🦎 Rules explained · Conservation Regulator

Rules-as-code · Plain-English guide

Wildlife licence holders

How the digitised conditions of Victoria's Wildlife Regulations 2024 decide what each kind of wildlife licence lets its holder do, the conditions attached to using it — where and with whom you may trade, how dingoes must be kept — and the records and notifications the holder must keep up. No code, no jargon left unexplained.

Conservation Regulator 12 licence types · 41 encoded rule groups Version v1.0.0 Source: staging

How to read this guide

This ruleset is about licence holders, not applications. It assumes someone already holds (or is modelling) a wildlife licence, and works out three things: which handling activities that licence permits, the conditions attached to exercising them, and the record-keeping and notification duties it obliges. Sections 3–4 cover permissions; sections 5–6 cover duties; sections 7–10 cover the licence conditions (new in this revision of the encoding). The colour code is constant throughout: Permitted, Forbidden, Obligated / Required, Rules work out.

01

The big picture

The Wildlife Regulations 2024 create twelve kinds of wildlife licence — basic, advanced, specimen, dingo, controller, dealer, demonstrator, displayer, game bird farmer, processor, farmer and taxidermist. Each kind lets its holder do some things with wildlife (buy it, keep it, sell it, breed it, and so on) but not others, attaches conditions to how those things may be done, and adds ongoing paperwork duties.

This ruleset takes the details of a licence — its type, the wildlife it covers, the purpose, the source of the animals — and works out, automatically:

  • What the holder may and may not do — every handling activity is marked Permitted or Forbidden (regs 8–19).
  • The conditions on doing it — where a transaction may take place, who the other party may be, where wildlife must be kept, and the special safety rules for dingoes (regs 38–60).
  • What the holder must do — record-keeping and notification duties are marked Obligated, individual form fields become Required, and the rules even check whether a record was filed on time (regs 27–37).

Everything below is worked out by the same rules, evaluated top-to-bottom: when two rules touch the same activity, the later one wins. That single idea explains the whole permission system — including how a condition can slam a permission shut again (a dingo pup under seven weeks turns "buy" back off unless the Secretary has approved).

This revision of the encoding roughly doubles the covered ground: alongside the permission matrix and the record-keeping duties, the licence conditions of regs 38–60 (transactions, displays, keeping, dingo safety, employees, signage, controller approvals) are now encoded, and reg 116 unlocks import/export for an import/export permit within its validity window. Regs 61–115 and 117–142 remain headings-only stubs — see Observations.

Three ideas behind the rules

Idea 1

Forbidden until unlocked

The rules begin by forbidding every wildlife activity. Each licence type then re-opens only the activities it is meant to allow. So a permission is really the answer to “does my licence unlock this?”.

Idea 2

Status, not yes/no

The rules don't output a single verdict. They attach a status to each activity — may do (Permitted), must not (Forbidden), must do (Obligated) — so one licence produces a whole map of dos and don'ts.

Idea 3

Schedules decide the species

Which licence covers which animal turns on the Schedules — official lists of taxa (Schedule 2, 3A, 3B, 4A, 4B, 5A, 5B, 6, 7). A licence unlocks its activities only when the animal is on the right Schedule for that licence.

02

What the system asks about

You provide a fact that is entered about the licence. Rules work out a conclusion the rules calculate. The ruleset draws on a large shared data model; the entities that actually drive these rules are below.

🪪 Wildlife licence

The licence itself — the central thing these rules reason about.

Licence typeYou provideone of the 12 categories
Wildlife covered — which Schedules it's listed in (2, 3A, 3B, 4A, 4B, 5A, 5B, 6, 7)You provideyes / no each
Wildlife covered — is it a bird / a dingo / alive / captive-bred / infertile eggsYou provideyes / no
Purpose — commercial, educational, conservation, hunting, farming, film, taxidermy…You provideyes / no each
Source — taken from the wild, approved by the Secretary, from a farmer, bought/acquired/received by the holder…You provideyes / no each
Issue dateYou providedate
Each handling activity (buy, sell, keep, breed, display, process, destroy…)Rules work outpermitted / forbidden / obligated

🤝 New transaction

A buy / sell / trade the holder wants to make — its location, the other party, and the wildlife involved. Drives the reg 38–50 conditions.

Other party — holds a licence, authorised to buy/sell, exempt person, has a dingo or displayer licenceYou provideyes / no each
Location — other party's premises, approved by relevant body, approved wildlife event, holder's own premisesYou provideyes / no each
Wildlife event — which licence types it permitsYou provideyes / no each
Secretary approvals (buy from party, sell to party, pups under 7 weeks)You provideyes / no
Location is allowed · may transact with the other partyRules work out

🏠 Kept wildlife & premises

What the holder keeps, where, and the signage on commercial premises.

Kept species — quantities, Schedule 7 flag, age flags, microchipsYou providelist
Kept at the premises specified in the licence · authorisation to keep elsewhereYou provideyes / no
Sign — prescribed texts, position, lettering, conditionYou provideyes / no each
Total Schedule 7 wildlife kept · displays an appropriate signRules work out

📒 Record book

The holder's log of what they've done under the licence. Each entry can trigger required fields and a timeliness check.

Transactions — species, quantity, type (buy/sell/trade/other), datesYou providelist
Losses — type (theft/escape/misplacement), species, microchips, datesYou providelist
Wildlife displays & demonstrations — dates, venueYou providelist
Was each record filed on time?Rules work outyes / no

👥 Employees & 📇 changes of detail

Staff a commercial holder employs to act under the licence, and any later change to a name, address or telephone number that must be notified.

Employee — name, date of birth, address, capacity, start / end datesYou providelist
Change of detail — who it's for, which detail, date changed, date reportedYou providevalue
Was the change / employee reported within the deadline?Rules work outyes / no
03

The default: everything is off

Before any licence-specific rule runs, an initialisation step sets every wildlife handling activity to Forbidden — buying, selling, acquiring, receiving, disposing, keeping, possessing, breeding, displaying, destroying, importing, exporting, and the rest. Nothing is allowed yet.

The same step switches on a handful of Obligated duties that apply to every holder regardless of licence type — chiefly the duties to notify a change of name, address or telephone number (for the holder, an employee, or an authorised person), to notify employee details, and to notify police of a wildlife theft.

Later still wins

Because the last rule to touch an activity wins, a licence rule can also switch something back to Forbidden after unlocking it — the taxidermist rules do this to a “sell” permission, and the dingo-pup rule (reg 50) does it to a whole set of transaction permissions (see §9).

04

What each licence lets you do

Each licence type has its own rule. It first checks that the chosen licence type matches, then checks a gate — the right Schedule for the species, the right purpose, sometimes the right source — and only then flips its activities to Permitted. The general shape is the same for all twelve:

The matrix shows which activities each licence can unlock. A ✓ means the licence permits that activity once its gate is met; the gate is spelled out in the notes beneath. Some licences (processor, taxidermist) unlock different activities on different branches — the ✓ marks any activity the licence can reach.

Licence typeBuySellAcquireReceiveDisposeKeepPossessBreedDisplayProcessDestroy
Basic
Advanced
Specimen
Dingo
Controller
Dealer
Demonstrator
Displayer
Game bird farmer
Processor
Farmer
Taxidermist

The gate for each licence — the extra conditions beyond selecting the type:

  • Basicnot commercial and the animal is in Schedule 2 or 7.
  • Advancednot commercial and the animal is in Schedule 2, 3A, 3B or 7.
  • Specimennot commercial, the animal is not alive, and it is a prepared or mounted specimen.
  • Dingo — non-commercial, or for a canine-association show, or educational, or the animal is a dingo. (A deliberately broad “any of these” gate.)
  • Controller — the animal is taken from the wild, is not being sold, is damaging or a danger to property, and is in Schedule 6. Unlocks only destroy and dispose.
  • Dealercommercial and the animal is in Schedule 2, 3A, 4B or 7. A second branch also permits dispose for dead animals in those Schedules.
  • Demonstrator — either “promote understanding of ecology and promote conservation”, or “display in commercial films”, and the animal is in Schedule 2, 3A, 3B, 4A or 4B (any one). (An earlier version joined those Schedules with “and”, so no animal could satisfy the gate; it now uses “or” and unlocks correctly.)
  • Displayer — for commercial films, or to promote conservation, or educational. (Opening and closing displays are unlocked separately in §5.)
  • Game bird farmer — the animal is a bird, bred in captivity, and the purpose is hunting. A second branch permits possess and display of prepared/mounted dead birds.
  • Processor — “to provide products for sale”, with the source either approved by the Secretary (Schedule 5A) or from a licensed farmer (Schedule 7), the animal not alive; a further branch permits sell / dispose / keep / possess / process for stock the holder itself bought, acquired or received.
  • Farmer — “for farming wildlife” and the animal is in Schedule 7 (unlocks the widest set, including process and destroy); a second branch permits disposing of infertile eggs.
  • Taxidermist — to preserve / prepare / mount / restore dead wildlife, with the animal in the right Schedule or from an approved source; different branches unlock buy/acquire/receive, then sell/keep/possess/process/display. One branch deliberately switches sell back to Forbidden.

Three licences also unlock a special “request approval to acquire wildlife from a specified source” permission (processor, taxidermist, and the farmer's egg branch).

05

Keeping records

Holding a licence isn't only about what you may do — it's about proving you did it properly. Four rule groups turn activities into record-keeping duties and then check the timing.

Transaction log (reg 27)

If the holder buys, acquires, disposes of or receives wildlife, they are Obligated to record transaction details in the log book. For each transaction, the species, quantity and transaction type become Required; a free-text description is required when the type is “other”. The rules then compute whether the entry was recorded on time:

  • Most licences — the transaction must be recorded by close of business on the day of the transaction.
  • Game bird farmer — a longer window of 48 hours after the transaction applies.

Theft, loss or damage (reg 33)

When a holder becomes aware of a wildlife loss, recording it is Required. For each loss, type, species and quantity are required; if the animal is a dog (Canis familiaris) each microchip number is required too. A theft triggers extra duties, and the loss must be recorded within two days:

Displays & demonstrations (reg 34–35)

A displayer licence unlocks opening a wildlife display; once a display is open the holder may close it. Each opening and closing must be recorded, and recorded within two days of the event. A demonstrator licence unlocks conducting a demonstration and obliges recording each one's date and venue.

DutyApplies toDeadline the rules check
Record a transactionAny holder who buys / acquires / disposes / receivesClose of business, same day 48 h for game bird farmer
Record a lossAny holder aware of a lossClose of business, 2 days later
Notify policeLosses that are theftsObligated (no computed deadline)
Record display opened / closedDisplayerWithin 2 days of opening / closing
Record demonstrationDemonstratorObligated (date & venue required)
06

Notifying changes & employees

Change of name, address or telephone (reg 36)

When the holder flags a change — to a name, address or telephone number, for the holder, an employee or an authorised person — the rules record who the change is for and which detail changed, then make the relevant new detail Required: a name change asks for the new name, an address change for the full new address, a telephone change for the new number. The change must be reported within 10 business days (modelled as 12 calendar days); the rules compute the elapsed time and mark the “report within 10 business days” duty Obligated.

Employees of commercial holders (reg 37)

If the purpose is commercial and the holder employs a person with delegated authority, notifying the employee's details is Obligated. For each employee, name, date of birth, telephone, full address, capacity and start date are Required. The rules check the start date was reported within the 10-business-day window; while the employee has no end date, terminating them is Permitted; once an end date is entered, its reporting is checked against the same window and marked Obligated.

“10 business days” = 12 days

Throughout, the “10 business day” deadline is modelled as a flat 12 calendar days. It's a deliberate approximation, not a bug — but reviewers should confirm 12 is the intended figure, since 10 business days can span 14 calendar days across weekends and public holidays.

07

Transactions — where, and with whom

New in this revision. Being permitted to buy or sell wildlife is only half the story — regs 38–50 constrain where the transaction may happen and who the other party may be. Any buying, selling, acquiring, receiving or disposing counts as “transacting under the licence” and switches these conditions on.

An allowed location (regs 38–39)

A transaction location qualifies when the other party is not an exempt person and the deal happens at the other party's premises, a location approved by the relevant body, or an approved wildlife event. For basic, advanced and dingo licences, selling or disposing anywhere other than the holder's own premises also qualifies. Whenever the holder transacts, using an allowed location is Obligated — and applying to transact in an unapproved location is always Permitted (you can ask).

At an approved wildlife event, one more check runs: the event's own allow-list must include your licence type (basic, advanced, specimen, dealer, demonstrator, displayer and taxidermist are each checked). Holding a licence type the event permits is Obligated.

An allowed counterparty (regs 40, 45, 49)

By default, transacting with the other party is Forbidden. It opens depending on your licence and the direction of the deal:

Your licenceDealPermitted when the other party…
Basic / AdvancedBuy, acquire or receiveholds a licence authorising sale, is an exempt person, or the Secretary approved buying from them
Sell or dispose (not Schedule 7)holds a licence authorising purchase, is exempt, or the Secretary approved the sale — otherwise Forbidden
Sell or dispose (Schedule 7)holds a basic or advanced licence, or the Secretary approved — otherwise Forbidden
SpecimenBuy, acquire or receiveis authorised to sell, is exempt, or the Secretary approved
DingoBuy, acquire or receiveholds a dingo licence or a wildlife displayer licence

The six-month hold (reg 41)

Wildlife on a basic or advanced licence must not be sold or disposed of within six months of the licence being issued. The rules compute a “six months after issue” date (issue date + 6 months) and forbid any sale or disposal whose transaction date falls before it. (An earlier revision compared the issue date against itself — always true — so these sales were forbidden forever; the current encoding compares the transaction date, as intended.)

08

Display & keeping conditions

Displaying (regs 42, 46)

For basic, advanced and specimen licences, displaying wildlife is Forbidden — unless the display is at an approved wildlife event, where it becomes Permitted. Charging a fee for the display is Forbidden either way.

Keeping (regs 43, 47, 51)

Holders who keep wildlife must keep it at the premises specified in the licence — an Obligated condition, Excused when the holder has an authorisation to keep it elsewhere or the wildlife is at an approved wildlife event. For basic and advanced licences the rules also tally the holder's total Schedule 7 head-count across all kept species (animals under four weeks old don't count).

For dingoes (reg 51) the keep-at-specified-premises rule is excused for recognised outings: exercising the dingo, education, a canine-association show, or a purpose approved by the Secretary. (This rule is now correctly limited to dingo licences — an earlier revision applied it to every holder.)

09

Dingo licences — safety, age, marking, escapes

Dingoes get the regulation's most detailed welfare-and-safety conditions (regs 52–57), all encoded:

  • Safety (52) — every dingo enclosure must be child-proof, permanent and fixed, must prevent escape and prevent unauthorised access. If the holder lets another person interact with the dingoes, minimising the risk of injury is Obligated.
  • Age (53) — the licence holder being under 18 is Forbidden, and allowing someone under 16 unsupervised access to dingoes is Forbidden, on an ongoing basis.
  • Marking (54) — every dingo over seven weeks old must have a microchip; the rules check each kept dingo and oblige the chip.
  • Escapes (55) — when the holder becomes aware dingoes have escaped, responding is Obligated: attempting to recapture them, humanely destroying them, or determining their fate. Doing any of the three satisfies the duty.
  • Display (56) — while displaying a dingo (education or canine show), the holder must remain in attendance, protect the dingo from abuse, retain direct control of it, minimise the risk of injury, and ensure it is conditioned to handling — five simultaneous Obligated duties.
  • Secretary approvals (57) — the holder may always apply to buy from or sell to a specified person, to transact a pup under seven weeks, or to keep dingoes at a different address; the application then requires the counterparty's details (and their licence number, if licensed).

And the strongest condition of all, reg 50: transacting a dingo pup under seven weeks old without the Secretary's approval flips buy, sell, acquire, receive and dispose all back to Forbidden — overriding every permission the dingo licence granted.

10

Commercial holders & controllers

Employees (reg 58)

A commercial holder who employs a person with delegated authority takes on three ongoing duties: ensuring all employees are aware of and competent in the licensed activities, providing a copy of the licence to each employee before they act under it, and ensuring the employee carries the copy while working. For controller licences there's a fourth: when an employee takes wildlife from the wild, the holder (if a natural person) — or the person responsible for licensed activities (if a company) — must be present.

Signs (reg 59)

Every commercial holder except a controller must display an appropriate sign: it must carry the two prescribed texts (“possessed under a licence…” and “wildlife must not be taken from the wild…”), sit at the main entrance in an obvious, readable position, use black block lettering at least 30 mm high on white, and be kept in good condition. All six attributes must hold for the computed “displays an appropriate sign” duty to be satisfied — and it is Obligated, ongoing.

Controller approvals (reg 60)

Where a controller's wildlife is taken from the wild, receiving or destroying it is Forbidden until the holder has prior written approval — with approval, both become Permitted.

11

Worked examples

🦜 A · A basic licence for a Schedule 2 bird, kept as a hobby

Given Licence type Wildlife basic licence
Given Purpose is commercial No
Given Animal listed in Schedule 2 Yes
1 Every activity starts Forbidden.
2 The basic-licence gate — not commercial and in Schedule 2 or 7 — is met.
3 Buy, sell, acquire, receive, dispose, keep, breed and display all flip to Permitted.
4 Buying wildlife is one of them, so recording transactions becomes Obligated — and any transaction must be logged by close of business that day.
5 Buying also counts as transacting, so the reg 38–40 conditions switch on: the deal must happen at an allowed location, with a seller who is licensed, exempt or Secretary-approved.
The holder may keep, breed and trade the bird — at an allowed location, with an allowed counterparty — and must log transactions the same day.

🏪 B · A commercial dealer who employs staff

Given Licence type Wildlife dealer licence
Given Purpose is commercial Yes
Given Animal listed in Schedule 3A Yes
Given Employs a person with delegated authority Yes
1 The dealer gate — commercial and Schedule 2/3A/4B/7 — is met, so the full commercial handling set becomes Permitted.
2 Because the purpose is commercial and an employee acts under the licence, notifying employee details is Obligated (reg 37), and the reg 58 duties switch on: competence, a copy of the licence provided before work and carried during it.
3 As a commercial holder (not a controller), displaying the prescribed sign at the main entrance is Obligated, ongoing (reg 59).
! Trading is permitted, but the dealer must notify and equip each employee, and keep the sign up.

🎬 C · A demonstrator licence for a Schedule 2 animal

Given Licence type Wildlife demonstrator licence
Given Purpose: promote ecology & conservation Yes
Given Animal listed in Schedule 2 Yes
1 Every activity starts Forbidden.
2 The licence type matches; the purpose part of the gate (“promote ecology and conservation”) is satisfied.
3 The Schedule part now needs the animal in Schedule 2, 3A, 3B, 4A or 4B — Schedule 2 alone is enough — so the gate opens and the demonstrator's handling activities flip to Permitted.
4 Conducting a demonstration is unlocked, so recording each demonstration's date and venue becomes Obligated (reg 35).
The demonstrator may handle and demonstrate the animal, and must record each demonstration. (This gate previously never opened, because an earlier version joined the Schedules with “and”; it now uses “or” and unlocks correctly.)

🐕 D · A dingo licence, and a five-week-old pup

Given Licence type Dingo licence
Given The animal is a dingo Yes
Given The transaction involves a pup under 7 weeks Yes
Given Secretary approval to transact pups this young No
1 The dingo gate is met, so buy, sell, acquire, receive, dispose, keep and breed flip to Permitted.
2 The counterparty rule (reg 49) narrows trading to other dingo-licence or displayer-licence holders.
3 Reg 50 then sees a pup under seven weeks with no Secretary approval — and, because later rules win, flips buy, sell, acquire, receive and dispose all back to Forbidden.
4 The holder may apply to the Secretary for approval (reg 57) — that application permission stays open.
The pup cannot be transacted — every transaction activity is Forbidden until the Secretary approves.
12

Test cases

Coverage at a glance

13 test suites, 16 scenarios, 20 expectations. Fifteen scenarios assert an outcome; one exercises the rules but asserts nothing. This is new in this revision — the previous encoding shipped with no tests at all — but the coverage is thin and one-sided, as noted below.

The suites are organised one-per-regulation. Twelve of them (regs 8–19) are a single happy path per licence type: give the right licence type with a qualifying Schedule, purpose and source, then assert that one representative handling activity comes out Permitted. The thirteenth suite (reg 27, record books) is the most thorough — it checks the transaction-logging duty and its timing both ways. The table lists every scenario and what it pins down.

Suite (reg)Scenario sets up……and asserts
8 · BasicNon-commercial holder of a Schedule 7 speciesbuyPermitted
8 · BasicA commercial purpose on a basic licencenothing asserted
9 · AdvancedNon-commercial, a Schedule 3B speciesbuyPermitted
10 · SpecimenNon-commercial, a mounted (non-living) specimensellPermitted
11 · DingoA dingo, non-commercialkeepPermitted
12 · ControllerA Schedule 6 animal, taken from the wild, a danger to propertydestroyPermitted
13 · DealerCommercial, a living Schedule 2/7 animalsellPermitted
14 · DemonstratorPromote ecology & conservation, a Schedule 2 animalkeepPermitted
15 · DisplayerTo display in commercial filmsbreedPermitted
16 · Game bird farmerA captive-bred bird, for huntingkeepPermitted
17 · ProcessorTo provide products for sale, a Secretary-approved Schedule 5A animal, not alivebuyPermitted
18 · FarmerFor farming wildlife, a Schedule 7 animalpossessPermitted
19 · TaxidermistPreserve / mount dead wildlife, a Schedule 2 animalreceivePermitted
27 · Record booksA buy, recorded the same daylogging duty Obligated; species & quantity Required
27 · Record booksThe same buy, recorded ~24 hours lateron-time duty Obligated, expected to be violated
27 · Record booksA game bird farmer records within 48 hoursrecorded-on-time = Yes

What the tests do well. Every licence type has at least one scenario that opens its gate and confirms a permission, and the record-book suite genuinely tests timing in both directions — a same-day record (on time), a 24-hour-late record (obligation violated), and the game bird farmer's longer 48-hour window (on time). That trio is exactly the shape the rest of the ruleset needs.

Where the coverage is thin. With 124 rule groups and 41 of them carrying logic, sixteen scenarios leave most of the behaviour unpinned:

  • Nothing asserts what stays Forbidden. Each licence scenario asserts a single activity is Permitted; none asserts that the activities the licence shouldn't unlock remain Forbidden, nor that a wrong-Schedule or wrong-purpose licence opens nothing. The one scenario aimed at a negative case — a commercial purpose on a basic licence — asserts nothing at all, so it can neither pass nor fail.
  • No condition overrides. The behaviours most likely to break silently are untested: the dingo-pup rule that revokes transaction permissions (reg 50), the taxidermist branch that switches sell back to Forbidden, the Schedule-7 sell restriction (reg 40), and the six-month hold (reg 41) — the very rule that was recently mis-encoded. A single “sale after six months is permitted” scenario would guard reg 41.
  • The whole conditions layer is untested. Beyond record books (reg 27), none of regs 33–60 has a scenario: theft/loss and police notification (33), displays & demonstrations (34–35), changes of detail (36), employees (37, 58), transaction location and counterparty (38–40, 45, 49), display & keeping conditions (42–43, 46–47, 51), the dingo safety/age/marking/escape rules (52–57), signage (59) and controller approvals (60). Import/export (reg 116) is likewise untested.
  • Copy-paste artefacts in the scenarios themselves. Several scenarios carry a name pasted from a different licence (the demonstrator scenario is internally named “Displayer licence lets you display wildlife”; the game bird scenario, “…display wildlife in commercial films”), and several licence scenarios assert against a rule identifier that lives in the basic-licence block (s 8) rather than their own — a reviewer should confirm each still exercises the licence it is named for.

Observations

Points a reviewer or the rule author may want to check; these describe the encoding as published and are not legal advice. Several issues flagged against the previous revision are now fixed: the six-month sale hold (reg 41) now compares the transaction date rather than the issue date against itself, so it no longer forbids these sales forever; the dingo keeping rule (reg 51) is now limited to dingo licences; the controller's Schedule-6 branch (reg 60) is now filled in rather than empty; import/export (reg 116) is now unlocked for an import/export permit within its validity window; and the duplicate default-block Forbidden sets have been removed. The observations below describe what still stands. Note: the published version string did not change across these edits, so “version 1.0.0” alone does not identify which behaviour is live — compare the rules directly.

1 · One address-change branch mixes two different flags

In reg 36, the three change-of-detail branches for the holder and the authorised person each test a single flag consistently (its existence and its value). The employee address branch is the odd one out: it tests that the name-change flag exists but that the address-change flag is true — two different properties. Depending on which flag the form actually sets, an employee address change may register at the wrong time, or not at all.

2 · Notification duties are split across two data roots

The initialisation block obligates some notify-of-change duties on licence.activities and others on application.desiredActivities (for example, “notify of holder name change” sits on the application root while “notify of holder address change” sits on the licence root). Reg 33 obligates the police-theft duty on both roots. Whether a duty surfaces to the user therefore depends on which root the form writes — worth reconciling so every duty lands on one consistent path.

3 · A couple of activities are forbidden and never unlocked

Conduct a wildlife display is set Forbidden in the default block and never turned Permitted anywhere. Transact under licence has its value computed by reg 38 and used as a gate, but its Forbidden modality from the default block is never lifted — a vestige, since the property is used as a computed flag rather than a permission.

4 · Small copy-paste and duplicated-branch artefacts

Reg 45 (specimen counterparties) contains two nearly identical branches that permit transacting with the other party twice. Reg 51's excusal list tests “is for exercising” twice. Reg 40's Schedule-7 check reads the wildlife from the application in one branch and from the transaction in the next. Reg 34 states the display-record requirements twice (once per-display, once against the list as a whole). None changes an outcome today, but each is a trap for future editors.

5 · The import/export gate keys off a licence-type name the rest of the model doesn't use

Reg 116 unlocks import/export only when the licence type equals the exact string “Import/Export licence”. But the application's list of licence types names “Wildlife import licence” and “Wildlife export licence” as two separate categories. Unless a licence actually carries the “Import/Export licence” type string, reg 116 never fires — the two enumerations should be reconciled.

6 · Roughly two-thirds of the regulation is still a stub

41 of the 124 rule groups contain logic — regs 8–19 (permissions), 27–37 (records & notifications), 38–60 (the licence conditions) and 116 (import/export). The remaining 83 — “Return forms”, a scattering of condition regs (44, 48, 61–64…) and almost everything from reg 61 to reg 142 — are headings with no rules inside: codes of practice, housing and transport standards, the section 28A authorisation, and all the exemptions.

7 · Minor: an unused computed value

The computed value isProtectedSpecies is declared in the data model but no rule in this ruleset ever sets it.

Glossary

Permitted / Forbidden / Obligated
The status a rule attaches to an activity: may do it, must not do it (an offence), or must do it. A field can also be Required (must be filled in), and an obligation can be Excused (waived in stated circumstances).
The golden rule
Rules run top-to-bottom; when two apply to the same activity, the later one wins. Here it makes “Forbidden by default, Permitted if your licence unlocks it” work — and lets a condition re-forbid what a licence granted.
Schedules (2, 3A, 3B, 4A, 4B, 5A, 5B, 6, 7)
Official lists of wildlife taxa in the Regulations. Which licence covers which animal turns on which Schedule(s) the animal is listed in.
Licence type
One of the twelve categories of wildlife licence: basic, advanced, specimen, dingo, controller, dealer, demonstrator, displayer, game bird farmer, processor, farmer, taxidermist.
The gate
The extra conditions — Schedule, purpose, source — a licence checks before it unlocks its activities. Selecting the right licence type alone is never enough.
Transacting under the licence
Any buying, selling, acquiring, receiving or disposing of wildlife. Transacting switches on the location and counterparty conditions of regs 38–50.
Approved wildlife event
An event (like a bird sale or show) approved by the Secretary, with its own list of which licence types may transact or display there.
Exempt person
Someone the Regulations allow to deal in wildlife without holding a licence; several counterparty rules accept an exempt person in place of a licensed one.
Close of business
The end of the working day. Timeliness checks compare the recording time against close of business on a given day (the transaction day, or two days after a loss).
10 business days
The reporting deadline for changes and employee details, modelled throughout as a flat 12 calendar days.