Who may lawfully store the firearms
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. Regulation 103(2) sets the standard: a storage facility that meets Regulation 86, or a licensed heir under a letter of consent. Only a person who may lawfully possess a firearm may hold it for the estate.
| Who may store | On what basis |
|---|---|
| A licensed dealer | In the safe or strongroom specified on its licence, for a person who may lawfully possess the firearm (Regulation 67). Each firearm is entered in the dealer's Firearms Safe Custody Register (Regulation 37(3)). SAPS guidance is that where there is no proper storage, arrangements must be made with a licensed dealer. |
| An heir who already holds a firearm licence | Under the executor's letter of consent, filed with the Designated Firearms Officer for the area where the heir lives (Regulation 103(2)). This costs the estate nothing in storage. |
| Before appointment: the nominated executor or, where there is none, an heir, next of kin or close relative | Under a section 21 temporary authorisation on form SAPS 518, until the executor's duties under Regulation 103(2) take effect (Regulation 103(1)). |
| An attorney administering the estate for the executor | Under a section 21 permit, until the firearms are transferred or surrendered, subject to Regulations 67(1), 67(4) and, so far as it applies, 86 (Regulation 103(11)). |
| Nobody else | A family member or friend without a licence, permit or authorisation for the firearm may not hold it, and giving them possession is an offence (sections 3 and 120(10)). |
Why the dealer must be licensed
A dealer's licence is tied to the premises specified on it, and a dealer stores firearms for others only in the safe or strongroom named in that licence (Regulations 67(3) and 86(2)). The Supreme Court of Appeal held in 2023 that storing firearms for others forms part of the trade in firearms, so a business that only stores them still needs a dealer's licence. No separate storage licence exists.
A dealer may not store firearms for another dealer. A move between dealers is therefore arranged as a release to the estate and a fresh receipt by the new dealer, never dealer to dealer. The High Court order of 15 September 2026 declares that a licensed dealer may lawfully receive a firearm from a deceased estate acting through its appointed executor; legal updates states where that order stands.
What a dealer records
A dealer enters every firearm it holds for someone else in its Firearms Safe Custody Register (Regulation 37(3)). The entry is signed when the dealer receives the firearm, by the executor or, where a permitted transporter delivers, by its staff for the executor.
- On receipt: the date, the depositor's names, identity number and address, the firearm's make, type, calibre and serial number, the licence number and its date, and the signature.
- On release: the date of return, transfer or disposal, and the recipient's signature.
- The register's pages are numbered, and signed and date-stamped by the Designated Firearms Officer before use. A dealer keeps its registers for 10 years at the licensed premises (Regulation 37(5)(a) and (10)).
- The firearm is held unloaded, inaccessible and attached with a secure locking device to a non-portable structure (Regulation 67(4)), in a safe or strongroom that meets the prescribed standard, SANS 953-1 for safes and SANS 953-2 for strongrooms (Regulation 86(2)).
- The executor receives a custody receipt. Keep it on the estate file as evidence of where each firearm is held.
Who pays, and what Firearmdesk charges
The estate pays. SAPS guidance places dealer storage for the estate's account, and the executor keeps a voucher for each charge for the liquidation and distribution account. How a charge ranks in that account, and how the Master's examiner treats it, is not settled by any published directive on firearm storage; confirm with the Master's office concerned.
Firearmdesk publishes one fee schedule, version 3, effective 4 October 2026, set out in full on the fees page. Each fee is shown once, as the total charged. Firearmdesk is not registered for VAT, so no VAT is added to our fees. The charges that apply to storage are these.
| Charge | Amount |
|---|---|
| Firearms Control Act compliance services to the executor, custody matter (per matter) | R2,242.50 |
| Firearms Control Act compliance services to the executor, in-situ matter where a licensed heir keeps the firearms (per matter) | R1,437.50 |
| Custody coordination (per firearm received into custody, charged once and not by the month) | R632.50 |
| Licensed dealer intake, at cost (per firearm; the dealer's own fee, with no mark-up) | R200, plus the dealer's VAT where it is registered for VAT |
| Licensed dealer storage, at cost (per firearm per month from day 15 after receipt; the first 14 days are not charged; the dealer's own fee, with no mark-up) | R110, plus the dealer's VAT where it is registered for VAT |
| Written valuation | R402.50 for the first firearm, plus R172.50 for each additional firearm |
How storage is charged and invoiced
- The dealer's intake and storage apply only once a firearm enters custody. Firearmdesk pays the dealer on the executor's behalf and recovers exactly the dealer's fees, with no mark-up.
- The custody coordination fee covers allocation to a licensed dealer, booking the transporter for the estate, pre-advice, receipt evidence, the monthly statements and release coordination. It is charged once, however long the firearm stays.
- Two itemised invoices per matter, at intake and at release, addressed to the estate care of the administering attorney. The dealer's intake and storage are invoiced at release, after Firearmdesk has paid the dealer; the storage is shown on a monthly statement as it accrues.
- Fees are paid by EFT. Payment status never affects whether a firearm is released.
- In an insolvent estate the dealer's storage is recovered from the estate for no more than 6 months.
- The schedule in force when the executor signs the custody mandate applies to the whole matter.
How the firearms get to the dealer
Only the person who holds the licence, permit or authorisation for a firearm may transport it to and from where it is stored (Regulation 86(4)(b)). Anyone who transports a firearm for reward needs a firearm transporter's permit (section 86(1)) and the holder's prior written consent (Regulation 70(a)).
- Firearmdesk never stores, carries or transports a firearm, and sells no collection or transport. On Firearmdesk matters nobody at the firm carries one.
- Where a licensed heir who will inherit already holds the firearms, they stay with that heir under the executor's written consent.
- Otherwise Firearmdesk books a permitted transporter for the estate. It collects the firearms where they are kept, on the executor's written consent, and delivers them to the dealer. It contracts with and invoices the estate; anything Firearmdesk pays it for the estate is recovered at cost, and Firearmdesk charges nothing for carriage.
- An executor named in the letters may also deliver in person. Whether an appointed executor without a section 21 authorisation may carry a firearm personally is not settled by any SAPS text; confirm with the Designated Firearms Officer before relying on it.
What storage adds up to
The table shows the dealer's storage for one firearm over whole months from day 15 after receipt, at cost. Intake and custody coordination are charged once and are not in these totals.
| Months of storage | Dealer's storage, at cost |
|---|---|
| 6 months | R660, plus the dealer's VAT where it is registered for VAT |
| 12 months | R1,320, plus the dealer's VAT where it is registered for VAT |
| 18 months | R1,980, plus the dealer's VAT where it is registered for VAT |
Weigh storage against value early
Storage accrues every month while a firearm waits for a licence, a buyer or an instruction, so weigh it against the firearm's value early. A licensed heir who stores the firearm under the executor's letter of consent avoids the charge.
- On Firearmdesk matters the executor receives a written economic review, setting the firearm's value against the charges so far, at months 6 and 12, and is asked for a disposition instruction at month 18.
- Where the valuation is under R3,500, the executor receives written advice on whether a sale is economic before instructing one.
- A transfer to an heir ends storage once the Central Firearms Registry has decided the heir's licence. Only the Registry decides it, and no provider can shorten that.
- Where no heir wants a low-value firearm, a sale through a licensed dealer, deactivation or surrender ends the charge.
- On a sale the dealer deducts its commission, 10% of the price with a minimum of R400, plus VAT if the dealer is registered for VAT. Firearmdesk takes no share of it.
How Firearmdesk helps
Firearmdesk allocates each firearm to a licensed dealer, books the permitted transporter for the estate where the firearms must move, keeps the receipts and the monthly storage statements on one matter record, and coordinates the release. 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 and the work starts with authority and documents.
Questions
Who may lawfully store firearms from a deceased estate in South Africa?
A person who may lawfully possess them: a licensed dealer, which holds them in the safe or strongroom named on its licence, or an heir who already holds a firearm licence, under the executor's letter of consent filed with the Designated Firearms Officer (Regulation 103(2)). Before appointment, a holder of a section 21 authorisation may possess them, and an attorney administering the estate may store them under a section 21 permit (Regulation 103(11)).
Can a family member keep the firearms until the estate is wound up?
Only one who holds a licence, permit or authorisation for the firearm. Holding a firearm without one is an offence under section 3 of the Firearms Control Act, and giving possession to someone who may not hold it is an offence under section 120(10), even where the person is an heir.
What does a licensed dealer record when it receives an estate firearm?
An entry in its Firearms Safe Custody Register: the date of receipt, the depositor's details, the firearm's make, type, calibre and serial number, the licence number and date, and the signature, and later the date of return, transfer or disposal with the recipient's signature (Regulation 37(3)). Where a permitted transporter delivers, its staff sign for the executor. The dealer keeps its registers for 10 years.
Who pays for storing the firearms, and what does it cost?
The estate. The licensed dealer charges R110 per firearm per month from day 15 after receipt and R200 per firearm for intake, plus the dealer's VAT where it is registered for VAT; both are passed on at cost with no mark-up. Firearmdesk's custody coordination fee is R632.50 per firearm, charged once. See the fee schedule.
Does storage with a licensed heir cost anything?
It costs the estate nothing in storage. The executor gives the heir a letter of consent and files a copy with the heir's Designated Firearms Officer (Regulation 103(2)). Where a licensed heir keeps the firearms, Firearmdesk's compliance fee is R1,437.50 per matter.
How do the firearms get to the dealer?
Where a licensed heir who will inherit holds them, they stay there. Otherwise Firearmdesk books a permitted transporter for the estate, which collects them where they are kept, on the executor's written consent, and delivers them to the dealer; it invoices the estate, and Firearmdesk charges nothing for carriage. An executor named in the letters may also deliver in person.
Can a firearm be moved from one dealer to another?
Not dealer to dealer: a dealer may not store firearms for another dealer, so the executor takes the firearm back by a release to the estate and the new dealer makes a fresh receipt. Firearmdesk charges R402.50 for a change of custodian only when the executor asks for the move in writing.
When can firearms go into dealer custody 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. Referral, verification of the executor's authority and the documents proceed from the day of referral. See legal updates.
Sources
- Firearms Control Act 60 of 2000 (SAFLII): sections 3, 86, 120 and 147
- Firearms Control Regulations, 2004 (SAFLII): regulations 37, 67, 70, 86 and 103
- SAPS: questions on firearms in deceased estates
- Outdoor Investment Holdings (Pty) Ltd v Minister of Police [2023] ZASCA 72: dealer storage and licence waiting times
- High Court, Gauteng Division, Pretoria, case 2025-104362, 15 September 2026: judgment (PDF); current status on the legal updates page
- Firearmdesk fee schedule, version 3: effective 4 October 2026