Firearms licensing: proposal to remove sound moderators from firearms licensing controls - government response (accessible)
Updated 17 June 2025
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This publication is available at https://www.gov.uk/government/consultations/firearms-licensing-sound-moderators/outcome/firearms-licensing-proposal-to-remove-sound-moderators-from-firearms-licensing-controls-government-response-accessible
June 2025
1. Introduction
1.1 This document provides a summary of responses to the consultation paper ‘Proposal to use a Legislative Reform Order to remove sound moderators from firearms licensing controls’, published by the Home Office on 21 February 2024.
1.2 It covers:
- the background to the consultation,
- a summary of the consultation responses,
- a detailed response to the specific questions raised in the consultation, and
- the next steps following this consultation.
2. Background
2.1 The previous Government published a public consultation paper on 21 February 2024 to seek views on its proposal to reform legislation governing the possession of a firearm accessory known as a sound moderator. The consultation paper explained that the Government at the time was minded to make this change through a Legislative Reform Order (LRO) under the Legislative and Regulatory Reform Act 2006.
2.2 A LRO is a statutory instrument which can amend primary legislation, independently of a Parliamentary Bill. A LRO is de-regulatory in nature and can be used to remove or reduce burdens resulting from legislation or to improve the way regulatory functions are carried out. The Government therefore sought views through the consultation on whether the proposal to de-regulate the controls relating to sound moderators met the criteria for making a LRO.
2.3 Sound moderators are currently controlled under section 57(1)(d) of the Firearms Act 1968 which includes, in the definition of firearms:
an accessory to a lethal barrelled weapon or a prohibited weapon where the accessory is designed or adapted to diminish the noise or flash caused by firing the weapon.
Sound moderators are also mentioned in section 57(4) which sets out the interpretation of various terms used in the 1968 Act as follows:
shot gun” has the meaning assigned to it by section 1(3)(a) of this Act and, in sections 3(1) and 45(2) of this Act and in the definition of “firearms dealer”, includes any component part of a shot gun and any accessory to a shot gun designed or adapted to diminish the noise or flash caused by firing the gun.
2.4 A sound moderator can be attached to a rifle barrel to reduce the sound and flash when the rifle is fired. It is essentially a threaded tube which fits on or over the end of a rifle barrel and works by trapping and slowing down the gases produced by the propellant when the rifle is fired to eliminate the muzzle blast of the shot. It does not fully silence the ‘crack’ of the bullet but reduces the audible sound of the rifle by around three quarters. Sound moderators are used to protect shooters’ hearing, to reduce the disturbance to others in the vicinity of shoots and to stop shooters being temporarily blinded by the muzzle flash of a shot. They are often fitted to firearms that are used in the control of vermin on farmland to prevent the spreading of disease among farm animals. They are entirely inert objects and contain no moving parts and do not of themselves create a risk to public safety. However, the practical effect of section 57(1)(d) of the Firearms Act 1968 is that a firearms certificate from the police is currently required in order to possess a sound moderator.
The Consultation
2.5 The consultation paper sought views on whether the requirement to obtain a certificate from the police in order to acquire and possess a sound moderator should be removed. The proposal set out in the consultation was that in order to achieve this outcome, the LRO would remove section 57(1)(d) and associated provisions from the Firearms Act 1968, which would thereby remove sound moderators from the legal definition of a firearm. This would mean that, in future, a person would not need to obtain a firearms certificate for the purposes of having authority to obtain or possess a sound moderator.
2.6 The consultation ran for six weeks and concluded on 2 April 2024. A total of 19,277 responses were received, whether by completing the online survey, or by sending responses to the Home Office by post or email. 4,665 partially completed online survey responses are omitted on the basis that the respondent did not reach the end of the survey to confirm they were ready to formally submit their response. Of those who completed the online survey, 4,995 responses provided comments in the ‘free text’ box included as part of the online survey before the consultation formally closed. The free text box provided those who responded to the survey an opportunity to provide any additional comments on the subject matter of the consultation. Every comment that was made in response to the consultation has been read by officials in the Home Office to ensure that everybody’s views were considered when preparing this response to the consultation. We are grateful to all those who responded, and we appreciate the time taken by a wide range of individuals, bodies and groups to provide their views.
The Government response
2.7 This paper provides a summary of the responses received to the consultation and sets out the next steps that the Government intends to take.
3. Summary of the consultation responses
3.1 We received a total 19,277 responses to the consultation, comprising 14,587 completed online survey responses, 4,665 partial responses, 21 responses by e-mail and 4 responses by post. Partially completed online survey responses are omitted on the basis that the respondent did not reach the end of the survey to confirm they were ready to formally submit their response.
3.2 Responses came in various formats as summarised in the table below:
| Response formats | Number of responses |
|---|---|
| Completed online responses | 14,587 |
| Email responses | 21 |
| Postal responses | 4 |
| Total responses analysed | 14,612 |
| Incomplete online responses | 4,665 |
3.3 Those responding to the consultation were asked to self-select the category of respondent that best described them, as set out in the table below. Those who did not consider that they fell into one of the first seven categories were able to select the group ‘Other’.
| Category | Number of responses | Percentage |
|---|---|---|
| Shotgun/firearms certificate holder | 12,471 | 85% |
| Member of the public | 1,398 | 10% |
| Registered firearms dealer | 381 | 2.6% |
| Police/law enforcement | 85 | 0.6% |
| Representative shooting body | 36 | 0.2% |
| Rural organisation | 14 | 0.1% |
| Community/Third Sector/Gun control | 9 | 0.1% |
| Other | 218 | 1.5% |
| Total | 14,612 | 100% |
3.4 The definitions below were included in the consultation paper to assist respondents in identifying the category which best described them:
- ‘Shotgun/firearms certificate holder’ includes those who self-reported to be a certificate holder and who responded to the consultation on that, rather than any other, basis.
- ‘Registered firearms dealer’ includes those who self-reported to be a dealer registered with the police and who responded to the consultation in that capacity.
- ‘Member of the public’ includes those who did not fall into any of the other categories listed.
- ‘Police/law enforcement’ includes those who self-reported as responding in an official capacity on behalf of a policing or law enforcement body, such as a police force or the National Police Chiefs’ Council.
- ‘Community/Third Sector/Gun control’ includes those who self-reported as responding to the consultation on behalf of a body or organisation that fell within this category.
- ‘Rural organisation’ includes those who self-reported as responding on behalf of a body that represents or champions rural interests.
- ‘Representative shooting body’ includes those who self-reported responding to the consultation on behalf of such a body.
- ‘Other’ includes all those who did not consider that they fell into any of the other categories listed.
4. Responses to specific questions
Introduction
4.1 In this chapter, we summarise responses to the four questions that were posed in the consultation paper, broken down by type of respondent. The total number of responses varies by question, as some respondents did not provide a response to every question.
4.2 The number of people who responded ‘agreed’ or ‘strongly agreed’, shown in the chart as proportions, are provided in brackets alongside each group. To see the total number of respondents in each group, please refer back to the table in section 3.3.
Q1. To what extent do you agree or disagree that the requirement to obtain a certificate from the police in order to acquire and possess a sound moderator should be removed?
94% of those who responded to this question either agreed or strongly agreed that the requirement to obtain a certificate from the police in order to acquire and possess a sound moderator should be removed. 6% either disagreed or strongly disagreed and 1% neither agreed nor disagreed. The number who either agreed or strongly agreed are shown as numbers and percentages by respondent group below:
Responded ‘agreed’ or ‘strongly agreed’
| Respondent group (number) | Percentage |
|---|---|
| Representative of shooting body (35) | 97% |
| Registered firearms dealer (363) | 95% |
| Shotgun/firearms certificate holder (11,709) | 94% |
| Member of the public (1,311) | 94% |
| Representative of police/law enforcement body (78) | 92% |
| Other (199) | 91% |
| Community/third sector/gun control (8) | 89% |
| Rural organisation (9) | 64% |
| Overall response (13,712) | 94% |
Q2. To what extent do you agree or disagree that there is no risk to public safety in removing sound moderators from licensing controls?
98% of those who responded to this question either agreed or strongly agreed that there is no risk to public safety in removing sound moderators from licensing controls. 2% either disagreed or strongly disagreed and 1% neither agreed nor disagreed. The number who either agreed or strongly agreed are shown as numbers and percentages by respondent group below:
Responded ‘agreed’ or ‘strongly agreed’
| Respondent group (number) | Percentage |
|---|---|
| Representative of shooting body (36) | 100% |
| Registered firearms dealer (375) | 98% |
| Shotgun/firearms certificate holder (12,196) | 98% |
| Member of the public (1,354) | 97% |
| Other (210) | 97% |
| Community/third sector/gun control (8) | 89% |
| Representative of police/law enforcement body (75) | 88% |
| Rural organisation (12) | 86% |
| Overall response (14,266) | 98% |
Q3. To what extent do you agree or disagree that the health and safety benefits of using sound moderators are important?
95% of those who responded to this question either agreed or strongly agreed that the health and safety benefits of using sound moderators are important. 2% either disagreed or strongly disagreed and 3% neither agreed nor disagreed. The number who either agreed or strongly agreed are shown as numbers and percentages by respondent group below:
Responded ‘agreed’ or ‘strongly agreed’
| Respondent group (number) | Percentage |
|---|---|
| Representative of shooting body (35) | 97% |
| Registered firearms dealer (366) | 96% |
| Shotgun/firearms certificate holder (11,874) | 95% |
| Other (206) | 94% |
| Member of the public (1,316) | 94% |
| Representative of police/law enforcement body (77) | 92% |
| Community/third sector/gun control (8) | 89% |
| Rural organisation (11) | 79% |
| Overall response (13,893) | 95% |
Q4. To what extent do you agree or disagree that the criteria for making a Legislative Reform Order have been met?
96% of those who responded to this question either agreed or strongly agreed that the criteria for making a Legislative Reform Order for the purpose of removing sound moderators from firearms licensing controls have been met. 1% either disagreed or strongly disagreed and 3% neither agreed nor disagreed. The number who either agreed or strongly agreed are shown as numbers and percentages by respondent group below:
Responded ‘agreed’ or ‘strongly agreed’
| Respondent group (number) | Percentage |
|---|---|
| Representative of shooting body (36) | 100% |
| Registered firearms dealer (371) | 98% |
| Shotgun/firearms certificate holder (11,905) | 96% |
| Member of the public (1,316) | 95% |
| Representative of police/law enforcement body (77) | 91% |
| Other (196) | 90% |
| Rural organisation (12) | 86% |
| Community/third sector/gun control (7) | 78% |
| Overall response (13,920) | 96% |
Additional comments
4.3 Those responding to the consultation were also asked whether they had any additional comments on the subject matter of the consultation. We have included the substance of these responses, where they relate directly to the subject matter of the consultation, in the analysis of responses set out in the next chapter of this paper.
5. Consultation outcomes
5.1 The Government has carefully considered the responses to the consultation and has reflected on the proposals that it set out. The consideration is set out below.
Should sound moderators be removed from firearms licensing controls?
5.2 There was very strong support for the proposal amongst those who commented on this question. Many respondents saw little purpose now in the requirement to obtain a variation to a firearms certificate in order to possess a sound moderator, given that these items were not component parts of a firearm and were not in any way dangerous in themselves. It was noted that those who used sound moderators lawfully would already have been subject to police suitability checks before obtaining their firearms certificate.
5.3 A number of respondents considered that it should remain a requirement to show a valid firearms certificate before being able to purchase a sound moderator from a Registered Firearms Dealer. It was suggested that this could help prevent these items making their way into the hands of criminals and being used with illegally held firearms, including illegally held handguns, for criminal purposes.
5.4 Many respondents also drew attention to the savings in police time that would arise if they were no longer required to administer variations to firearms certificates each time a firearms certificate holder acquires a sound moderator or disposes of one.
5.5 Some respondents were concerned that sound moderators are pressure bearing and that any deregulation could therefore lead to the supply of substandard sound moderators which could present unforeseen dangers to shooters. It was suggested that there should therefore remain some regulation of the market for these items.
5.6 Finally in relation to this question, some respondents made the point that, whatever the arguments for or against the de-regulation of sound moderators, any relaxation of firearms controls should be resisted, and that there could remain some value in the police making checks to ensure that those seeking a variation of their firearms certificates had a genuine and continuing need to possess a sound moderator.
Would removing sound moderators from firearms licensing controls create any risks to public safety?
5.7 The overwhelming majority (98%) of those who responded to this consultation question considered there to be no public safety risks in removing sound moderators from firearms licensing controls. Many agreed with the point set out in the consultation document that sound moderators contain no moving parts and are not of themselves dangerous.
5.8 Many respondents also questioned whether there was any evidence to show that sound moderators had ever featured in crimes involving firearms, including illegally held firearms. Others, however, questioned whether the proposed deregulation of sound moderators might make it easier for criminals to acquire these items, and for them to begin to feature more in firearms-related crime. It was noted that firearms fitted with sound moderators, and particularly small calibre rimfire rifles with subsonic ammunition, could make it easier for poachers and others to conduct criminal activity, or for more crimes involving firearms to go unreported because a reduction in sound results in fewer witnesses or numbers hearing the shot. It was also noted that reduced noise levels could also make it more difficult to identify the location of a shooting incident, potentially hindering a police response to an active incident.
5.9 Some considered that the risks highlighted above outweighed the potential savings to the police and to certificate holders that would follow from deregulation. It was suggested that these risks might, in part at least, be mitigated by retaining a requirement to present a valid firearms certificate when purchasing a sound moderator, to help ensure that they were only obtained by those with a legitimate purpose to possess.
Are the health and safety benefits of using sound moderators important?
5.10 A large number of respondents referred to the benefits of protecting the shooter’s hearing that arise from the use of sound moderators, with many noting the detrimental effect to their hearing of shooting over many years without access to sound moderators.
5.11 A minority of respondents suggested that there was a flipside to these benefits, in that dampening the sound of the firearm could pose a danger to others in the vicinity who might not be aware that shooting was taking place nearby for example, by a farmer shooting vermin in order to protect crops. While acknowledging the potential health and safety benefits, some were concerned about the activities of those who might seek to exploit the dampening of the sound of shooting, i.e. poachers and other criminals, with the suggestion that the health and safety benefits afforded by sound moderators could be achieved in other ways, such as through the use of ear plugs or ear defenders. These could provide the same protection for the shooters hearing, while not masking the sound of illicit activity.
Have the criteria for making a Legislative Reform Order been met?
5.12 Many commented that this seemed to be a good way to remove an unnecessary burden on firearms certificate holders and the police with some questioning why this had not been proposed before.
Conclusions
5.13 Having given fresh consideration to this issue, the Government is of the view that there are strong arguments in favour of removing sound moderators from firearms licensing controls. As set out in the consultation paper, these items are a firearms accessory that present no danger in themselves to the public.
5.14 The Government has taken account of views of those who suggested that the removal of sound moderators from firearms licensing controls could give rise to public safety risks. These views are summarised in paragraphs 5.8 and 5.9 above. The Government has given full consideration to these issues. While we do not consider that the removal of sound moderators from firearms licensing controls will increase the risk to public safety, bearing in mind that this device does not mean that the sound of the discharge disappears altogether, we do see merit in the suggestion, set out in paragraphs 5.3 and 5.9 above, that any potential public safety risk would be reduced by a requirement to have a valid firearms certificate in order to lawfully possess a sound moderator. 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 help ensure that they were only held by those with a legitimate purpose, as demonstrated by the possession of a valid firearms certificate.
5.15 The Government does not consider it to be appropriate to use a Legislative Reform Order, made under section 1 of the Legislative and Regulatory Reform Act 2006, to remove sound moderators from firearms controls. While this change can be viewed as a matter of de-regulation, the proposal is in fact to change the statutory definition of firearm as set out in section 57 of the Firearms Act 1968. The objective will be achieved by removing section 57(1)(d) and related provisions from the Firearms Act 1968, while also amending that Act to make it an offence for a person to possess a sound moderator unless that person is in possession of a firearm certificate allowing for lawful possession of a firearm. The Government is of the view that the proper course would be to make these statutory changes through primary legislation, and we will seek to make this change when Parliamentary time allows.
6. Scotland
6.1 The Government’s intention to remove sound moderators from firearms licensing controls will apply to firearms licensing in England, Wales and Scotland.
6.2 Air weapons are subject to licensing controls in Scotland through the Air Weapons and Licensing (Scotland) Act 2015. Section 1(3)(b) of this Act explicitly includes sound moderators in the definition of air weapon in Scotland. This will mean that, once the statutory changes set out in the preceding chapter are made, sound moderators for firearms will no longer be controlled in Scotland but sound moderators for air weapons will continue to be subject to licensing controls.
6.3 The Scottish Government is currently considering whether any changes are required to the controls on air weapons in Scotland as a consequence of the intended removal of sound moderators from firearms licensing controls in England, Wales and Scotland.