Author: Luther Cutts, Head Instructor (NSCA Level 3), Competitor
There has been a dizzying series of changes to the laws governing firearms use and possession in Canada, and it is easy to see why some people are struggling to keep up. There are more changes yet to come in the form of Bill C-21, so we will all have to wait to see what those changes are – there is a lot of discussion regarding C-21, and nothing has been finalized.
What has been set into motion as of late 2022 is the cessation of the ability to transfer or acquire restricted firearms. This translates into our collective inability to buy or sell restricted firearms. Any transactions that were initiated before this new policy was implemented will be completed, but no new transfers will be allowed.
To many people, this new development has been interpreted to mean there is no longer any reason to obtain a Restricted Possession and Acquisition License (R-PAL), but this characterization may not be entirely correct.
The ability of an individual to borrow a restricted firearm has not been curtailed. If you have an R-PAL, you can apply for an Authorization to Transport (ATT) to borrow a friend’s restricted firearm. Before getting the ATT, a few things need to be in place – you will require the Registration Certificate for each firearm you intend to borrow, and you will need to be a member of an approved restricted firearm range.
You can now apply for an ATT online through the RCMP individual web services page.
As an instructor for the Canadian Firearms Safety Course, I cannot help but notice the increasing interest in firearms use in Alberta. My monthly classes are normally full, and I routinely must turn people away. Young women have been increasingly represented in these classes, which is encouraging – firearms use, enjoyment, and ownership should not be limited to men.
As a current or future firearms owner and user, we are required stay abreast of the laws regarding firearms. There is, regrettably, always some misinformation on this topic. Your individual interests will be best served when you have a factual understanding of the law regarding firearms.
A few topics I understand some people find confusing include:
Minor’s Permit
The Minor’s permit is available to individuals who are older than 12-years of age, and not yet 18 years old. This permit does not allow the individual to acquire firearms or ammunition, but they can possess a firearm. This distinction can be confusing to some folks, and I will attempt to clarify.
The Minor’s Permit allows an individual to legally possess non-restricted firearms. This does not include acquiring or owning firearms, but rather, is specifically limited to possession. This means your 15-year-old daughter can use your firearm unsupervised if she has her Minor’s Permit. She cannot own the firearm, but she can borrow it. This translates into allowing you and a licensed minor to, for instance, go hunting, and the minor will not have to be in the immediate presence of a licensed adult.
The Minor’s permit does not authorize or allow a minor to purchase a firearm or ammunition.
To obtain a Minor’s Permit, an individual must be at least 12-years old, and they must successfully complete the Canadian Firearms Safety Course. They will require the specific informed consent of their parent to apply for the permit, the fee for which depends on the duration of the permit. The costs are $10 for one year, $20 for two years, and $30 for three years.
Unlike the PAL, a Minor’s Permit cannot be renewed – instead a new application must be submitted. The Minor’s Permit is only valid with individuals who are under the age of 18. If you are 16 years old when you apply, you can only apply for two years.
It is recommended that as a minor approaches their 18th birthday, they should submit their PAL application at least six months before their birthday. Since they already have the CFSC under their belt, all they need to apply for a PAL is their Minor’s Permit number.
There is no requirement for them to take the CFSC again.
A minor may not participate in the Canadian Restricted Firearms Safety Course, as the course is available only to those individuals who have reached the age of 18 years.
PAL Renewal
If your firearms license is still valid, you can apply to renew online. It is a much faster process and can be done in a few minutes if you have access to a computer. There have been significant delays in renewing licenses, so the earlier you can get your renewal into the system, the higher the likelihood you will receive your new PAL on time is. Applying to renew your PAL six months, or more, before your PAL expires is not unreasonable. Do not leave this until the last moment.
If you PAL has expired, the online renewal option is no longer available. You will have to obtain the paper application form, RCMP GRC 5592, and apply the old-fashioned way. Allowing your PAL to expire not only means you will have to apply with a slower, more cumbersome method, but it also creates some potential legal issues as well.
PAL Expiration
For a variety of reasons, the Canadian Firearms Program has been struggling to maintain service levels since 2020 – processes that used to take weeks are now taking many months. There was a time when you could apply to renew your PAL a month or six weeks before it expired, and you would be fine. Unfortunately, the delays in processing renewals have been much longer – six months to a year.
What is your legal status if you have applied to renew your PAL, but the renewed PAL does not arrive before your existing PAL expires? It will depend on whether you have applied to renew your PAL before it expired. If you did apply for your renewal before your existing PAL expired, you will be granted a grace period – a gray area of Canadian law.
Although you are technically without a PAL when your current PAL expires, if you apply to renew your PAL while it is still active, there is a presumption that your PAL is going to be approved, and you will be allowed to continue with the lawful possession of your firearms and ammunition.
For greater clarity, the position of the Alberta CPFO is that you can still possess your firearms and ammunition, however, you may not acquire additional firearms, nor may you acquire ammunition without your new PAL. The CPFO also states that while you may possess your firearms and ammunition, you cannot use any of them until your new PAL arrives.
If, on the other hand, you did not apply to renew your PAL before it expires, your situation is markedly different.
An individual whose PAL has expired, and they are unable to prove that they have applied for a renewal before the expiry date of their most current PAL, is in the unenviable position of being in possession of firearms and ammunition without a license – a criminal offence. Thankfully, the general attitude of the Canadian Firearms Program is geared more towards compliance than enforcement, meaning that when you apply for your PAL, you will be spoken to and strongly urged to remain in compliance. It is unlikely, but not impossible, that you could face criminal charges for this oversight. It is something that is best avoided.
The folks in the Alberta Chief Provincial Firearms Officer branch are working diligently to overcome these backlogs, and we will hopefully see some resolution soon. Until then, we can do our part by making sure we are doing whatever we are expected to do with enough advance time built into the process to give everything time to work through the system.
Upgrading your PAL
If you already have your PAL, and you have recently completed the CRFSC, you will need to upgrade your PAL to the R-PAL status, which requires an application on form 5592, which is the PAL application form, and the submission of a fee of $41.62. Please note the cost to upgrade from a Non-Restricted PAL to a Restricted PAL is $41.62, which is one-half of the fee for someone applying for their firearms license in the first instance, or someone renewing their PAL.
It can be a bit confusing, ….
Hopefully this table will help clarify some of the various situations you might be confronted with.
| Situation | Process and required form | Fee |
| You have recently passed the CFSC and wish to apply for your non-Restricted Possession and Acquisition License (PAL) | Complete RCMP form 5592, and submit to through the mail to the RCMP | $62.42 |
| You have recently passed the CFSC and wish to apply for your Minor’s Permit | Complete RCMP form 5485, and submit through the mail to the RCMP | $10/year |
| You have recently passed the CFSC and the CRFSC, wish to apply for your Restricted Possession and Acquisition License (PAL) | Complete RCMP form 5592, and submit to through the mail to the RCMP | $83.23 |
| You already have your non-Restricted PAL, you have recently completed the CRFSC, and you wish to upgrade your non-Restricted PAL to a Restricted PAL | Complete RCMP form 5592, and submit to through the mail to the RCMP | $41.62 |
| Your non-Restricted PAL is still valid, and you wish to renew it before it expires | You can renew your license online through the Individual Web Services portal on the RCMP website, or you can complete RCMP Form 5614 and submit it through the mail to the RCMP | $62.42 |
| Your Restricted PAL is still valid, and you wish to renew it before it expires | You can renew your license online through the Individual Web Services portal on the RCMP website, or you can complete RCMP Form 5614 and submit it through the mail to the RCMP | $83.23 |
| Your Minor’s Permit is going to expire | Complete RCMP form 5485, and submit through the mail to the RCMP | $10/year |
| Your non-Restricted PAL has expired | Complete RCMP form 5592, and submit to through the mail to the RCMP | $62.42 |
| Your Restricted PAL has expired | Complete RCMP form 5592, and submit to through the mail to the RCMP | $83.23 |
Please note, these prices are accurate until March 30, 2023. On March 31, the prices will change. The fee for the Non-Restricted PAL increases from $62.42 to $64.54, while the fee for the Restricted PAL increases from $83.23 to $86.06.
It is important to include the correct fee with the application – if you use an older fee that is no longer accurate, it can cause further delays in getting your application processes.