often ran for twelve weeks, the indication for the proposed firearms licensing consultation is that the window may be limited to ten weeks. This reduces the margin for delay and means the trade must be prepared to act promptly once the process opens.
2. WHO CAN RESPOND
Government consultations are open to anyone. In practice, the Home Office expects to receive submissions from individuals, businesses and organisations with direct experience of the licensing system. For the shooting industry, this will include RFDs, shooting grounds, sporting estates, manufacturers, distributors and trade associations.
The British Shooting Sports Council (BSSC) will submit its own detailed response in addition to contributions from its 15 member bodies. The Gun Trade Association will also support members in preparing submissions and will work to raise awareness across the trade of what the proposal may mean for day-to-day business.
3. WHAT A RESPONSE SHOULD CONTAIN
The Home Office is required under Government rules and equality duties to assess the impact of any proposed change on existing businesses and communities. For the trade, this makes the economic and operational implications of convergence a central part of any submission. Evidence-based feedback carries particular weight. This may include data on certificate processing times, staff costs associated with compliance, customer behaviour, potential reductions in sales and the wider effect on rural economies.
Responses can be submitted through online forms or by email. There is no required format beyond clear, relevant information that answers the issues raised in the consultation document.
4. GUNNING PRINCIPLES: THE RULES THE HOME OFFICE MUST FOLLOW
All government consultations must comply with the four Gunning principles, which act as the legal test for fairness:
• consultations must be launched when policy is still at a formative stage
• consultees must be given sufficient information to respond meaningfully
• adequate time must be allowed for responses
• all responses must be conscientiously taken into account
Courts have repeatedly upheld these principles through judicial review. If a Department of State fails to meet them, its decisions can be challenged.
5. BEHIND-THE-SCENES ENGAGEMENT
Alongside formal consultation, there is often informal engagement between government officials and representative bodies. These discussions can be useful for clarifying technical points and ensuring officials understand the practical realities of implementing a proposal. Whether such engagement occurs is entirely at the Home Office’s discretion. Any contact must be handled through established channels and should not bypass the officials responsible for the consultation.
6. AFTER THE CONSULTATION CLOSES
Once the consultation period ends, the Home Office will review every submission. The time required to publish a government response depends heavily on the volume of material received. Although the intention may be to publish a response early next year, high levels of engagement could delay this.
The Government response will summarise the views received and set out the Department’s proposed next steps. If the Home Office recommends convergence, the issue may then move into the political arena. At that stage parliamentarians, specialist committees and the media play a greater role.
7. WHAT HAPPENS IF GOVERNMENT PROCEEDS WITH HARMONISATION OF SECTIONS 1 AND 2
If the Home Office recommends change, further stages follow before any legislative proposal reaches Parliament. Amending legislation could take many months to table and would be subject to scrutiny in both Houses. Business managers in the House of Commons control the timetable and may delay or prioritise the bill depending on wider parliamentary pressures.
Stakeholder organisations may seek to work with Parliamentarians to examine the details of the bill, highlight areas of concern and suggest amendments. The House of Lords, in particular, has considerable scope to revise or delay legislation. Support from peers with an interest in the countryside, policing or regulatory issues can influence the progress of a bill. Campaigning activity outside Parliament may also increase at this point, including Parliamentary Questions, Select Committee interest and national media coverage.
Some shooting organisations may additionally consider petitions or wider public engagement to draw attention to the implications for rural jobs, trade and participation. As the proposal would have a direct impact on licensing workloads, it is possible that policing organisations or frontline representatives could also take an interest.
8. REALISTIC EXPECTATIONS
It is important to recognise that a Government with a large Parliamentary majority retains the ability to pass legislation even in the face of opposition from stakeholders. While sustained pressure can influence the detail of a bill, it may not prevent legislation if the Government is determined to act. In the event that harmonisation of Sections 1 and 2 becomes law, any challenges are likely to be limited and costly.
9. WHY TRADE ENGAGEMENT MATTERS
For now, the consultation is the decisive stage. It is the point at which the trade can present clear evidence about the economic and operational consequences of harmonisation. Strong, informed submissions will give the Home Office a detailed understanding of the proposal’s real-world impact and ensure the trade’s position is fully recorded.
With a truncated consultation window expected, prompt preparation and coordinated action across the industry will be essential. The consultation is not a formality. It is the moment at which the Home Office must listen. The strength of the trade’s input at this stage will help shape the direction of policy.
The Gun Trade Association is already leading discussions with other key stakeholders – BASC, CPSA, NRA, BSSC and the Countryside Alliance – to establish a national campaign co-ordinating hub. With support from the Shooting Industry Fund, this hub is being set up to prepare for a potential worst-case scenario: namely, that the Government recommends legislation to drive through Sections 1 and 2 harmonisation.
CONSULTATION PROCESS: STEP-BY-STEP FLOW
1. GOVERNMENT SIGNALS INTENT
The Home Office announces that a policy proposal is being considered.
Often accompanied by: call for evidence, green paper or early communication. →
2. CONSULTATION FORMALLY LAUNCHED
Documents published on gov.uk setting out:
• scope of the proposal
• background information
• questions for respondents
• deadline for submissions →
3. CONSULTATION WINDOW
Public and stakeholders respond through:
• online forms
• written submissions
• evidence from trade bodies
• sector-specific data or case studies Government must allow adequate time under the Gunning principles. →
4. RESPONSES GATHERED AND REVIEWED
Officials analyse submissions, identify common themes, assess evidence and produce internal summaries. Home Office must demonstrate that responses are taken into account. →
5. GOVERNMENT RESPONSE PUBLISHED
A formal report summarises what respondents said and explains the department’s next steps.
This is normally published within 12 weeks of the consultation closing. →
6. POLICY DECISION AND NEXT STAGE
Depending on the outcome, government may:
• revise the proposal
• proceed to legislation
• conduct further targeted engagement
• abandon or defer the proposal →
7. LEGISLATIVE PROCESS (IF REQUIRED)
If the policy requires primary legislation, it proceeds through the full Parliamentary process.
If secondary legislation is used, it follows the relevant statutory procedure