Firearms Licence Revocations & Refusals

When the Chief Firearms Officer Says No

Most PAL and RPAL holders never deal with the Chief Firearms Officer (CFO) beyond a renewal form. When they do, it usually arrives without warning: a letter saying the licence is revoked, an application refused, or the owner’s authority to use and acquire firearms suspended. For hunters, sport shooters, collectors, and farmers, that letter puts a whole collection at risk.

Revocations and refusals are administrative decisions under the Firearms Act, not criminal convictions, but the deadlines are short. Parliament has amended this area several times recently, and guidance that was accurate two years ago is out of date.

This page covers eligibility, the notice, the first days, and the route to court. For the broader picture, see our firearms licensing overview.

How Eligibility and Revocation Work

The Section 5 Eligibility Test

Section 5(1) of the Firearms Act sets the core test: a person is not eligible if it is desirable, in the interests of the safety of that person or any other person, that they not possess firearms or ammunition.

Section 5(2) lists factors that the CFO (or a judge on a reference) shall have regard to. It is not an automatic bar. The factors include whether the person:

• Has been convicted or discharged of an offence involving violence, an offence under the Firearms Act or Part III of the Criminal Code, criminal harassment, or certain drug trafficking offences
• Has been treated for a mental illness associated with violence or threatened or attempted violence
• Has a history of violence, threatened or attempted violence, or threatening conduct, including threats made online
• Is or was subject to a no-contact or keep-away order made for someone’s safety, and poses or could pose a risk
• For any other reason, poses a risk of harm to any person

There is no fixed “five-year rule”. The question is always public safety on the whole picture.

Suspension, Revocation, and Refusal

• Suspension (s. 69.1). In force since March 7, 2025. If the CFO has reasonable grounds to suspect that you are no longer eligible, they must suspend your authorization to use, acquire, and import firearms for up to 30 days. You keep your firearms but cannot use or buy them.
• Revocation (s. 70). The CFO may revoke “for any good and sufficient reason”, including ineligibility, breach of a licence condition, a non-restricted transfer without licence verification, use or acquisition during a suspension, or a conviction or discharge for an offence listed in s. 5(2)(a).
• Refusal (s. 68). The CFO shall refuse a licence to someone who is not eligible.

Domestic Violence and Protection Orders After Bill C-21

Former Bill C-21 (S.C. 2023, c. 32) added intimate partner and family violence provisions. Their status matters:

• Mandatory revocation (s. 70.1), in force April 4, 2025. If the CFO has reasonable grounds to suspect that a licence holder may have engaged in an act of domestic violence or stalking, the CFO must revoke within 24 hours. “Domestic violence” is defined broadly and includes non-criminal conduct such as psychological or financial abuse and coercive control.
• Ineligibility (s. 6.1). A person convicted of an offence involving violence against an intimate partner or family member is ineligible. Since July 18, 2026, the Protecting Victims Act (S.C. 2026, c. 19) also makes a person ineligible if the CFO has reasonable grounds to suspect domestic violence or stalking.
• Protection orders (ss. 6.1(a) and 70.2). The Act provides for automatic revocation on a protection order, but the s. 2(1) definition of “protection order” had not been brought into force as of September 2026, and a transitional provision limits these sections to orders made after it is. For now, a protection order is weighed as a safety factor under s. 5 rather than triggering automatic revocation.
• Sustenance exception (s. 70.3). A person caught by ss. 6.1, 70.1, or 70.2 may, in prescribed circumstances, get a conditional licence if they need a firearm to hunt or trap to sustain themselves or their family.

Continuous Eligibility Screening

Licence holders are screened throughout the life of the licence. When a holder is involved in a police incident of a kind listed in s. 5, a Firearms Interest Police (FIP) report goes to the CFO for review. No charge is required; a domestic call or wellness check can be enough. That is why many clients first hear from the CFO weeks after an incident they thought was over.

What Triggers a Review

Common triggers include charges for domestic assault, uttering threats, criminal harassment, or weapons offences (even if later withdrawn); domestic calls without charges; complaints from a partner, ex-partner, or neighbour; mental health events; peace bonds, bail conditions, or family court orders; storage findings; and omissions on an application or renewal.

The Notice and the First Days

What the Notice Must Say

Under s. 72, a refusal or revocation notice must give reasons disclosing the nature of the information relied on and include a copy of ss. 74 to 81 (your right to go to court). The CFO may withhold information whose disclosure could endanger someone’s safety.

A revocation notice must also tell you to deliver every firearm, prohibited or restricted weapon, prohibited device, and prohibited ammunition you possess to a peace officer, a firearms officer, or the CFO within 24 hours or, if that is not possible, within an extended period set by the CFO. During that window, the unauthorized-possession offences in ss. 91, 92, and 94 of the Criminal Code do not apply to you. After it closes, they can.

Two points are often misunderstood:

• The wording tightened on July 18, 2026. Before that date, s. 72(4) said the holder may deliver firearms within 24 hours. It now says the holder must. Older guidance describing a longer window to sell or transfer on your own schedule no longer reflects the Act.
• Starting a court challenge does not pause the delivery requirement. Under s. 72(6), if you refer the decision to a judge, you still have to deliver your firearms to a peace officer within the same period.

What to Do

1. Read the notice carefully and note the date you received it. The 30-day limit for a court reference runs from receipt.
2. Get advice immediately. The delivery window is measured in hours, not weeks.
3. If 24 hours is not realistic, ask the CFO for an extended period in writing, for example for a large collection or a remote property.
4. Inventory and photograph everything (makes, models, serial numbers, registration numbers), and tell police in advance that you are delivering firearms to comply with a CFO notice.

What Not to Do

• Do not ignore the deadline. Once the delivery period ends, possession can be charged as unauthorized possession under s. 91 or s. 92 of the Criminal Code. It is not charged under s. 117.01, which deals with breaching a court prohibition order.
• Do not quietly move firearms to a friend’s house. Handing firearms to someone else without the paperwork and approvals the law requires can create new offences for both of you.
• Do not discuss the underlying incident with a CFO investigator before getting advice, particularly if charges are outstanding.

Surrender, Transfer, or Storage

Under the current s. 72(4), delivery to a peace officer, firearms officer, or the CFO comes first. Sale or transfer to a licensed individual or business usually happens after surrender, through the police holding the firearms or, if a reference fails, under a court order. Under s. 72(7), a judge who confirms the CFO’s decision may order the firearms returned to you so you can dispose of them lawfully. Section 72(10) then gives you 30 days to do so.

Where the CFO is still investigating and has not yet revoked, there is sometimes room to propose alternatives. These can include voluntary third-party storage with a licensed individual or business, or licence conditions under s. 58. Whether that is realistic depends on the facts.

Our Approach

1. Stabilize the Deadline

We confirm the date of receipt, request any needed extension, and make sure you comply on time, so a licensing problem does not become a criminal charge.

2. Get the Record

We obtain what the CFO relied on: FIP reports, occurrence reports, and investigator notes. These are often one-sided summaries that leave out context.

3. Engage the CFO Before It Hardens

Where a suspension or investigation is under way, a timely written submission with context, references, and medical information can sometimes resolve the concern before revocation.

4. Coordinate With Any Criminal Case

If the review follows a charge, the licensing file and the criminal file have to move together. What you say to a firearms officer can be used in the criminal case, and a bail condition or peace bond can affect your eligibility. Jaime Mor and Peter Kott handle both sides.

5. Take It to Court

If the CFO will not change course, we bring a Section 74 reference in the Ontario Court of Justice. It must be filed within 30 days of receiving the notice, or within further time a judge allows. At the hearing, the burden is on you to show the decision was not justified (s. 75(3)). The judge may confirm the decision, direct the CFO to issue the licence, or cancel the revocation (s. 76).

Collateral Consequences

• Your firearms. After an unsuccessful challenge they must be disposed of, and handguns now have very limited resale options.
• Future applications. A revocation stays on your licensing history.
• Employment. Guides, security staff, farmers, and others whose work depends on a licence may lose income immediately.
• Criminal exposure. Keeping firearms after the delivery period is an offence in its own right.

Related Resources

• Firearms Licensing Overview: the hub page for PAL applications, revocations, and prohibition orders
• Section 74 Reference Hearings: how a revocation or refusal is challenged in court
• Firearms Compliance: Storage, Transport & Registration: the rules whose breach often starts a review

If you have received a suspension, revocation, or refusal notice, the time limits are already running. Contact Mor Fisher LLP at 705-721-6642 or through our contact page to review your notice and plan your next steps.