Australia, Britain and Switzerland compared, and why none of them is America

Every gun debate eventually reaches the same stage of exhaustion. Someone says "Australia," and someone else says "Switzerland," and the two of them stare at each other across the table like diplomats who have each brought a map of a different country.

That is exactly what has happened. Both sides reach for a foreign example, because a foreign example is a convenient way to say "it has been tried, and look." The trouble is that a country is not an experiment run in a lab. Each of these three nations arrived at its gun rules through its own law, its own tragedies and its own history, and none of them started where America starts. I want to lay the three side by side, give the sharpest version of each argument, and then explain why the American answer cannot be borrowed.

The claim

The claim: Australia's buyback, Britain's handgun ban and Switzerland's militia culture are each the product of a particular legal and historical setting. None can be transplanted to the United States, because the Second Amendment, the Supreme Court's decision in District of Columbia v. Heller, and the sheer number of firearms already in private hands make a mandatory buyback both unconstitutional and impractical here.

I am not claiming that Australia's or Britain's laws are wicked, or that Switzerland is a model to copy. I am claiming that comparisons between countries with different constitutions are weaker evidence than either side pretends.

Australia, 1996

On April 28, 1996, a gunman killed 35 people at Port Arthur, a tourist site in Tasmania. It was the worst mass shooting in modern Australian history. Within about twelve days, on May 10, the federal government and the states agreed on the National Firearms Agreement, and the states passed the legislation to implement it.

The agreement did several things. It sought to take automatic and semi-automatic weapons out of ordinary civilian hands. It required licensing and background checks for owners and set strict storage rules, and it was paired with a government buyback funded by a one-time increase in the Medicare levy, the national health levy. The government compensated owners for the banned guns, and about 650,000 firearms were surrendered.

The argument for Australia says that after 1996 the country has had no mass shooting on the scale of Port Arthur, and that the firearm death rate has declined. Both facts are broadly true as far as they go. The honest limit is that researchers disagree about how much of the later decline the buyback explains. A before-and-after comparison in a single country, over a period when many other things changed, cannot isolate one cause. Australia also remains a country where many people lawfully own guns, under stricter licensing than before.

Britain, 1997

On March 13, 1996, a man shot dead 16 children and their teacher at Dunblane Primary School in Scotland. The British government commissioned an inquiry, the Cullen Report, and Parliament responded with two statutes in 1997. The Firearms (Amendment) Act 1997 banned most handguns above .22 caliber, and the Firearms (Amendment) (No. 2) Act 1997, passed after a change of government, extended the ban to nearly all cartridge handguns, Britain had already tightened its rifle laws after the Hungerford shooting in 1987, but that legislation left handguns alone.

British gun law is built on licensing. A person must obtain a firearm or shotgun certificate from the police. There is no constitutional right to own a gun in Britain: ownership is a licensed privilege.

The argument for Britain points to the low number of gun homicides compared with America's. That is true, and it is also a point that the gun-control side tends to overstate. Britain's gun ownership was low long before 1997, so cause and effect are tangled. Britain also has a different policing model, a different criminal-justice system and an island's border.

Switzerland, the militia nation

Switzerland is the example gun-rights advocates prefer, and they should be careful with it. The Swiss Army is a militia. Historically, male citizens served in it and kept their service weapons at home, which is the root of the idea that the country is "armed to the teeth." Ownership of firearms is relatively widespread by European standards, and private shooting clubs are a significant part of Swiss civic life.

But the rules are not what Americans suppose. Buying a handgun, or a semi-automatic rifle, generally requires an acquisition permit from the cantonal authorities. Carrying a loaded weapon in public requires a separate permit that is not easy to obtain. Ammunition for home storage is no longer issued to soldiers. In February 2011 Swiss voters rejected an initiative that would have required army weapons to be kept in armories rather than at home; 56.3 percent voted no.

The lesson of Switzerland is more subtle than the slogan. It is that a high rate of gun ownership can coexist with low rates of gun crime where ownership is tied to training, civic duty and a culture of shared rules. It is not the lesson that unregulated gun ownership is safe. Switzerland has regulations, and a unified culture, a small and homogeneous population, and a civil order that was built over centuries.

The three side by side

The argument from tailored history

The simplest way to see why the three cannot be imported is to ask a legal question, because a country's gun law is not separable from its constitution.

Australia has no bill of rights that protects a right to keep arms. Its parliaments are supreme, and a licensing regime is a matter of ordinary legislation. Britain's Bill of Rights of 1689 did include a provision that Protestant subjects might have arms for their defense "suitable to their conditions and as allowed by law," and a historian will tell you that this right was conditioned on law almost from the start. Modern British law treats ownership as a licensed privilege. Switzerland places firearms in a federal weapons law that the cantons help administer.

The United States is different on the page. The Second Amendment reads: "A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed." The Supreme Court held in District of Columbia v. Heller (2008) that this protects an individual right to possess firearms, unconnected with service in a militia, for lawful purposes such as self-defense in the home. In McDonald v. City of Chicago (2010) the Court held that the right binds the states, and in New York State Rifle & Pistol Association v. Bruen (2022) that it extends to carrying a handgun in public and that restrictions must be consistent with the nation's historical tradition of firearm regulation.

That matters more than any statistic. An Australian-style licensing system that makes ownership depend on persuading a government official that you have a reason, and that does not count self-defense as one, could not be squared with a right that Heller describes as protecting self-defense. A British-style ban on handguns runs straight into Heller, where the Court held that a ban on handguns, the class of arms most Americans choose for home protection, would fail under any standard of scrutiny. A comparison to Switzerland leads somewhere else: it is a country where the state treats the citizen as part of the militia, and the American Founders thought that way as well, as George Mason and the well regulated militia composed of the body of the people shows.

The practical objection: three hundred million reasons

Even if the Constitution permitted it, a mandatory buyback would face a problem of scale.

Australia in 1996 had a small population, a modest number of the targeted firearms and a government that could register and trace them. The United States has a population of more than three hundred million, and by every estimate its civilians own firearms in the hundreds of millions, many unregistered, and no federal registry exists. A mandatory buyback would require the government to learn what each person owns, which it does not know, and to compel the owner to hand it over.

Here is the arithmetic of the problem. Suppose, for argument's sake, that the federal government offered to pay an average of $500 for each prohibited firearm, and suppose, to keep the illustration conservative, that there were 20 million such firearms. That is a $10 billion program at the outset, before any cost of collection, storage, destruction or enforcement. If the real number were five times as large, the figure would be $50 billion. These numbers are hypothetical and are only meant to show the order of magnitude. The more serious point is that compliance would depend on law-abiding owners, who would hand over their property, while the people the policy aims to disarm would not.

And there is the constitutional cost. The Fifth Amendment provides that private property shall not be "taken for public use, without just compensation." A buyback that pays compensation may satisfy that clause in form. But under Heller, arms "in common use" for lawful purposes are protected by the Second Amendment, and the Court's opinion treated the question of whether a weapon is commonly owned as central. A ban on the kind of rifle that millions of Americans own, enforced by confiscation or by a "voluntary" program with a penalty for refusal, would have to survive that test. I do not think it could.

The best argument on the other side

A fair critic would say that the Second Amendment is not unlimited, and that I have not answered the central point: other rich democracies have far fewer gun deaths than America, and a country that cares about life should learn from them.

I answer in three parts. First, Heller itself says the right is not unlimited. The Court wrote that nothing in the opinion should cast doubt on laws prohibiting possession by felons and the mentally ill, or forbidding carrying in sensitive places, or imposing conditions on the commercial sale of arms. The Constitution leaves wide room for regulation, and the question is what regulation fits the American tradition. Second, the difference in gun deaths is not explained by gun laws alone. The United States has different rates of violent crime generally, in some regions much lower than in others, and different patterns of urban violence, which any serious comparison has to confront. Third, a free people is entitled to decide how much liberty to trade for how much safety, and the Constitution has already made the choice on one point. If a majority wants a different bargain, the Constitution provides a way: Article V.

That answer is not a dodge. It is the central conservative claim about constitutional government. A right does not disappear because other countries have chosen to do without it.

What can be learned from abroad

It would be a mistake to throw out the comparison altogether. Several things can be learned.

1. Training and civic responsibility matter. The Swiss emphasis on instruction and on shooting as a community activity is a model of how a widespread right can be paired with a culture of care. The American tradition of hunter education and the work of shooting clubs lines up with that.
2. Licensing can be designed for safety without a pretext. The question is whether a license is a condition to be satisfied by any law-abiding person or a permission to be granted at an official's discretion. Bruen answered that question for carry permits.
3. Cause is hard to prove. Anyone who tells you that a single law fully explains the difference between two countries is selling something. The honest position is that the evidence is mixed and that the best policy is the one consistent with the Constitution and aimed at the people who actually commit violent crime.

For related reading on how other countries treat rights, see Europe's Digital Services Act and the First Amendment, Side by Side, which makes a similar point about speech, and for the roots of the American right, The Powder Alarm and the British arms embargo that came before Lexington and What the ratifying conventions demanded before Madison drafted an arms right. The text of the amendment is in the Constitution.

The case in brief

1. Australia's 1996 agreement and buyback after Port Arthur, and Britain's 1997 handgun ban after Dunblane, came out of parliamentary systems with no entrenched right to arms.
2. Switzerland pairs widespread ownership with permits, training and a militia tradition, so it cannot be cited as proof that loose rules are safe.
3. Before-and-after comparisons across countries cannot isolate one law as the cause of a change in violence.
4. In America, Heller, McDonald and Bruen make a ban on common arms, or a licensing system that refuses to count self-defense as a reason, constitutionally impossible without an amendment.
5. A mandatory buyback is also impractical: there is no registry, the guns number in the hundreds of millions, and the compliance burden would fall on the law-abiding.

What you can do: read the Second Amendment and the Court's holding in Heller for yourself, then ask the next person who says "Australia did it" which clause of the American Constitution they would amend to do the same.