As introduced, proposed section 38D would allow an application to be made for a certificate of approval for a pistol shooting club by:

• an authorised person if the pistol shooting club is a body corporate

• an authorised club representative if the pistol shooting club is not a body corporate.

However, we note that proposed section 38C would require a pistol shooting club to be an incorporated society. Given this requirement, we recommend amending proposed section 38D(1) to remove the second option above and make clear that only a person authorised by the pistol shooting club could apply for a certificate of approval on the club’s behalf.

Proposed section 38XD would require a non-pistol shooting club that is organising a shooting activity at a temporary non-pistol shooting range to notify the Police Commissioner of that activity. This means that only non-pistol shooting clubs could operate a temporary non-pistol shooting range. It would exclude individuals who are likely to have relevant experience in running safe shooting ranges from organising events at temporary non-pistol shooting ranges.

We recommend replacing proposed section 38XD(1) with a provision specifying that the persons who could operate a temporary non-pistol shooting range are:

• a shooting club

• a member of a shooting club

• an operator of a certified pistol shooting range

• an operator of an enrolled non-pistol shooting range.

The bill would replace approval requirements for non-pistol clubs and ranges with a system of enrolment. The bill would not require non-pistol shooting ranges to have range standing orders, but we understand that this requirement would be included in regulations. To afford certainty, we recommend inserting, in proposed section 38XE(2), a requirement that a non-pistol shooting range include in its application for enrolment a declaration that it has range standing orders. These range standing orders must be approved by the association the range is affiliated with or the Police.

Resource consent and range enrolment are both needed for a non-pistol shooting range to legally operate. However, the bill as introduced does not mention the need for a non-pistol shooting range to confirm that it has obtained the necessary resource consents when applying for enrolment. We see a risk that this silence could give rise to the misconception that a non-pistol shooting range did not need a resource consent to operate, provided it was enrolled.

We therefore recommend inserting a new provision in proposed section 38XE(2) requiring that a non-pistol shooting range include a declaration in its enrolment application that all necessary territorial authority and regional council consents to operate the range have been obtained.

Clause 10 of the bill would add a new Part 4 to Schedule 1 of the Act, which contains transitional, savings, and related provisions. This new Part would provide that non-pistol shooting clubs that are approved, and non-pistol shooting ranges that are certified, before the commencement date of the bill are to be treated as enrolled once the bill comes into force. Some submitters raised concerns that this transitional provision would not cover applications for approval or certification that may still be pending at the commencement date.

We understand that a number of applications for approval and certification are pending. We note that pending applications for approval and certification contain all the information required for applications for enrolment proposed in the bill. Therefore, we think that requiring clubs and ranges with pending applications to reapply for enrolment would involve unnecessary duplication.

We recommend inserting further provisions in proposed Part 4 of Schedule 1 by inserting clauses 25 and 26. This would enable applications for approval and applications for certification that have been made but not yet determined before the commencement date to be treated on and after that date as applications for enrolment and certification.

Clause 12 of the bill would replace section 74(3) and (4) of the Act. This section concerns the regulation-making powers. The Regulations Review Committee suggested clarifying whether regulations made under section 74(1)(pa) would be subject to the consultation requirement in section 74(4). We agree, and recommend inserting new section 74(3)(b). This would ensure that the responsible Minister may only recommend that regulations be made under section 74 of the Act if satisfied that the Secretary for Justice has complied with the consultation requirements in section 74(4).

Proposed section 38A sets out definitions for proposed new Part 6. One definition is for “temporary non-pistol shooting range”. As introduced, it states that a temporary range could be set up for no more than 2 events in any calendar year that include shooting activities. However, it is unclear how long an event may last. Therefore, we propose defining “shooting event” as an event that lasts for no more than 4 days.

Proposed section 38XL would allow the Police to temporarily suspend the operations of a shooting club, by notice in writing, if they are satisfied that the shooting club has failed to comply with an improvement notice. However, we note that it was only intended that this power be exercised in relation to a pistol shooting club. We recommend amending proposed section 38XL to make this clear.

We have grave reservations about the impact of this bill on the safety of frontline police, small business owners, and rural landowners, such as farmers and forestry companies.

These groups are frequently confronted by offenders with firearms sourced from the black market through diversion from licensed firearms owners. These firearms are then used during aggravated robberies and illegal hunting. Police have also warned the Police Minister of gang members practising their shooting skills on unregulated shooting ranges.

The public safety risks of unregulated clubs and ranges were highlighted by the Royal Commission of Inquiry into the terrorist attack in Christchurch, currently still subject to a Coroners Inquiry. The Royal Commission found the terrorist was able to practise rapid-firing techniques on an unregulated rifle range. This bill would allow unscrupulous landowners to let criminals or extremists use their facilities. For example, in late 2024 media reports of a Police inquiry into offending by the Comancheros gang indicated members practised military-style live firing on farmland in Northland, effectively an uncertified shooting range.

This bill attempts to give the impression of regulatory oversight, but in fact undermines the ability of Police to monitor and enforce safety. There are no compliance tools of any substance; for example, there are no penalty provisions for refusing access to inspect ranges. The public and law-abiding users of shooting ranges will have no confidence that the range is operating safely or correctly.

The proposed “enrolment” system appears to return to a system pre-2019. It will be largely voluntary to follow safety practices set by the shooting governing body, with no oversight by Police and no ability for Police to enforce the rules unless breaches are drawn to their attention by a third party. The proposals will effectively limit Police inspections of clubs and ranges to once every five years, at the first application for enrolment or certification and then at the five-yearly application for renewal. The reduced ability for the Police to carry out inspections undermines the ability to enforce safety.

This bill increases the opportunity for unsupervised shooting at ranges by people without licences. It creates multiple loopholes for gang members and extremists like the Christchurch terrorist to exploit and to practice their shooting skills without Police oversight. It increases the opportunities for supply of ammunition to criminals who unlawfully hold firearms. Ammunition is a form of currency in the criminal underworld. It also creates a dangerous precedent for many landowners who will find “pop-up” shooting ranges over their back fence. There is no ability for the Police to enforce safety measures or even inspect the facilities, if there are only two events per calendar year. This is a “Wild West” approach to firearms regulation.

The Police are effectively locked out of doing inspections of either pistol ranges or non-pistol ranges for five years. They will never know if safety standards are being met during that time, or if unsupervised, unlicensed shooters are being allowed on the range, because they will not be able to visit and inspect. Pistol ranges and rifle ranges do not have a track record of self-reporting problems to the Police. Further, in June 2024, Parliament’s Petitions Committee questioned the ability of operators of shooting clubs and ranges to monitor or screen for criminals and extremists who use the facilities, and noted Police and security agencies needed oversight of club internal processes.

This bill undermines public confidence in consistency of safety standards at shooting clubs and ranges because it removes the current adherence to national standards for non-pistol (rifle and shotgun) ranges. This is at odds with pistol ranges that must use the guidance issued by the Commissioner of Police. Non-pistol ranges will be able to set their own standards, and the Police will have to inspect them against the operator’s own rules, not against any law or regulation set by Parliament. They should, at the bare minimum, be required to adhere to the ballistic safety guidelines in the Police Shooting Range Manual.

Rifles and shotguns still present a serious safety risk, despite suggestions in the bill that pistols are the more serious safety concern. The Police have publicly stated that 70 percent of firearms seized from criminals are the so-called “A-Cat” or “non-prohibited” firearms, such as ordinary hunting rifles and shotguns. The Firearms Safety Code provides insight to the lethal risks from rifles and shotguns commonly used on non-pistol ranges. Their long-range firing capacity is in marked contrast to a pistol. A bullet fired from a common deer hunting rifle, a .308, can travel 4km. A .22 rifle, common for shooting possums and rabbits, can fire rounds that travel 2.5km.

This section is quite simply a power grab by the Associate Minister of Justice from the Minister of Police. It has nothing to do with reforms to shooting clubs or ranges. It should wait for the wider review of the Firearms Registry and the whole Arms Act.

• 1.

  Require all non-pistol ranges to use the guidance (Shooting Range Manual) issued by the Commissioner of Police.

• 2.

  Enable Police to inspect any shooting range (both pistol and non-pistol), with a minimum seven-day notice period, to inspect compliance with the Police Shooting Range Manual requirements.

• 3.

  Defer the changes under the “other matters” section till the Arms Act rewrite exercise is complete, as the proposals have no relevance to shooting clubs and ranges and this bill is not the appropriate vehicle to make that change.

• 4.

  Extend the implementation date of the bill to a minimum of six months after Royal Assent, and potentially longer, to wait until the current Arms Act rewrite is complete so that oversight of shooting clubs and ranges is considered within the broader context of the wider firearms regulatory system.

Deferral of the bill would also enable Parliament to ensure it meets the principles of the Regulatory Standards Bill to be passed later this year, which are that “No law should be passed without showing what problem is being solved, whether the benefits outweigh the costs, and who pays the costs and gets the benefits.”

This bill represents a significant step backwards for Aotearoa’s firearm safety regulations. The Royal Commission of Inquiry into the Christchurch terrorist attack made it clear that robust oversight of shooting ranges and clubs is essential to prevent firearms from being misused by criminals and extremists. Weakening these regulations creates dangerous loopholes for individuals seeking to harm our communities.

From a tikanga Māori perspective:

• Mana Mokopuna: Loosening firearm regulations endangers our mokopuna by increasing access to dangerous weapons. Our role is to ensure the safety and well-being of future generations, and this bill fails to uphold that responsibility.

• Mana Ōrite: The lack of consultation with Māori communities is a failure of partnership under Te Tiriti. This bill disproportionately impacts Māori by ignoring our voices and perpetuating inequities in public safety.

• Mana Motuhake: Māori communities deserve policies that empower and protect them, not legislation designed to serve a small, privileged interest group.

The argument that this bill is necessary to reduce burdens on firearm owners is not supported by evidence. You do not need these types of guns for kai. These weapons, including those capable of rapid firing, have no place in Aotearoa and were tools of white supremacist violence in the Christchurch terrorist attack. The gunman was able to train with these firearms at an unregulated shooting range, honing techniques for mass killing. This bill risks re-creating the very conditions that allowed that devastating attack to occur.

The Christchurch terrorist attack on 15 March 2019 was the deadliest act of white supremacist violence in Aotearoa’s history, killing 51 innocent people and injuring dozens more. It was not an isolated event. Globally, white supremacist terrorism has surged, with coordinated attacks targeting marginalised communities, particularly those who are Muslim, Jewish, or people of colour.

The Royal Commission of Inquiry into the Christchurch attack revealed that the gunman’s ability to practice rapid-firing techniques on an unregulated shooting range was a critical factor in his preparation. The shooter exploited weak oversight of firearm clubs and ranges to prepare for his act of terror. Any effort to deregulate shooting clubs and ranges is a direct threat to public safety and a step backwards in the fight against domestic terrorism.

White supremacist violence is not an abstract threat—it is a lived reality for many communities in Aotearoa. This bill, by removing critical safety regulations, creates opportunities for extremists to access firearms and practise their techniques without oversight. Such deregulation undermines the safety of all communities and dishonours the memories of the victims of the Christchurch attack.

This bill fails to uphold Te Tiriti o Waitangi, particularly the Crown’s obligation for active protection of Māori communities. By removing safety measures and regulations that protect whānau from the harms of firearms, the bill breaches the Crown’s duty to safeguard Māori.

The lack of meaningful consultation further demonstrates a failure to honour Te Tiriti’s partnering with Māori. Māori communities, who are disproportionately affected by gun violence, were not adequately engaged in shaping this legislation. Instead, this bill reflects the priorities of a small firearms lobby, ignoring the lived realities of tangata whenua.

From a justice perspective, the deregulation of firearms will worsen systemic injustices. Deregulated shooting ranges and clubs could increase access to firearms in communities already facing heightened levels of violence and systemic inequities. History shows that Māori communities are often over-policed yet under-protected. By weakening firearm regulations, this bill increases the risk of firearms being misused in already vulnerable communities, while exposing Māori to heightened police scrutiny. This perpetuates the cycles of racial bias and criminalisation that have long affected Māori.

A justice-focused approach would strengthen firearm regulations, ensuring that Māori communities are actively protected from harm. This would include community-led initiatives that prioritise restorative justice and public safety, rather than policies that amplify inequities.

• 1.

  Erosion of public safety: By rolling back safety measures established after the Christchurch terrorist attack, this bill opens the door to criminals and extremists exploiting unregulated shooting ranges.

• 2.

  White supremacist terrorism: The bill ignores the risks posed by deregulation, which creates opportunities for extremists to access firearms and practise deadly techniques.

• 3.

  Disproportionate impact on Māori: Weakening firearm regulations disproportionately affects Māori, increasing both the risk of harm and the likelihood of racial profiling by police.

• 4.

  Conflict of interest: The fact that this bill is led by a former gun lobbyist raises serious concerns about whose interests are being prioritised.

Te Pāti Māori calls for:

• Maintaining and strengthening the existing regulatory framework under the Arms Act 1983. All shooting clubs and ranges must be subject to regular inspections and compliance with national safety standards.

• Policies informed by robust data and meaningful consultation with Māori, ensuring they align with tikanga and Te Tiriti o Waitangi principles.

• Rejecting legislative proposals that prioritise lobbyist interests over public safety and equity.

This bill is a step in the wrong direction, undermining the progress made to ensure firearm safety in Aotearoa. Guns capable of rapid firing are tools of terror, not tools for kai, and their deregulation compromises the safety of all people. Te Pāti Māori stands resolutely against this legislation, calling on Parliament to reject this dangerous rollback of protections and honour the victims of the Christchurch terrorist attack by upholding public safety and equity for all.