Firearms License 2026 and the New Arms Act: A Guide for Entrepreneurs
The Firearms and Ammunition Act (No. 90/2024 Coll.) brings the most significant legislative change for businesses in recent years. Firearms licenses are being reduced to three categories (ZL1, ZL2, ZL3), a mandatory position of chief armorer is being introduced, rules for recording firearms and ammunition are changing, and companies must update their internal regulations by the end of 2026. This guide by attorney Jiří Mlčák, a specialist in firearms law and the arms industry, covers all key changes and their practical implications.

Firearms Licenses 2026: New ZL1, ZL2, and ZL3 Categorization

What are firearms licenses and who needs them

Unlike firearms permits, which were also affected by the legislative change, firearms licenses primarily concern businesses. One of the main changes is the new categorization of firearms licenses, the document that authorizes its holder to handle firearms and ammunition. Before January 2026, there were 10 groups (A through J); today, only three remain (ZL1, ZL2, ZL3).

ZL1 Firearms License: For firearms dealers, manufacturers, and importers

The ZL1 firearms license is the broadest business license—it consolidates the former groups A through E under the old law. It is obtained primarily by manufacturers of firearms and ammunition, firearms dealers, importers, gunsmiths, and companies involved in the transport of firearms and ammunition.

ZL1 authorizes:

  • development,
  • manufacturing,
  • repairs,
  • testing,
  • sales,
  • purchasing,
  • storage,
  • transport,
  • and brokering these activities. 

Firearms License ZL2: For shooting ranges, clubs, and security services

The ZL2 firearms license corresponds to the former groups F through J. It is most commonly required by:

  • shooting range operators,
  • sport shooting clubs,
  • hunting associations,
  • private security services,
  • museums,
  • collections,
  • zoological gardens.

It allows for the handling of firearms and ammunition to an extent that does not require the "higher" ZL1 license.

ZL3 Firearms License: For non-commercial purposes (collecting and 3D printing)

New special ZL3 group license, which, conversely, must not be issued for business purposes. It is intended for non-business individuals for one-off purposes that would otherwise require a ZL1 or ZL2 group firearms license (typically, this may include collectors of category R1 weapons or one-off self-manufacture of a weapon). A ZL3 license holder cannot simultaneously hold a ZL1 or ZL2 license.

Jiří Mlčák is an attorney, a hunter, and an active firearms license holder himself. He therefore assesses the qualifications of a chief armorer from the perspective of someone who actually handles firearms.

Chief Armorer: New requirements starting in 2026

Who is a chief armorer and what is their role

A new position of so-called chief armorer is being introduced, which every firearms license holder must appoint. This is a professionally qualified person who bears responsibility for the handling of weapons and ammunition, must hold a firearms license, possess verifiable minimum professional experience in the field, and must also have a specific relationship with the business owner, typically as an employee who is actively involved in their operations. 

However, the applicant themselves can also be the chief armorer (in the case of a sole proprietor), or it can be a partner or a member of the applicant's statutory body (for example, their executive director).

Who can be a chief armorer: qualification requirements

  • There can only be one chief armorer
  • The chief armorer does not replace the position of armorer under the old law 
  • The obligation to have a chief armorer does not prevent a business owner from appointing additional armorers as needed to be responsible for specific tasks within their operations 
  • An armorer already appointed by a firearms license holder under the old law does not automatically become the chief armorer when the new law takes effect
  • The chief armorer must hold an extended firearms license
  • The chief armourer must have at least a secondary education with a vocational certificate in a field focused on weapons or ammunition, or have at least 3 years of experience in handling weapons or ammunition.
  • The chief armourer of a ZL2 licence holder may hold only a general firearms licence, provided they have held it for at least 3 years.
”Appointing a chief armourer is not just an administrative formality – this person assumes responsibility for the handling of weapons within the company. We recommend paying maximum attention to the selection process and, in case of doubt, consulting their qualifications with a lawyer,” says attorney Jaroslav Čižmář.

Professional competence for firearms licence holders

Another new development for entrepreneurs applying for a firearms licence (i.e., applicants for groups ZL1 and ZL2, see above) is that, in addition to the condition of integrity and reliability, they must also meet the requirement of professional competence. This is not an entirely new requirement – while the old Act No. 119/2002 Coll., on Firearms and Ammunition, did not explicitly require it, applicants essentially could not do without it.

Participating persons: Registration in the CRZ and mandatory training 

Who is a participating person under the new law

Firearms licence holders are now required to register in the Central Arms Register (CRZ) all persons involved in the handling of firearms or ammunition as part of their business activities. Business owners are also required to register these individuals retroactively, for which the new law provides a 12-month grace period from the date it takes effect.

When a participating person must hold a firearms license

In certain cases, participating persons must also be holders of a firearms license. And if the participating person performs work involving the protection of life, health, or property (such as security services), a standard firearms license is not sufficient – they must hold an extended firearms license.

When a participating person does not need a firearms license

However, there are exceptions where a participating person is not required to hold a firearms license. In short, this applies to, for example:

  • warehouse staff,
  • shipping personnel,
  • CNC machine operators.

For the exemption to apply, the employer must hold a ZL1 group firearms license, and it must be ensured that no weapons or ammunition are entrusted to, handed over to, or transferred to the participating person and that this person does not handle, carry, or fire the weapon themselves. 

Furthermore, their activities must be supervised by a holder of an extended firearms license – or by a person with so-called registered authorization. The same rules apply to the operation of vehicles used to transport weapons or ammunition: if the driver does not handle the weapons themselves in any way, they are not required to hold a firearms license.

Mandatory annual training for participating personnel – OSH for firearms

"The law also newly imposes an obligation on the entrepreneur to ensure occupational safety training for participating personnel at least once a year regarding the performance of their tasks and to record this in the CRZ," adds OSH expert and attorney, Ondřej Chlada.

Missing or poorly documented training is one of the most common reasons for fines. Contact us for a non-binding consultation – write to info@endors.cz or use the contact form.

Internal regulations for firearms license holders: What must be included

The internal regulation is a binding documentthat governs the entrepreneur and their employees, and its compliance with the law is a prerequisite for the issuance of a firearms license.

What the internal regulation must contain under the new law

The specific content varies depending on the scope of the entrepreneur's activities, but in general, it primarily regulates the organization of handling firearms and ammunition, the designation of persons responsible for individual activities, or the method of recording firearms and ammunition.

The internal regulation must be followed not only by the entrepreneur but also by their employees. It is therefore important that it is set realistically and corresponds to the actual agenda and the functioning of your processes. We therefore do not recommend setting rules that are unnecessarily strict or creating obligations that you will not be able to fulfill in the long term in practice. Failure to comply with internal regulations can lead to fines reaching hundreds of thousands of crowns.

A simple, clear, and actually followed internal policy is always better than an overly detailed and strict one that exists only on paper and is ignored in practice, notes the attorney, Jiří Mlčák.

Why you should avoid universal internal policy templates

It must be emphasized that there is no such thing as a universal internal policy template. For this reason, we do not recommend adopting or copying policies from others without adapting them to your own processes and legal requirements. You could end up committing yourself to obligations that you do not actually fulfill.

We will prepare a custom internal policy for you

"Given that the new law has established some new content requirements, we recommend that all firearms license holders gradually update their internal policies throughout 2026 to comply with these new standards. If you are unsure, you can always turn to us. At endors, we will prepare an internal policy tailored to your needs," says labor law and OHS expert, attorney Ondřej Chlada. 

Contact us for a non-binding consultation — email info@endors.cz or use our contact form.

Submit internal policy changes to the Police of the Czech Republic

Also, do not forget that every change to an internal policy must be submitted to the Police of the Czech Republic. Failure to do so will render the regulation ineffective. Therefore, once you have brought the regulation into compliance with the new legislation, remember to fulfill this obligation.

Firearms Record Log: What to track and how to maintain it

What is a firearms record log and why should you keep one

For firearms license holders, the new law introduces an additional requirement to maintain, alongside the Central Firearms Register (CRZ), a so-called record log of certain data previously included in the CRZ or partial records. 

The previous law required businesses to maintain records of category A, A-I, B, and C firearms, ammunition for these firearms, and category C-I firearms, either:

  • in paper form in a record book, 
  • in electronic form, 
  • or within the CRZ. 

However, these record-keeping obligations are no longer present in the new legislation.The new Act on Firearms and Ammunition simplifies record-keeping , and all necessary data is now found exclusively in the record log or the CRZ.  

What forms of record logs are permitted

Any internal record-keeping system can serve as an inventory, provided it is convenient for you and allows for the clear and verifiable determination of the required information to confirm its accuracy against reality. 

Suitable options include an economic information system or records maintained in another manner, whether in electronic or paper form (such as Excel or a physical logbook), or it may be part of records already maintained by the entrepreneur, such as accounting software or an inventory management system.

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Where to specify the form of the inventory records in your documentation

The only requirement is to state the form of the inventory records within your internal regulations. Unlike the Central Firearms Register (CRZ), the inventory records are not available online in real-time, but you must still ensure they contain up-to-date information for inspection purposes. 

The new law establishes a mandatory minimum of informationthat you must include in such records. However, it is up to you what additional details you choose to track—for example, you can customize it to monitor the movement of firearms within your operations. 

Mandatory minimum for inventory records

  • Inventory and identification data for NO category firearms (includes most firearms previously classified as category D)
  • Type and quantity of firearm components capable of automatic fire 
  • Type and quantity of semi-finished products main parts of category R1, R2, R3, R4 firearms 
  • Personal identification detailsto whom the firearms license holder has transferred or assigned the firearm or its regulated component

Firearm categories 2026: R1, R2, R3, R4, PO, NO and ammunition categories S1–S4

The new law also brought changes to firearm and ammunition categories, which primarily consist of renaming and merging existing categories and the types of firearms within them, thereby streamlining the regulations and clarifying any ambiguities regarding the classification of the same firearms into different categories.

Firearm categories subject to registration (R1–R4)

Firearms subject to registration are now divided into groups R1 through R4:

  • R1 – prohibited firearms, such as automatic firearms or firearms with special characteristics (replaces the former category A);
  • R2 – firearms that can only be possessed with an exemption, typically semi-automatic firearms derived from automatic firearms (replaces the former category A-I);
  • R3 – firearms requiring a purchase permit, particularly short semi-automatic pistols or long guns with higher magazine capacity (replaces the former category B);
  • R4 – firearms that only need to be registered after acquisition, such as semi-automatic and repeating firearms not classified in higher categories (replaces the former category C).

Special firearm categories: PO (subject to notification) and NO (not subject to notification)

In addition to these groups, there are two special categories of firearms for which no firearms license is required to acquire or possess:

  • PO (firearms subject to notification) – this includes, for example, expansion firearms, certain gas-powered firearms, or Flobert firearms manufactured before 2026. The owner is only required to notify the police after acquiring the firearm (replaces the former category C-I);
  • NO (firearms not subject to notification) – includes, for example, air guns up to a specified caliber, historical firearms, airsoft guns, and paintball markers. These firearms can continue to be acquired freely from the age of 18 without registration (replaces the former category D)

Ammunition categories 2026: S1, S2, S3, S4

Ammunition is now divided into its own categories, labeled S1, S2, S3, and S4, based on its characteristics and level of regulation, departing from the old legislation.

Category S1 ammunition primarily includes cartridges with projectiles containing explosive or incendiary charges, armor-piercing projectiles, or cartridges undetectable by detection and X-ray equipment. Category S2 includes ammunition with tracer projectiles or specially designed projectiles intended to increase wounding effect (Note: this does not include standard soft-point bullets or projectiles that only exhibit partial design elements promoting deformation or fragmentation, provided such ammunition was not considered prohibited under the old Firearms Act). 

Category S3 includes standard ammunition intended primarily for firearms subject to registration, including blank cartridges designed to simulate live fire. Category S4 then includes ammunition intended for most PO and NO category firearms.

"In practice, if you are unsure which category to classify ammunition into because its technical characteristics theoretically place it in multiple categories, it is classified into the most strictly regulated one," adds attorney Jiří Mlčák.
Contact Jiří Mlčák at info@endors.cz or at +420 601 501 630.

Are you dealing with the new Firearms Act in your company?

We will help you with the revision and preparation of internal regulations, the appointment of a chief armorer, the registration of participating persons in the Central Firearms Register, the setup of inventory records, and representation during inspections by the Police of the Czech Republic. 

Consulting is provided by attorney Jiří Mlčák, who has long specialized in firearms law and is himself an active holder of an extended firearms license.

Fill out the form or email us at info@endors.cz. We will get back to you within 24 hours, and the initial assessment of your situation is completely non-binding.

Article author: Jiří Mlčák

Jiří Mlčák is an attorney, hunter and also an active holder of an extended firearms license. He focuses primarily on the arms industry, capital market regulation, and contract law. In the arms industry, in addition to legal consulting, he also participates in negotiations with foreign partners. He also gained valuable experience at the Ministry of Industry and Trade and at the High Court in Prague.

The new law affects not only business but also the weapons you hold personally. Attorney Jiří Mlčák has written about the changes for individual owners in a separate article.
‍→A legal guide for firearms license applicants and owners of weapons & ammunition.

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