link to page 1
10 June 2025
IR-01-25-15242
New Zealand Citizen
[FYI request #30816 email]
Tēnā koe
Thank you for your Official Information Act 1982 (OIA) request dated 24 April 2025 where
you asked for information relating to unlawful hunting.
By way of context, you provided the fol owing:
I am writing to request information regarding the framework and processes in
place for addressing unlawful hunting, particularly incidents involving firearms. I
would appreciate clarification on several key aspects of policy, training, and inter-
agency cooperation related to the enforcement of laws concerning unlawful
hunting and firearm use.
This request is made under the Official Information Act 1982. Please find below a
series of questions aimed at gaining a comprehensive understanding of how
unlawful hunting is managed within New Zealand, and how NZ Police and the
Firearms Safety Authority respond to such incidents. Any insights or
documentation you can provide would be greatly appreciated.
I have answered each question below.
1. Internal Policies or Operational Framework Does NZ Police have an internal
policy, operational procedure, or decision-making framework specifical y
addressing unlawful hunting, particularly where firearms are involved?
– If yes, please provide a copy of any such documents or an outline of the
process.
– If no formal policy exists, how are such incidents typically handled or assessed
by NZ Police?
While there is no specific document addressing unlawful hunting, the assessment of al
firearms licence applicants is aligned to the purpose and principles of section 1A
1 of the
1 Purposes of this Act
(1) The purposes of this Act are to-
(a) promote the safe possession and use of firearms and other weapons; and
(b) impose controls on the possession and use of firearms and other weapons.
(2) The regulatory regime established by this Act to achieve those purposes reflects the following principles:
(a) that the possession and use of arms is a privilege: and
(b) that persons authorised to import, manufacture, supply, sell, sell, possess, or use arms have a
responsibility to act in the interests of personal and public safety.
Section 1A: inserted, on 25 June 2020, by section 5 of the Arms Legislation Act 2020 (2020 No 23).
Te Tari Pūreke – Firearms Safety Authority
Telephone: 0800 844 431
www.firearmssafetyauthority.govt.nz
Te Tari Pūreke – Firearms Safety Authority is a business unit of New Zealand Police.
link to page 2 link to page 2 link to page 2
Arms Act 1983 (the Act). Section 24 of the Act requires that an applicant must be a “fit
and proper” person to be in possession of a firearm or an airgun. The grounds for
firearms licence revocation or suspension pending revocation under sections 27 and 60A
of the Act
2 include where the licence holder is not a fit and proper person to be in
possession of a firearm or airgun.
From 24 December 2020, a new section 24A4
3 of the Act provided more detailed
statutory guidance on circumstances relevant to whether a person is fit and proper to
possess firearms or airguns.
These factors are relevant considerations when assessing whether a person is or
remains a fit and proper person to possess firearms or airguns. They are not an exclusive
list – section 24A(2)(c)
4 makes it clear that Police may take into account any other
relevant matters considered appropriate.
The assessment of a person’s fit and proper status requires consideration under a two-
stage process:
1. is a firearms licence holder involved in specific behaviours, offending or
circumstances defined in section 24A(1)(a) - (n), or 24A(2) or as considered
relevant, and then,
2. the severity and recency of the circumstance(s) (specific behaviours, offending
listed above) individually at first, and then col ectively when considered overall.
One significant matter may suffice, or more less significant matters. This includes
all other matters deemed relevant.
The factors for consideration for assessment as a fit and proper person include the extent
of harm or risk of harm, including the danger of self-harm or harm to others.
Actions that create risks but do not actual y lead to harm occurring can stil be serious
and require a firm response of harm or the risk of harm includes the following factors:
• Minimal or no harm or risk of harm,
• harm is, or would likely be, easily mitigated,
• significant or widespread harm or potential for such harm is actually or potential y
caused to members of the community.
Conduct in this context means the behaviours, intent, and capability of the licence holder
whose actions are being considered.
Assessment of conduct includes the fol owing factors:
• It is first-time or one-off behaviour that is less serious or unlikely to be repeated,
• the conduct is accidental or resulted from momentary carelessness or the result
of a limited understanding of the law (where that is not inconsistent with the
expectations of someone holding a firearms licence),
• mitigating factors exist,
2
https:/ www.legislation.govt.nz/act/public/1983/0044/latest/whole.html#LMS440344
3 24A Fit and proper person to possess firearm or airgun
(1) For the purposes of this Act, a member of the Police may find a person is not a fit and proper person to be in
possession of a firearm or an airgun if the member of the Police is satisfied that 1 or more of the following
circumstances exist [ … ]
https:/ www.legislation.govt.nz/act/public/1983/0044/latest/LMS440359.html
4 In determining whether, for the purposes of this Act, a person is a fit and proper person to be in possession of
a firearm or an airgun, the member of the Police may take into account: […] (c) any other relevant matters the
member of the Police considers appropriate.
• the behaviour is deliberate, more serious, repeated, reckless or involving
consistent carelessness or involving disregard for New Zealand legislation,
• aggravating factors exist.
Public interest can be described as something being in the interest of the wider public or
of public importance. Considerations include whether the event reflects a widespread
problem that can be usefully addressed by highlighting the need for compliance.
Assessment of public interest includes the fol owing factors:
• the conduct occurred some time ago and has ceased,
• a decision not to act would undermine public confidence in Police as a regulatory
authority, and
• enforcement action is necessary to deter others from similar conduct.
Each case wil have its own set of specific and unique circumstances, meaning that the
decision maker wil need to identify the relevant factors applicable on a case-by-case
basis.
The final consideration in the fit and proper assessment requires Police to review the
totality of the specific behaviour / offending by the licence holder, in the context of the
aims of the Act, in order to reach a fair and justifiable decision.
Conversely, there wil also be instances where Police’s decision wil be based on the
totality of the specific behaviour / offending, where the licence holder does not meet the
threshold for consideration of revocation, and remains, however marginal y or otherwise,
a fit and proper person to possess a firearm or airgun.
Police may instead issue a warning letter to the licence holder setting the relevant facts
and corresponding legislative grounds under section 24A that may affect the licence
holder’s fit and proper status and the consequence of potential revocation of the firearms
licence for any subsequent offending/behaviour.
As an example of how Police manage incidents of il egal hunting, I refer you to the Police
media statement (see link below):
Wairarapa Police are getting tough on poachers –
Wairarapa Police are stepping up their efforts to target poachers and hope recent
convictions encourage rural communities to break the silence. Police are ramping up
patrols on rural roads across the Wairarapa and are stopping all vehicles that they come
across, says Acting Sergeant Nick Bunny, Wairarapa Community and Rural Manager. In
the past year, Wairarapa Police have charged a number of people with poaching.
Offenders face prosecution in court, having their firearms licence revoked, equipment
seized, and firearms destroyed (4 October 2024).
Wairarapa Police are getting tough on poachers | New Zealand Police
Note that each case wil have its own set of specific and unique circumstances, meaning
that the decision maker wil need to identify the relevant factors applicable on a case-by-
case basis.
2. Firearms Licensing and Behavioural Red Flags Are incidents of unlawful
hunting considered a behavioural red flag when assessing an individual's fitness
to possess a firearms licence under the Arms Act 1983?
– If so, how is this reflected in operational guidelines or decision-making criteria
Firearms owners and users have certain other obligations under the Arms Act 1983 and
Arms Regulations 1992. Failure to follow these requirements can lead to their licence
being suspended or revoked, and in some cases result in prosecution.
As referenced in my response to question 1 above, each case wil have its own set of
specific and unique circumstances, meaning that the decision maker wil need to identify
the relevant factors applicable on a case-by-case basis.
3. Referral Process to the Firearms Safety Authority Is there a formal referral
process in place between NZ Police and the Firearms Safety Authority when
unlawful hunting is identified?
– If yes, please provide details of how such referrals are documented and
assessed
Te Tari Pūreke is a branded business unit of Police charged with ensuring that only fit
and proper persons can maintain firearm licences. Any incident where firearms are
alleged to have been used il egal y wil be of interest to us in terms of the civil regulatory
function which may overlap with any separate criminal investigation and prosecution.
As part of Police, Te Tari Pūreke have ful access to all required Police systems, therefore
Te Tari Pūreke is notified when an alert for unlawful hunting occurs on any Police system,
most usual y via the National Intel igence Application (NIA).
Note too that Te Tari Pūreke Resolutions team receives daily the Firearms Licence
Review Report (FLRR), from wider Police, which notes when a firearms licence holder
has an interaction with Police. An unlawful hunting event noted in this report would trigger
a potential review of a firearms licence holder’s fit and proper status.
Upon notification of an unlawful hunting incident, the Resolutions team undertake an
assessment of the person/s involved (see my response to question 1). Based on that
assessment, a decision can be made to (either or):
•
Do nothing (often due to lack of information)
•
Educational phone call
•
Provide a warning letter
•
Suspend the firearms licence pending possible revocation (28 days)
•
Revoke firearms licence (5 years)
4. Training and Guidance on Unlawful Hunting Enforcement What training and
internal guidance is provided to NZ Police or the Firearms Safety Authority for
handling unlawful hunting or trespassing with firearms incidents?
– What legislation is covered in officer training (e.g., Wildlife Act 1953, Wild
Animal Control Act 1977, Trespass Act 1980, Arms Act 1983)?
– Is this training universal or tailored to specific roles?
– Are there internal materials or procedures that guide staff in identifying and
responding to unlawful hunting or firearm-related trespass, particularly in rural
areas?
– How are staff instructed to apply this training in practice?
The fol owing guidance is available:
•
The Rural Police intranet page includes video content on investigating unlawful
hunting and contains advice and tools regarding the application of appropriate
legislation for these events.
•
Guidance concerning unlawful hunting is available to officers via Checkpoint (an
app on police mobile devices).
A prosecutions resource booklet specific to unlawful hunting has been available since
2024 aiming to improve the quality of prosecution files and confidence of prosecutors.
The booklet covers the following topics:
•
Il egal hunting – a prosecution overview
•
Il egal hunting – the law
Wildlife Act 1953
Wild Animal Control Act 1977
o What is being hunted?
o Where is the ‘hunting ‘occurring and what permissions apply?
o What actions constitute hunting?
o Other helpful aspects of Wild Animal Control Act 1977
Animal Welfare Act 1999
Arms Act 1983
Crimes Act 1961
•
Il egal hunting – examples for presenting the case
•
Il egal hunting - outcomes
In addition, a ‘best practice’ Police manual chapter that is specific to Unlawful Hunting is
in final draft stage and pending legal review prior to publication.
Although currently there are no learning modules specific to unlawful hunting, a learning
module specifically for rural staff is in development with the Royal New Zealand Police
Col ege (RNZPC).
5. District-Level Responsibility for Investigations Within each NZ Police district, is
there a designated person, unit, or team responsible for overseeing investigations
into unlawful hunting activities?
– If so, what is their role, and how are they selected or trained?
There is no designated persons or groups overseeing investigations in Police in relation
to unlawful hunting. Investigations and prosecution files follow the national process from
investigation, recommendations, supervisor review and decision to prosecute or other
actions.
Alongside Police, the Department of Conservation staff hold powers to act under the Wild
Animal Control Act 1977 and Fish & Game staff hold powers under the Wildlife Act 1953.
– How does NZ Police ensure that officers with relevant expertise (e.g., rural
crime, firearms law, or wildlife legislation) are assigned to these investigations?
Police officers are trained sufficiently and where required, will engage other areas of
Police to assist in investigations. This may include, Criminal Investigation Branch (CIB),
Scene of Crime Officers (SOCOs), prosecutions, Crown law or other specialist groups, for
example, the Firearms Safety Authority, in assisting to complete an investigation.
Since 2023, rural staff have been supported through the implementation and appointment
of a Rural Policing Manager (Inspector level) based at Police National Headquarters
(PNHQ). The core component of this role is to support rural staff across the country in the
consistency of practices and advocate for their welfare and upskil of training.
– If possible, please provide a list of responsible roles or units by district.
Rural Officers, in addition to their line managers, are supported by Rural Liaison Officers
(RLOs). Nationally, each Police District is supported by a leadership representative who
is of rank of Senior Sergeant or above (except Northland which is Sergeant level
supported).
6. Public Reporting Through the 105 System Given previous public awareness
campaigns encouraging the reporting of unlawful hunting, has NZ Police
considered adding a dedicated digital reporting category—such as “Unlawful
Hunting/Poaching”—under the Make a Report section of the 105 platform?
Agencies are not obligated to create new information or form opinions to respond to
requests under the OIA. The OIA applies only to information that the agency already
holds in its official capacity, therefore this part of your request is refused under section
18(g) of the OIA, the information is not held, and I have no grounds for believing that the
information is held by another agency.
Additionally, it should be noted that the Te Tari Pūreke website ‘Contact us’ page
[https://www.firearmssafetyauthority.govt.nz/contact-us] carries information on a range of
scenarios, including “If you have a concern with someone’s firearms use”, where the
following drop-down information is provided:
In an emergency, cal 111. Otherwise, use the Police non-emergency reporting line.
• Phone the non-emergency Police number
105
• Online:
Contact New Zealand Police form
7. Triage and Dispatch of Unlawful Hunting Reports When a report of unlawful
hunting is made via 111 or 105, is there a process to ensure it is al ocated to
officers or units with the appropriate expertise?
– How is this triaging process managed to ensure a consistent and informed
response across districts?
8. Recording and Use of Non-Conviction Information If an individual is identified
as engaging in unlawful hunting but is not charged or convicted, is any
information recorded that could be linked to their firearms licence?
– If so, how is this information recorded and accessed?
– Does it influence future assessments of the person’s suitability to possess or
retain a firearms licence under the Arms Act 1983?
– Are there internal thresholds or guidelines for when a non-conviction incident
becomes relevant to licensing decisions?
In relation to questions 7 and 8, if a person has been involved in unlawful hunting, a
noting could be added to the National Intel igence Application (NIA) and could be linked
to their firearms licence information. I refer you to my answer to question three.
Please also see the below link, under the subheading “How we assess if you are a ‘fit and
proper person’”
“The Arms Act 1983 gives some circumstances in which Te Tari Pūreke may find
you are not a fit and proper person to have and use firearms. If any of these
circumstances apply to you, we do not automatically refuse your application.
[ … ] We wil probably have more questions if:
• you have been charged with or convicted of an offence punishable by
imprisonment,
• you have been charged with or convicted of an offence under the Arms Act
1983, against section 231A of the Crimes Act 1961, or against the Game
Animal Council Act 2013, the Wildlife Act 1953, or the Wild Animal Control
Act 1977 “
link to page 7
https://www.firearmssafetyauthority.govt.nz/manage-and-apply/firearms-licence/you-
apply-firearms-licence
I refer you also to my answer to question 1.
9. Data Sharing Between Agencies
Does NZ Police share information on unlawful hunting incidents with other
agencies (e.g., DOC, local councils, MPI)?
It is possible for Police to share information about unlawful hunting incidents with other
agencies if needed (under strict privacy law requirements) however, I have no record of
this occurring in relation to unlawful hunting events.
– If so, how is this data shared and used?
– Are there formal agreements or Memorandums of Understanding (MOUs) in
place?
– Does this sharing include incidents that do not result in prosecution?
– How is sensitive data, such as personal information, handled and protected
when shared between agencies?
I have answered the questions above in relation to unlawful hunting. Part 7
5 of the Act
describes direct access to registry information. Direct access requires a Memorandum of
Understanding (MoU) with the appropriate agency and Police and must be signed by both
Ministers in charge of each agency. Currently, no agency Ministers have signed a MOU
under part 7, as such I have no knowledge of any information outside the Registry that
may be shared regarding unlawful hunting.
(While Police does have an MoU with the Department of Conservation (DOC), and the
Ministry of Primary Industries (MPI) they are not pursuant to part 7 of the Act, and there is
no specific detail that relate to unlawful hunting. (Police is currently engaged with DOC to
undertake joint hunting compliance operations; draft Operational templates have been
created for use by both agencies undertaking hunting compliance operations).
I refer you to the following link in relation to how Police manage personal information
generally, under the subheading “Disclosing and sharing personal information.” (Note that
this is information sharing general y and does not mention unlawful hunting.)
https://www.police.govt.nz/about-us/privacy-statement-how-we-manage-personal-
information
10. Proactive Monitoring and Prevention Measures Does NZ Police conduct
proactive monitoring, intel igence gathering, or preventive operations to deter
unlawful hunting with firearms?
The New Zealand Information Security Manual (NZISM) provides guidance for sharing
data between New Zealand government agencies, but it does not mandate a specific
standard for al data sharing, nor does it mention unlawful hunting.
Agencies must ensure data sharing is authorized, either through legislation or formal
agreements, and must document the process and security measures in place, including
controls that align with the NZISM. As there are no formal agreements in place within Te
5
https:/ www.legislation.govt.nz/act/public/1983/0044/latest/LMS853063.html
Tari Pūreke, currently there are no set standards agreed upon for transferring any
information including that related to unlawful hunting.
New Zealand Information Security Manual: Home (Publicly available)
– Are there regions or seasons (e.g., deer roar) where enforcement is heightened
due to increased risk?
Fish & Game NZ, in conjunction with Police, undertake targeted compliance activity of
recreational gamebird hunters over the opening weekend of the gamebird season. Police
also work with other land managers and owners on il egal hunting prevention initiatives in
known problem areas.
https://www.rnz.co.nz/news/national/539290/five-people-arrested-after-illegal-hunting-
wilful-damage-and-theft-in-the-kinleith-forests
Police on the hunt for poachers | The Post
– What technologies (e.g., drones, surveil ance cameras) or inter-agency
partnerships are in place to support proactive enforcement?
There are no technologies or formal interagency partnerships in place regarding unlawful
hunting and “proactive enforcement”.
However, I refer you to the publicly available information accessible through the below
links in relation to Police and emergent technologies, including links to the Police Manual
chapter “Trial or adoption of new policing technology”. Although unlawful hunting is not
mentioned, the Police evaluation report titled “Remotely Piloted Aircraft Systems (RPAS)
Proof of Concept” may be of assistance to you.
https://www.police.govt.nz/about-us/programmes-initiatives/police-use-emergent-
technologies
https://www.police.govt.nz/sites/default/files/publications/rpas-poc.pdf
Trial or adoption of new policing technology - Police Manual chapter | New Zealand
Police
– Would NZ Police be open to working with a third-party organisation that
specialises in surveil ance or intelligence gathering specifical y for unlawful
hunting activities?
Agencies are not obligated to create new information or form opinions to respond to
requests under the OIA. The OIA applies only to information that the agency already
holds in its official capacity, therefore this part of your request relating to “working with a
third-party organisation” is refused under section 18(g) of the OIA, the information is not
held, and I have no grounds for believing that the information is held by another agency.
11. Complaint Follow-Up and Victim Communication What is the process for
following up with members of the public who report unlawful hunting?
Police has requirements for responding and fol owing up on complaints general y, based
on the urgency and seriousness of the offence. Follow-ups differ and consideration is
given in relation to whether it was an individual or corporate report, how it was initially
reported (111, or 105; report to local officer or station) and time delay between offending
to reporting. A key aspect is the obligation to maintain communication and updates to
victims and complainants.
– Are complainants informed of the outcome or progress of their report?
Please see my response to your question (directly above).
To answer this question would require a manual review of each 105 call to ascertain if it
was in relation to unlawful hunting, and then would require a review of each Enquiry and
Prosecution file coded 6337 (unlawful hunting), therefore this part of your request is
refused under section 18(f) of the OIA that the information cannot be made available
without substantial research and collation.
– Is there a standard victim communication protocol in such cases, especial y
where firearms are involved?
Victims’ rights are enshrined in legislation and policy, as such Police should always apply
policy and best practice when dealing with a victim regardless of the nature of the
offending.
– What is the official communication method used to update complainants on the
status of their report?
I refer you to my response to question 11 above.
Note there is no special or defined response specific to victims of unlawful hunting (in the
way there is in Family Harm). And too, rural communications to victims may differ slightly
to victims in urban centres due to geography, smal community norms, isolation, and
other factors.
12. Cultural and Community Engagement
Does NZ Police engage with rural communities, iwi, or hunting groups to raise
awareness and prevent unlawful hunting?
– Are there community liaison roles or outreach programmes in place to improve
communication and reporting in high-risk areas?
– Are there any initiatives or feedback mechanisms in place for rural communities
to express concerns or suggestions about the enforcement of unlawful hunting?
Te Tari Pūreke is committed to working with the firearms sector and the wider community
to listen and understand their ideas and feedback, as well as their challenges and
concerns. Along with Police and other stakeholders, Te Tari Pūreke is doing our part to
contribute to preventing unlawful hunting and wil continue to investigate reports of this
nature as they relate to firearms licence holders.
Te Tari Pūreke works closely with relevant groups, such as the Recreational Firearms
Users Working Group which includes organisations such as the Game Animal Council,
Federated Farmers of New Zealand, and the New Zealand Deerstalkers Association,
whom have considerable investment in addressing the unlawful hunting issue.
One of the Core Functions of Te Tari Pūreke is to promote the safe and legitimate use of
firearms. Lawful hunting access is one the key elements of legitimate firearms use, and
the consistent message is that al firearms users must have permission to use firearms on
the land that they hunt or shoot on. This has been communicated in the seasonal roar
and gamebird hunting messaging and in involvement in the National Goat Hunting
Competition Steering Group. The Te Tari Pūreke website has information on hunting
access and shooting on lifestyle blocks:
Hunting access and unlawful hunting activities | Firearms Safety Authority New Zealand
Shooting on rural lifestyle properties or smal holdings | Firearms Safety Authority New
Zealand
There are considerable penalties for unlawful hunting activities in both the Wild Animal
Control Act 1977 and the Wildlife Act 1953. Te Tari Pūreke has regular meetings with
Department of Conservation and Fish & Game staff, in which compliance and
enforcement issues are commonly raised.
The centralisation of the Te Tari Pūreke Resolutions and Firearms Licensing teams is
helping to give greater oversight of this type of il egal activity and wil lead to more
consistency in the way unlawful hunting offences are dealt with national y.
13. Use of Technology by Offenders Are there any trends or concerns regarding
the use of modern technologies by individuals involved in unlawful hunting (e.g.,
trail cameras, thermal scopes, night vision, drones)?
– Has NZ Police observed any increase in tech-assisted offending?
– Are officers trained or equipped to detect and respond to these evolving
methods?
Anecdotal evidence from DOC indicates an increase in the use of thermal imaging
devices in relation to unlawful hunting. Police and DOC work together to conduct
compliance operations due to their increasing use in relation to hunting.
I refer you to Te Tari Pūreke’s Firearm Safety Code (below) in regard to thermal imaging
under the sub heading “Shooting in low light – Night vision devices (NVD)”.
https://www.firearms safety authority firearm safety code
You have the right to ask the Ombudsman to review this decision if you are not satisfied
with the response to your request. Information about how to make a complaint is
available at:
www.ombudsman.parliament.nz.
For your information, Police has developed a process for proactive release of information,
so the anonymised response to your request may be publicly released on the New
Zealand Police website.
Nāku noa, nā
Mike Mcllraith
Kaihautū Kōtui | Director Partnerships & Communities
Te Tari Pūreke | Firearms Safety Authority
