NatureScot has launched a public review of its General Licences for wildlife management, to which both individuals and organisations are invited to respond. We’d ask that you consider taking the time to do so before it closes on 31 August 2026. Every voice counts, and together we can really make some noise.
Once you click on the above link the consultation homepage page will show you various tiles, covering broader general licence questions and on the individual licences themselves. You can click on each of these in turn to submit your thoughts. The review allows you to comment freely without boxing in responses too much.
It also has a broad scope, and so we (Wild Justice) have considered carefully which parts we respond to with our time and resources, and which we don’t. Of course you can also decide if there are other aspects of the review that you’d like to comment on yourself.
You can read our response, in full, below. Feel free to use this to help form your own individual responses, though we’d ask that you don’t copy and paste from our response (please), as comments written in your own words are very important.
You can read our response to the consultation in full, below.
The original questionnaire text is in black,
Wild Justice’s responses are in blue
Broader questions on General Licences
See a list of all 16 Proposed General Licences for 2027
N/A
Yes No
Please explain your answer
Wild Justice is concerned that this general licence consultation is being undertaken before the long-awaited publication of NatureScot’s Species Licensing Review, despite this review apparently being completed last year. The results of that review should inform the future direction of species licensing, of which general licences are a significant part, and it is unacceptable that this review is unavailable to inform respondents to this latest consultation.
General licences were introduced over 30 years ago, and the so-called “light touch” approach to permit the killing of otherwise protected species has continued since then, with only relatively minor adjustments to the licences over that period. It is therefore welcome that a thorough review is now taking place.
We have serious concerns about the use of general licences, rather than individual licences, to authorise otherwise illegal activities. They may offer a sensible approach in limited circumstances, provided they are worded carefully, with all the appropriate terms and conditions in place, and where they authorise activities that will have a minimal impact on wildlife. But when it comes to the killing of wildlife, this approach is badly flawed; there is a real danger that the primary motivations here, those of cutting costs and making things easier for licence users, are at the expense of unacceptable harms to our wildlife.
We believe that the current system of general licences in Scotland is out-dated, unaccountable, and not fit for purpose. The licensing authority publishes these licences annually, but has no idea who, what, where or how these licences are used and has no data on which to base future licensing decisions, or to assess the impact or effectiveness of current licences.
We see no reason why those killing birds (or animals) should not be subject to the same regulations – having a permit/licence and submitting a return – as those who catch and release them for the purposes of ringing or other scientific study. Having such data would allow informed decisions on future licences, where currently this is unable to happen.
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Please explain your answer
We believe that the killing of protected species under licence should be subject to registration and subsequent compliance monitoring, and those undertaking the activity should submit an annual return. This is not currently the case.
NatureScot’s website states that “General licences cover relatively common situations where there’s unlikely to be any significant conservation impact.” The vagueness of the language, “relatively common situations” gives little confidence that the licences are based on clear, defined issues in relation to whether there is an evidenced need to carry out the killing of otherwise protected wild birds.
Secondly, given the almost total lack of regulation applied to the use of the licences (the much referred to “light touch approach”), the licensing authority will have little or no information as to the level of use, location, timing or the nature of use of these licences. Therefore, it is difficult to see how it can be possible to measure the conservation impact other than by relying on vague guesswork. It should be noted that our concerns extend to the impacts on non-target species as well as target species and also to circumstances where licences are deliberately abused or misused.
Some of the proposed licences for 2027 state that “they cover situations where we are satisfied that there is no other satisfactory solution in respect of the species to which they relate and the circumstances in which the licensed action may be taken.” This is an unacceptable and vague principle given the lack of regulation and oversight of the licences. Under this system NatureScot will be unaware of the circumstances used to justify any single use of a general licence, let alone make a judgement on whether a non-lethal alternative may be available, or more appropriate, or even considered. Indeed, we suggest that this notion gives carte-blanche to a shoot-on-sight approach to some species by some land managers.
We also note the following from the ‘Statement of Reasons’ for some of the licences issued for 2026 – “it is a condition of the licence that Licence holders are expected to use non-licence actions and licensed actions in a hierarchical approach, with licensed actions such as lethal control being the last available action.” While this is perhaps a laudable aspiration, it does not feature as a licence condition for 2027, and contradicts NatureScot’s statement on each licence (that they are satisfied that there is no other satisfactory solution), and is of course wholly unenforceable.
We noted the publication of ‘Statements of Reasons’ for the General Licences available in 2026, and are assuming this will be the case for licences published for 2027. It is worrying to note that even though in some cases these licences acknowledged that evidence of a conservation impact by certain species was “limited” or “relatively weak” or “only account for a small proportion of nest predation events”, species’ control under the licence was still permitted. We discuss this further in our responses to the proposed licences for 2027.
Select one option
Yes No Some, not all
Definition – Returns are information submitted to NatureScot by the user of a licence, outlining what licenced actions were done that year. Returns are often due annually and expected to be provided within a month of the licence expiring.
Wild Justice supports the record keeping and a reporting requirement to NatureScot being a condition of licences GL01, GL02, GL03 and GL14.
We are aware that some conservations organisations not only publish an annual summary of vertebrates controlled across land holdings, but also apply for NatureScot licences to allow employees to engage in the capture, possession, release, disturbance, photography or marking of a wide spectrum of species as part of specific conservation work. Similarly, we are aware that other organisations such as the Scottish Raptor Study Group workers and bird ringers require a licence and extensive training to undertake their studies. All these licences are issued with a reporting requirement to either NatureScot or British Trust for Ornithology as a condition.
Given the above, it is inconsistent that an unknown number of anonymous individuals, under the auspices of a General Licence, can legally kill or take a large, but currently unknown, number of birds and animals in Scotland every year, without the Scottish Government’s statutory nature conservation advisors, NatureScot, having any idea of what, where, by whom and through which methods this is taking place.
In most other European countries these are mandatory requirements. We strongly support having a statutory reporting requirement, to provide statistics for policy decision-making and to allow the annual publication of anonymised statistics for transparency and public scrutiny.
Select one option
Yes No
Please explain your answer
We do not believe that there is robust, peer-reviewed evidence to support adding lethal control of any further species to existing licences or for the creation of new general licences.
[Further questions in this section relate purely to administrative issues related to the form submission]
This question is required.
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GL01 Species
Select one option
Yes No
If no, please select which species you wish to comment on and provide your reasoning for each selected below.
Select one or more options
Magpie Carrion Crow Hooded Crow Jackdaw Jay Ruddy Duck Canada Goose
Comment on species you have selected above.
We note that the Statement of Reasons in GL01 for 2026 acknowledges that there is limited quantitative evidence of the impacts of Magpie predation on other bird species. In a literature review carried out by Scottish Natural Heritage in advance of the last General Licensing consultation in 2019. In summary, it was noted that “analyses of large-scale and extensive national monitoring data provide little evidence for national-scale impacts of magpies on avian prey populations, but most studies do not assess the impact of magpies alone”. We also note NatureScot’s commitment that its species advisors will “provide clear justification for the inclusion or exclusion of a species from the General Licences”. We suggest that until this justification is available, the precautionary approach would be to remove Magpie from the list of species that can be killed under this licence.
While we acknowledge the evidence that Carrion Crow and Hooded Crow nest predation might have a conservation impact on other rare bird species, it is our view that users of this licence should document the numbers of birds killed, when and on what conservation basis they are being killed, the methods used and that that information should be supplied to NatureScot as part of an annual return.
The Statement of Reasons in GL01 for 2026 also acknowledges that there is limited evidence that Jackdaws impact the conservation status of wild bird species, and that Jackdaws form a very small proportion of nest predation events. It is our view that there is nothing to support this species remaining on a licence that permits unrestricted, unmonitored, unregulated killing.
We are not aware of any clear, consistent evidence that implicates Jay in the decline of other species, and certainly not to the extent of justifying unlimited, unregulated and unmonitored killing under general licence authority, especially in a Scottish context where their distribution remains very fragmented. It is our view that in the complete absence of evidence of any negative conservation impact caused by this species (and in contrast to their well-known positive role in deciduous woodland ecology), there is no justification for this species being included in the proposed GL01 for 2027.
Ruddy Duck and Canada Goose are non-native species, and it is our view that the random free for all approach afforded by the General Licences are not an appropriate tool for effective Invasive Non-native Species management.
No. As we have stated elsewhere in this consultation, we do not believe that there is robust, peer-reviewed evidence to support adding unrestricted, unmonitored, unregulated killing of any further species to existing general licences.
GL01 Methods
Select one option
Yes No
If no, please select which methods you wish to comment on, and provide your reasoning for each selected, below.
Select one or more options
Pricking of Eggs
Oiling of eggs
Destruction of eggs
By hand
Targeted Falconry
Shooting with any firearm, including semi-automatic firearms, shotguns or air guns
A multi catch cage trap
A Larsen mate trap
A Larsen pod trap
A Larsen trap
Comments on methods selected above:
No mention appears to have been made in this review and consultation to the provisions contained in Section 7 of the Wildlife Management and Muirburn Act. Though not yet enacted, this legislation will require all trap users to be trained and licensed, and we assume the terms of each individual licence will have to sit alongside the terms and conditions of any subsequent general licence. However, Wild Justice believes that it is now more appropriate, particularly considering the risks and concerns we describe below, and to avoid the confusion of needing two different licences for one activity, that all future trap use will more appropriately be regulated using individual licences.
Wild Justice is concerned about the misuse and deliberate abuse of traps, purporting to be targeting corvids, and permitted by general licences. We have yet to see any initiative from NatureScot seeking to address the pressing issue of deliberate abuse of GL01 and 02, in particular for the illegal targeting of birds of prey.
No compliance monitoring of traps is undertaken by statutory agencies,
It is our understanding that a significant majority of the multi-catch cage traps that have been checked by RSPB Investigations Officers, SSPCA Inspectors, Police, or others, were being operated in a manner in contravention of the terms and conditions of the General Licence. This has included routine failures to provide food, water, adequate shelter or a perch, or a combination of these; frequent failures by operators to carry out checks of traps at least every 24 hours; and failures to fit a tag with a trap registration number. Additionally, on numerous occasions, traps that are apparently not in use are found not properly immobilised or rendered incapable of catching and holding birds.
While some may regard these as minor administrative infractions, each incident can have significant welfare implications for the birds trapped inside, including, in some cases, resulting in victims’ starvation. A number of such offences have resulted in prosecutions.
A significant concern, however, is the routine capture of non-target species in multi-catch traps, with scavenging species such as Buzzards or Red Kites attracted by baits, while active hunters such as Goshawks or Sparrowhawks being lured into traps by the presence of potential prey in the form of decoy birds, notably, but not exclusively Magpies, Jackdaws or Jays (no longer a legal decoy). We understand that a significant range of species, from passerines to White-tailed Eagles, have been caught in what are clearly very non-selective traps.
It has been suggested to us that while the capture of a non-target species is not an offence in itself, assuming the victim is “immediately released unharmed”, that when a trap repeatedly catches non-target species this should be viewed as a “reckless” taking offence under Section 1 of the Wildlife and Countryside Act 1981 (as amended). RSPB Investigations have recorded some individual traps repeatedly catching non-target species, notably Common Buzzards.
We are also concerned that there have been numerous cases where non-target species have not been released unharmed immediately. This has included examples where protected birds of prey have been witnessed and/or filmed being shot, bludgeoned to death or stuffed into a sack and removed to face an unknown fate elsewhere. In other examples, birds of prey caught in traps have “disappeared” during the hours of darkness, sometimes well after a 24-hour period has lapsed. Some of these cases have resulted in prosecutions, with the most recent in April 2026, where a Perthshire gamekeeper was convicted of killing a Goshawk he had captured in a multi-catch crow cage trap.
It is astonishing that nobody knows how many multi-catch Crow traps are being used in Scotland, or where they are. And no one knows how many corvids are killed through their operation, and how many non-target species are captured, accidentally, recklessly or otherwise, by traps that are inherently non-selective.
It is readily apparent, from multiple incidents where victims have been uncovered and criminal acts witnessed, that these traps routinely catch protected birds of prey; indeed, it is likely that the use of some are deliberately timed, sited and baited to do so.
A General Licence that allows the use of such non-selective traps simply facilitates and provides cover for those wishing to persecute raptors and other species, and facilitates appalling welfare consequences for those held as ‘decoy’ birds and those birds trapped in them. We question whether the future use of these traps can be legitimately justified and we suggest they should no longer be used.
No further methods should be included on this licence
GL01 Conditions
This question is required.
Select one option
Yes No
If no, tell us which conditions, why and your proposed alternatives.
We have given our thoughts elsewhere in our consultation response.
Additionally:
If the use of Crow Cage Traps are to continue, and in our view they should not be used at all for the reasons we stated previously, then the checking of traps needs to happen twice within a 24-hour period, with at least 8 hours between daily checks during the period March 1st and July 31st when species caught may have dependent young.
The Licence should only be applicable for the period where evidence suggests that corvid predation can have a conservation impact, i.e. during the breeding season, between March 1st and July 31st. Out with this period, the licence should be not used (thereby reducing the likelihood that post fledging dispersing birds of prey will be attracted to or caught in traps).
This question is required.
1 2 3 4 5
Select one option
Yes No
If no, please select which species you wish to comment on and provide your reasoning for each selected below.
Select one or more options
Feral Pigeon
Woodpigeon
Carrion Crow
Hooded Crow
Jackdaw
Magpie
Rook
Canada Goose
Greylag Goose
Comment on species you have selected above.
With the killing of Feral Pigeons it would be useful to understand how NatureScot resolves the question of the wild Rock Dove population whose behaviour and status does not appear to justify the unrestricted, unmonitored, unregulated killing which the General Licences authorise. Whilst the term ‘feral pigeon’ appears to exclude Rock Doves, the WCA requires that the scientific name be used as the ultimate legal identity of a species and Feral Pigeons and Rock Doves are, of course, one and the same in this respect.
It appears that the presence of Woodpigeon on General Licences is often used as a cover for what is purely sports shooting of the species. We would be interested to know NatureScot’s views on this issue and what measures it will take to reflect the Defra consultation seeking views on proposed changes to Part 1, Schedule 2 (2.1) of the Wildlife and Countryside Act 1981 (WCA) conducted in Spring 2026.
As with licence 01, with the killing of Carrion Crow and Hooded Crow, that users of this licence should document the numbers of birds killed, when and on what basis they are being killed, the methods used and that that information should be supplied to NatureScot as part of an annual return to assess ‘serious damage’
We note that with respect to Jackdaw and Magpie, the Statement of Reasons for GL02 for 2026 states that scientific evidence for both species causing serious damage to agriculture crops is absent, but both are listed on the licence. It is our view that there is nothing to support these species remaining on a licence that permits unrestricted, unmonitored, unregulated killing.
Rooks can benefit farmers through eating ‘pest’ insect species, and this needs to be assessed in conjunction with any perceived agriculture damage. It is amber listed in a UK context. It is our view that this species should not be subject to unrestricted, unmonitored, unregulated killing, and it should not feature on the General Licence.
With respect to Canada Geese, we note that in the Statement of Reasons for the 2026 licence, it acknowledges that “Impacts on agriculture are likely to be relatively localised and relate to areas where large concentrations of Canada geese accumulate.” Additionally, as we have said elsewhere in our response to this review, any control of this species this needs to be done by properly resourced, targeted and coordinated action, rather than the random, free-for-all approach afforded by their inclusion here. It is our view that General Licences are not an appropriate tool for effective Invasive Non-native Species management.
For Greylag Geese, there needs to be an absolute requirement for accurate mortality data, i.e. bag data. A voluntary approach to bag reporting will not suffice, as the approach needs complete confidence in the accuracy of mortality data. Under current systems, management of this species cannot be achieved using a General Licence that permits unrestricted, unmonitored, unregulated killing.
Select one option
Yes No
If no, please select which methods you wish to comment on, and provide your reasoning for each selected, below.
Select one or more options
Pricking of Eggs
Oiling of eggs
Destruction of eggs
By hand
Targeted Falconry
Shooting with any firearm, including semi-automatic firearms, shotguns or air guns
In the case of Feral pigeon, Columba livia, shooting with the aid of any device for illuminating a target or any device for night shooting
A multi catch cage trap
A Larsen mate trap
A Larsen pod trap
A Larsen trap
Comments on methods selected above:
We refer the reader to our response under GL01 with regard to our views on the use of the various corvid traps and the comments regarding Falconry.
As with GL01, no further methods should be included on this licence. Additionally, the use of all unselective traps – multi-catch crow cage traps and Larsen Mate/Pod baited with meat – should cease.
GL02 Conditions
This question is required.
Select one option
Yes No
If no, tell us which conditions, why and your proposed alternatives.
We refer the reader to our earlier response under GL01 regarding our views on licence conditions and proposed alternatives. Additionally, as with other General Licences under which users can kill wildlife, there should be a reporting requirement for this licence.
This question is required.
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Feral Pigeon
Canada Goose
Select one option
Yes No
Comment on species you have selected above.
Although we accept Feral pigeon being listed here, we reiterate the points we made under GL02 about the necessity of distinction being made between Feral Pigeon and wild Rock Doves.
We repeat the points we have made about Canada Goose under GL01 and GL02, in that we do not regard the General Licence as an appropriate tool for effective management of an Invasive Non-native Species.
Select one option
Yes No
If no, please select which methods you wish to comment on, and provide your reasoning for each selected, below.
Select one or more options
Pricking of Eggs
Oiling of eggs
Destruction of eggs
By hand
Targeted Falconry
Shooting with any firearm, including semi-automatic firearms, shotguns or air guns
In the case of Feral pigeon, Columba livia, shooting with the aid of any device for illuminating a target or any device for night shooting
Comment on methods selected above.
No.
This question is required.
Select one option
Yes No
As with other General Licences under which users can kill wildlife, there should be a reporting requirement for this licence.
This question is required.
1 2 3 4 5
Select one option
Yes No
If no, please select which methods you wish to comment on, and provide your reasoning for each selected, below.
Select one or more options
By hand
By a hand-held net which must have a minimum opening diameter of 30cm
Any form of artificial lighting, mirror or other dazzling device
Comment on methods selected above.
This General Licence is to facilitate the medication of a Red Grouse, and that can only be to create or retain a shootable surplus of Red Grouse. It would be helpful if, given no other species is treated in this way, if NatureScot could clarify for which licensable purpose the licence is granted.
We also have more specific concerns:
It is our view that the principle of mass medicinal treatment of an entire, albeit local, wild animal population needs proper risk assessment, and the precautionary principle dictates that this entire activity ceases until that is satisfactorily completed.