Who may deal with the firearms
The executor. Section 147 of the Firearms Control Act requires an executor who comes into possession of a firearm licensed to the deceased to store it as prescribed, and Regulation 103 sets out the notices, reports and storage duties. SAPS describes the executor as the custodian of the firearm until it is disposed of or licensed.
The attorney administering the estate. An attorney rendering a professional service in the administration of the estate on the executor's behalf may, under a section 21 permit, store the estate's firearms until they are transferred or surrendered, and must then comply with Regulation 103 as if they were the executor (Regulation 103(11)).
What doing it yourself involves
- Establish which firearms the deceased held, from licence copies or a record from the Central Firearms Registry.
- Before appointment, if someone must hold the firearms, apply for a section 21 authorisation on form SAPS 518.
- On appointment, arrange storage that meets Regulation 86: a licensed dealer, or a licensed heir under a letter of consent filed with the heir's Designated Firearms Officer.
- Within 14 days of appointment, send the inventory and notice to the Registrar, and file the acknowledgement.
- Report to the Registrar at least every three months until every firearm is dealt with.
- Ask each heir whether they want the firearm transferred, sold, deactivated or surrendered, and obtain a valuation where the inventory or a sale needs one.
- Move a firearm only through a person holding authority for it or a permitted transporter, with the holder's written consent.
- Instruct the dealer on a sale, follow each heir's licence application, and keep a voucher for every charge.
- Obtain the Registrar's notification that every firearm has been transferred before applying to finalise.
When the executor usually manages alone
- One or two firearms, and an heir who already holds a firearm licence and can store them under the executor's letter of consent. This costs the estate nothing in storage.
- The executor or the firm already works with a licensed dealer near where the firearms are.
- The heirs have decided what they want, and the firearms, the heirs and the dealer are in the same area.
- Someone at the firm has time to diarise the three-monthly reports and follow each application with the Registry.
When a specialist is worth it
- Several firearms with different routes: one to an heir, one for sale, one for surrender.
- Heirs far apart, or far from the firearms, so storage and handover need coordinating across regions.
- No licensed heir, so the firearms need dealer storage while licences are applied for or a sale is arranged.
- No existing relationship with a licensed dealer or a permitted transporter.
- Attorney time: the notices, three-monthly reports and follow-up run for months and add up in fee-earner hours.
- Evidence for the file: a receipt for every movement, the valuations, the executor's instructions and the settlement records, in one place.
What to ask any provider
Whoever the executor uses, these questions show how the firearms and the estate's money will be handled.
- Who holds the firearms, and under which licence? A dealer stores firearms for others in the safe or strongroom on its licence, and only for a person who may lawfully possess them.
- Is each firearm entered in the dealer's Firearms Safe Custody Register, signed by the executor or by a permitted transporter's staff for the executor, and does the executor receive a receipt?
- Who transports the firearms? Does the transporter hold a firearm transporter's permit, and is the executor's written consent obtained first?
- Are the fees published, and is every charge itemised on an invoice to the estate?
- Do sale proceeds go straight from the dealer to the estate or the attorney's trust account, or through the provider?
- How is storage reported as it accrues, and when is the executor asked to weigh it against the firearm's value?
- Are licence applications and other Registry steps reported as pending until there is evidence of a decision?
How Firearmdesk does it
Firearmdesk provides Firearms Control Act compliance services to the executor: the Regulation 103 inventory and notices, the section 21 authorisation application, the executor mandate, custody allocation to a licensed dealer, a permitted transporter booked for the estate where the firearms must move, the evidence record and the closure pack. Fees are fixed and published, the estate is invoiced care of your firm, and sale proceeds never pass through Firearmdesk. Dealer custody under the order of 15 September 2026 opens once a check of the court file confirms that no late application for leave to appeal was lodged. That check is under way. Refer an estate or read the fee schedule.
Questions
Can the estate's attorney deal with the firearms instead of the executor?
Yes. An attorney administering the estate on the executor's behalf may, under a section 21 permit, store the estate's firearms until they are transferred or surrendered, and must then comply with Regulation 103 as if they were the executor (Regulation 103(11)).
Does the executor stay responsible if a specialist is used?
Yes. SAPS describes the executor as the custodian of each firearm until it is disposed of or licensed. A provider carries out the work on the executor's instructions.
Is a specialist worth it for a single firearm?
Often not, where an heir who already holds a firearm licence can store it under the executor's letter of consent: that costs the estate nothing in storage. It is more often worth it where no heir is licensed, the heir lives far away or the executor has no dealer to use.
Can a specialist speed up an heir's licence?
No. The Central Firearms Registry decides licence applications, and no provider can shorten that. A provider can tell the heir what the application needs and keep the firearm in lawful storage meanwhile.
What does a specialist cost?
It depends on the provider and on where the firearms are kept. Firearmdesk's compliance fee is R2,242.50 per custody matter, or R1,437.50 where a licensed heir keeps the firearms; per-firearm charges are on the fee schedule.
Sources
- Firearms Control Act 60 of 2000 (SAFLII): sections 3, 21, 86, 147 and 148
- Firearms Control Regulations, 2004 (SAFLII): regulations 37, 67, 70, 86 and 103
- SAPS: questions on firearms in deceased estates
- Firearmdesk fee schedule, version 3: effective 4 October 2026