Final report from the Expert Advisory Panel on Firearms

Table of contents

Introduction

This is the report of the Expert Advisory Panel on Firearms (the panel). It includes a summary of the panel's work and its analysis and recommendations. [Redacted]

Summary of the panel's work

The panel was mandated by Public Safety Canada to "provide advice on firearms that remain on the market" that employ "semi-automatic action with sustained rapid-fire capability (tactical/military design with large capacity magazine)," while "identifying any that are reasonable for hunting and sport shooting purposes and to provide guidance on associated characteristics."

The panel met in person on 18 and 19 December 2024 at the RCMP Vanier Campus in Ottawa. At that meeting the panel received a briefing on the work to be undertaken. The panel was tasked with considering the appropriate classification of several models of firearms not prohibited by regulation (orders-in-council (OICs)) in May 2020 and December 2024, but which share characteristics with the firearms prohibited by regulation. We refer to the firearms under consideration as the 'gap list' firearms.

The panel received a tour of the Specialized Firearms Support Services-Canadian Firearms Program (SFSS-CFP) firearms vault and a technical briefing, which included a presentation of illustrative examples of firearms prohibited in May 2020 and December 2024, as well as several similar firearms that remain on the market. Officials provided the panel members with a walkthrough of the Firearms Reference Table (FRT), including its origins and how to complete research using the database. Panel members subsequently received access to the web version of the FRT. Officials also presented the legislative framework for the firearms classification system. They highlighted s.117.15(2) of the Criminal Code, which provides that "the Governor in Council may not prescribe anything to be a prohibited firearm, a restricted firearm, a prohibited weapon, a restricted weapon, a prohibited device or prohibited ammunition if, in the opinion of the Governor in Council, the thing to be prescribed is reasonable for use in Canada for hunting or sporting purposes."

A list of the gap firearms to be evaluated was provided to the panel. Other background information shared with the panel included a survey of provincial and territorial hunting regulations related to firearms, excerpts of evidence from stakeholders concerning firearms they consider suitable for hunting or sport shooting, a summary of the firearm classification system, and a copy of a study prepared by the Ontario Federation of Anglers and Hunters.

The panel members independently undertook research on the gap list firearms following the December meeting, including research using the FRT. On 6 January 2025, the panel members met via Zoom to discuss their preliminary views about the classification of the gap list firearms, to identify further information needed from officials, and to plan next steps. At an on-line meeting with government officials later on 6 January, the panel posed questions to officials and requested additional information on some firearm models and a summary of consultations with Indigenous peoples potentially affected by changes to firearm classifications. Following the meeting, officials provided the panel with this information.

On 11 January the panel met via Zoom to consider the gap list in detail and to outline its report. Following this meeting, the panel members continued to conduct research and began to draft the report.

The panel met again via Zoom on 15 January to discuss its draft report and consider amendments. Later that day the panel met with government officials and committed to submitting a draft report to officials to ensure it achieved the panel's mandate. A draft report was submitted on 17 January, which was discussed with government officials on 23 January. The panel met again via Zoom on 29 January and 31 January and submitted its report on 31 January.

Analysis and recommendations

The panel recognizes and affirms the place of legal firearms in Canadian society. Indigenous peoples and settler Canadians have employed firearms for hunting and sporting purposes for centuries. It is important that legitimate users retain the ability to legally acquire and use firearms for these purposes.

However, the panel also believes that the interests of gun owners need to be balanced against the public safety interests of all Canadians. This means that limits should be placed on the possession or use of firearms that pose substantial public safety risks because of their design and capabilities.

Firearm performance may be improved in several ways, including through changes in range, precision, type of projectile, and rate of fire. In war, as in mass shootings and terrorist attacks, the rate of fire is key because most shootings occur at close or medium range. Firearms with potentially high rates of fire – that are self-loading, with detachable magazines, and tactical designs – should generally be prohibited or restricted.

This is not a new approach. In 1991 Minister of Justice Kim Campbell described the Progressive Conservative government's decision to limit access to what she called "modern semi-automatic military assault weapons." Minister Campbell asserted that Parliament must focus on strictly regulating the "types of firearms associated with the greatest risk to public safety, and relatively few, if any, legitimate sporting uses." "Where there are relatively few legitimate uses for these firearms," she continued, "they would be prohibited altogether."Footnote i

The panel concludes that limiting access to some firearms is a reasonable and logical approach to preventing criminals from acquiring dangerous firearms, mitigating the risk of mass shootings, decreasing the dangers faced by police, and encouraging a culture of responsible firearm ownership. We agree with former Prime Minister Stephen Harper, who in 2012 emphasized the need to prohibit some firearms when he told the House of Commons that "prohibited weapons exist as a category under the law for essential reasons of public safety."Footnote ii

Canada has long sought to limit access to some firearms, but the firearms classification regime developed since the late 1960s has resulted in firearms with similar capabilities having different classifications. In the 1990s the federal government used regulations to declare many firearm models to be restricted or prohibited. However, as new models of semi-automatic assault-style weapons entered the Canadian market they were often classified as non-restricted firearms if their barrel and overall lengths met statutory requirements or were not deemed variants of firearm models previously restricted or prohibited by regulation.

Therefore, by the 2010s semi-automatic firearms with detachable magazines were classified as non-restricted, restricted or prohibited firearms depending on their physical characteristics (such as barrel length) and whether they had been classified as restricted or prohibited firearms by regulation.

The regulations of May 2020 and December 2024 were important steps in rationalizing the classification regime as they declared as prohibited many models of semi-automatic rifles capable of sustained fire that can receive large detachable magazines. However, firearms with similar capabilities, including many of those on the gap list, remain on the market as either restricted or non-restricted firearms.

The availability of these firearms requires immediate consideration since the Mass Casualty Commission recommended in 2023 that the "federal government should amend the Criminal Code to prohibit all semi-automatic handguns and all semi-automatic rifles and shotguns that discharge centre-fire ammunition and that are designed to accept detachable magazines with capacities of more than five rounds."Footnote iii

The panel divided the gap list into three categories for its analysis:

  1. semi-automatic shotguns with detachable magazines;
  2. semi-automatic military service firearms; and
  3. unique or unusual firearms not captured by previous prohibitions.

a) Semi-automatic shotguns with detachable magazines

The panel considered the design, capabilities, and classification of the various models of semi-automatic shotguns on the gap list. As semi-automatic (or 'self-loading') firearms, these shotguns have an action that loads a cartridge from the magazine into the chamber after each discharge but require shooters to manually fire each shot with a separate pull of the trigger.

The panel divided the semi-automatic shotguns on the gap list into two subcategories: bullpup shotguns and tactical shotguns. Bullpup shotguns feature firing grips in front of the breech of the firearm. This allows bullpup shotguns to have short overall lengths, thus making them compact, concealable, and maneuverable. The tactical shotguns on the gap list typically include pistol grips, and detachable magazines located in front of the firing grip.

For lists of semi-automatic bullpup and tactical shotguns on the gap list see Annex #1.

Figure 1: Titan K78 shotgun – example of a bullpup design
A Revolution Armory Titan K78 shotgun with a bullpup design. It is a black rifle with a long barrel and a detachable magazine that is located behind the trigger.
Image description

A Revolution Armory Titan K78 shotgun with a bullpup design. It is a black rifle with a long barrel and a detachable magazine that is located behind the trigger.

Figure 2: Armed Stryker shotgun – example of a tactical design shotgun
An Armed Stryker shotgun, which has a tactical design. It is a black rifle with a long barrel and a detachable magazine.
Image description

An Armed Stryker shotgun, which has a tactical design. It is a black rifle with a long barrel and a detachable magazine.

The panel recommends the prohibition of the bullpup and tactical shotguns on the gap list. Most of these semi-automatic shotguns can receive large magazines that exceed the capacity used by hunters and allow for the shotguns to be quickly reloaded. They provide users with more firepower than generally needed for hunting purposes. Almost all provinces and territories place limits on the number of rounds that shotguns can carry when used for hunting – typically, shotguns must be 'plugged' to limit them to 2-3 rounds. The panel also notes that many of these firearms are marketed as firearms for self-defense or for tactical, military-style shooting. The panel believes that the threat to public safety posed by semi-automatic shotguns with detachable magazines outweighs the value of such firearms for hunting or sport shooting.

In addition, the panel recommends that the government consider prohibiting semi-automatic shotguns with rotary tube magazines, as these firearms can be designed to hold large amounts of ammunition. The gap list contained one such firearm: the SRM Arms 12.

b) Semi-automatic military service firearms

The panel analyzed numerous examples of semi-automatic rifles, most of which had been designed for military use before or during the Second World War.

These firearms tend to share several characteristics. They are semi-automatic firearms. They have magazines that are either attached box magazines and / or detachable magazines. Many are reloaded using 'stripper clips' (a speedloader that holds several cartridges together in a single unit for easier and faster loading of a firearm magazine). Most of these rifles were designed for military use. In their original configurations, many are relatively long, heavy firearms that fire full-powered cartridges. There are exceptions to this broad characterization of these firearms. For example, the M1 carbine is a compact rifle originally designed with a detachable large-capacity magazine.

Most of the semi-automatic service firearms on the gap list are capable of sustained rapid fire and were produced to arm militaries during the Second World War and the Cold War. Some were sold off as surplus into the civilian market. In other cases, manufacturers produced these models for the civilian market after the guns had largely ceased to be used by military forces.

For a list of the semi-automatic military service rifles on the gap list see Annex #2.

Some of these firearms have been updated by manufacturers or users such that they share characteristics with other firearms that are now prohibited in Canada. That is, designs have been altered to accept large-capacity, detachable magazines and have improved ergonomics to permit the user to train and aim at targets more quickly.

In the wrong hands, semi-automatic firearms can be used to inflict substantial harm to the public and law enforcement. This has long been recognized. For example, a 1990 study prepared on Progressive Conservative gun control proposals by the Research Branch of the Library of Parliament concluded that "It must be acknowledged that even weapons designed and manufactured as semi-automatic hunting and recreational shooting rifles and shotguns can be used to create carnage. The Montreal tragedy bears dramatic witness to this potential."Footnote iv Incidents in which police have been killed by people wielding such firearms, such as when three RCMP were murdered in Moncton 2014, have also highlighted the danger of semi-automatic rifles.

Since the 1990s Canada has sought to mitigate the risk of semi-automatic firearms by limiting the magazine capacity of rifles (with some exceptions) to five rounds. Minister of Justice Campbell succinctly explained the rationale for this policy in 1991: "The addition of a large magazine can convert almost any ordinary semi-automatic hunting rifle into an assault weapon."Footnote v

[Redacted]

The panel also recognizes that many Canadians, including many Indigenous people, acquired semi-automatic military service firearms such as the SKS, Tokarev SVT 1938/1940 and Ljungmann AG42 for hunting purposes. SKS rifles, for example, entered the Canadian market in large numbers in the 1990s after the fall of communist governments. Many Indigenous harvesters adopted the non-restricted SKS because it was robust, cheap to purchase, and fired inexpensive ammunition. In its original configuration, the SKS was a semi-automatic rifle chambered in 7.62x39mm with a 10 round fixed magazine that was loaded from the top of the rifle with stripper clips. In Canada the fixed box magazine was limited to holding five rounds of ammunition.

[Redacted]

Figure 3: Three SKS rifle variants: original wood-stock, modified with detachable magazine, and a modern AK-style variant
Three variations of the SKS rifle. The top rifle is the original, wooden design of the SKS with a fixed magazine. The second rifle is an SKS that has been modified to accept a detachable large capacity magazine. The third is an SKS rifle that has been modified with modern parts to resemble an AK style firearm.
Image description

Three variations of the SKS rifle. The top rifle is the original, wooden design of the SKS with a fixed magazine. The second rifle is an SKS that has been modified to accept a detachable large capacity magazine. The third is an SKS rifle that has been modified with modern parts to resemble an AK style firearm.

Because some models of semi-automatic military service firearms were adopted by some harvesters, the panel is reluctant to recommend the prohibition of all models of such firearms on the gap list without further study. However, classification changes should be considered by the government for some of these models. Factors for the government to consider in deciding whether to prohibit these firearm models should include:

c) Unique or unusual firearms

The gap list contains several firearms that the panel believes have characteristics like models that the government previously declared to be prohibited by regulation. These include semi-automatic versions of sub-machine gun models. These models are compact and concealable and can employ large-capacity magazines. Given that these firearms are inappropriate for hunting or sport shooting, the panel concludes that they should be prohibited. Prohibition will also ensure more consistency in the classification regime.

For a list of these firearms on the gap list see Annex #3.

Figure 4: Franchi LF57 submachine gun – example of a compact design
a Franchi LF57 submachine gun. It is a short, black firearm with a folding stock and an extended magazine.
Image description

A Franchi LF57 submachine gun. It is a short, black firearm with a folding stock and an extended magazine.

Conclusion

The panel believes that additional firearms from the gap list should be declared to be prohibited by regulatory amendment. This should be done in a way that minimizes the impact on people who are reliant on harvesting game to support themselves and their families, particularly Indigenous peoples.

The panel also strongly recommends that the Government of Canada undertake a comprehensive overhaul of the firearm classification system. The origin of the current regulatory system for classifying long guns dates from the late 1960s. In the last half century, the classification system has become complex and unwieldly. Some firearms are determined to be restricted or prohibited by virtue of characteristics such as barrel length or firing mechanism. Others have been declared as restricted or prohibited by regulation. Bill C-21 established a new technical definition of a prohibited firearm, but this definition only applies to firearms designed and manufactured after 15 December 2023.

The panel believes that this regulatory regime has produced one of the most complex systems of firearm classification in the world. This poses challenges for law enforcement, the Canadian Firearm Program, firearm users, government officials, and lawmakers. It provides opportunities for potentially dangerous models of firearms to enter the Canadian market. The panel thus strongly urges the federal government to undertake a comprehensive revision of the firearm classification system to ensure that Canadians remain safe from wrongdoers armed with dangerous firearms. The panel agrees with the Mass Casualty Commission, which recommended that the federal government "reform the classification system for firearms and develop a standardized schedule and definitions of prohibited firearms within the Criminal Code of Canada, with an emphasis on simplicity and consistency."Footnote vi The panel members would welcome the opportunity to participate in a review of the classification system.

Finally, the panel members wish to extend gratitude to the government officials who assisted them in completing their work. Officials demonstrated professionalism and a deep technical knowledge of firearms, the classification system, and the FRT. They quickly responded to requests from the panel for additional information. In doing so, they provided unbiased data and analysis, and did not seek to influence the panel's findings.

Annex 1 – Semi-automatic shotguns with detachable magazines

Bullpup shotguns

Tactical shotguns

Multiple tube fed shotgun

Annex 2 – Semi-automatic military service firearms

Firearms with detachable magazines

Firearms with non-detachable magazines

Firearms requiring further study

Annex 3 – Unique or unusual firearms

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