Policy Memorandum


Legislative changes needed to improve the Common Sense Firearms Licensing Act which ought to be implemented early in the 42nd Parliament

Policy Memorandum No.:


Replaces (if applicable):


To be read with (if applicable):


Passed by Policy Committee:

23 September 2015

Passed by Board of Directors

23 September 2015


To seek legislative change to s. 19(2.1) of the Firearms Act to expand the Automatic Authorizations to Transport to the whole of Canada and to remove the reference to the need for the licence to be renewed.

Rationale and Discussion:

On 2 September 2015, subsection 2(1), sections 6 and 11, and subsection 13(1) of the Common Sense Firearms Licensing Act, S.C. 2015, c. 27, came into force (Order Fixing September 2, 2015 as the Day on which Certain Provisions of the Act Come into Force, S.I./2015-0080 (2015) C. Gaz. II, 2634). As a result, s. 19(2) of the Firearms Act, S.C. 1995, c. 39, was amended to provide that (at new s. 19(2.1)) “an individual who holds a licence authorizing the individual to possess prohibited firearms or restricted firearms must, if the licence is renewed, be authorized to transport them within the individual’s province of residence (a) to and from all shooting clubs and shooting ranges that are approved under section 29; (b) to and from any place a peace officer, firearms officer or chief firearms officer is located, for verification, registration or disposal in accordance with this Act or Part III of the Criminal Code; (c) to and from a business that holds a licence authorizing it to repair or appraise prohibited firearms or restricted firearms; (d) to and from a gun show; and (e) to a port of exit in order to take them outside Canada, and from a port of entry.”

The wording of the Common Sense Firearms Licensing Act leaves two things to be desired.

First, the AATT is expressly limited to the licence holder’s province of residence (which is contrary to s. 63(1) of the Firearms Act, which makes all licences and authorizations, other than Authorizations to Carry, valid throughout Canada). Second, the strict interpretation of s. 19(2.1) would only apply AATTs upon renewal of RPALs, such that first-time RPAL holders would not get the benefit.

There is no principled public safety reason for either of these issues, and the CCFR submits that immediate legislative change is desirable.