The Review is being undertaken in a serious public safety context, and ADA acknowledges the Government’s responsibility to ensure firearms laws remain robust, contemporary, and effective. At the same time, ADA’s submission strongly reinforces that lawful, licensed recreational hunters are not the source of firearm-related violence — and that reforms must be evidence-based, proportionate, and risk-focused.
ADA’s submission is grounded in data, operational experience, and long-standing engagement with government and regulators.
To help address the lack of publicly available data on lawful firearm use, ADA conducted a structured survey of its Victorian members. The survey provides direct evidence about how recreational hunters lawfully use firearms, how many activities they participate in, and how proposed changes could affect compliance and safety outcomes. These findings are referenced throughout the submission.
ADA does not support arbitrary numerical limits on the number of firearms a licensed person may own.
The submission explains that firearm ownership among recreational hunters is purpose-based, not discretionary. Different deer species, hunting environments, and animal-welfare requirements often require different firearms and calibres. Survey results show that most members own multiple firearms because they participate in multiple lawful activities — not because of any increased risk.
Importantly, ADA notes there is no evidence that the number of firearms lawfully held by licensed hunters is linked to violent crime or public safety risk.
ADA strongly supports Victoria’s firearms licensing system, including background checks, fit-and-proper-person assessments, testing, and ongoing monitoring.
The submission highlights that Victoria’s firearm licence testing framework has recently undergone an audit and uplift led by Victoria Police’s Licensing and Regulation Division, in consultation with the Victorian Firearms Consultative Committee. This demonstrates that the existing system can be strengthened through evidence-based review without resorting to blunt or exclusionary measures.
ADA also urges caution around proposals to introduce citizenship-based eligibility requirements, noting that many permanent residents already meet all licensing, probity, and compliance requirements and do not present an elevated risk.
ADA does not support shortening licence terms.
The submission explains that such a change would increase licence renewal volumes on an ongoing basis, placing significant additional pressure on licensing systems and police resources. ADA argues that this would divert attention away from intelligence-led monitoring and illicit firearms enforcement — where real public safety gains can be made — without evidence of improved safety outcomes.
A central theme of ADA’s submission is that the greatest threat to public safety comes from illicit firearms, not licensed recreational hunters.
ADA strongly supports measures to prevent illegal manufacture, trafficking, and criminal use of firearms. This includes improved information sharing between agencies and the development of the National Firearms Register, which is intended to provide near real-time information to law enforcement.
ADA will continue to engage constructively with government to help ensure these systems are accurate, workable, and fit for purpose.
The submission also addresses the broader public confidence issue around firearms.
ADA notes the Victorian Government’s announcement of its intention to establish Outdoor Recreation Victoria as a statutory body. ADA submits that this presents a valuable opportunity — alongside industry associations — to better educate the public about regulated hunting, lawful firearm use, and the role hunters play in wildlife management and conservation on public land.
ADA’s submission reinforces the Association’s long-standing approach of working constructively with government. Past advocacy — including successful engagement on access arrangements for deer hunting in the Snowy River and Errinundra National Parks — demonstrates that balanced, evidence-based policy development can enhance public safety while recognising legitimate firearm use.
ADA remains committed to engaging with the Victorian Government, Victoria Police, and the Review to ensure firearms regulation:
Members can be confident that ADA is representing their interests clearly, professionally, and responsibly — backed by evidence and focused on outcomes that genuinely improve community safety.
You can read the full submission here.
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