Intimate Partner Gun Violence and Femicides: NAWL Urges Public Safety Minister Gary Anandasangaree to Broaden the Definition of Protection Orders

Urgent: Defining Protection Orders Broadly under the Firearms Licenses Regulations to Address Intimate Partner Gun Violence and Femicides  

Dear Minister Anandasangaree,  

Last week, the government concluded its second consultation on the regulatory definition of “protection order” for the purposes of firearm license revocation under former Bill C-21. One of the objectives of Bill C-21 was to protect women and children from intimate partner gun violence by ensuring that individuals who are subject to a protection order cannot hold a firearms licence and that their licences are revoked. To fulfill this objective, and to respect Parliament’s clear intent, the regulations must define “protection order” to include any order made by a court or other competent authority, without limiting the definition to peace bonds or to civil orders.  

Parliament deliberately adopted a broad definition of protection order in former Bill C-21 to ensure that any binding order made in the interest of the safety or security of a person, civil or criminal, would trigger licence revocation. Despite this clear legislative direction, the proposed regulations take a narrow approach that excludes certain criminal protection orders like bail release orders and probation orders.  

Excluding these orders creates an arbitrary and dangerous distinction. A survivor who has obtained a peace bond where no charges were laid will be protected by the automatic license revocation, while a survivor whose abuser has been charged and released on bail with similar no-contact conditions may not. There is no justification for Public Safety Canada to narrow a clearly drafted statute in a manner that creates such avoidable risks and introduces uncertainty for survivors of family violence and their children. Survivors should not be left with less protection because of the procedural path their case followed. 

Proposed Solution  

The only way to respect legislative intent and protect women’s safety is to remove the word “civil” from the proposed definition of “protection orders”, so that it reads as follows: 

1.01(1) For the purposes of the Act, protection order means an order made by a court or other competent authority in the interests of the safety or security of a person, including an order that prohibits the person from 

(a) being in proximity to an identified person or following that person from place to place; 

(b) communicating with an identified person, either directly or indirectly; 

(c) being at a specified place or within a specified distance of that place; 

(d) engaging in harassing or threatening conduct directed at an identified person; 

(e) occupying a family home or a residence;  

(f) engaging in family violence as defined in subsection 2(1) of the Divorce Act; or 

(g) engaging in domestic violence as defined in subsection 70.1(2) of the Act. 

Survivors Cannot Afford to Wait  

NAWL has been calling for the development of regulations and emphasizing the urgency of fully implementing Bill C-21 since 2022. Despite these calls, there were significant delays in proposing regulations, leaving women and children unprotected. The proposed narrowing of the definition of protection order further compromises the safety of survivors of intimate partner violence by excluding situations where courts have already identified a risk of violence. Survivors of intimate partner violence cannot afford further delay or vacillation.  

In addition to the above, over 50 organizations have provided Public Safety Canada with a list of recommendations to support the effective implementation of Bill C-21, including directives for Chief Firearms Officers, training for police and the courts and public education. Implementing these measures alongside strong regulations is critical to addressing the twin epidemics of intimate partner gun violence and femicide. A robust firearm protection regime is a matter of life and death; it determines whether women survive intimate partner violence or are spoken of in the past tense. 

Sincerely, 

Suzanne Zaccour, Director of Legal Affairs, National Association of Women and the Law (NAWL) 

Read NAWL’s Legal Brief: Consultations on Proposed Regulations Amending the Firearms Licences Regulations – Protection Orders (March 2026)