If you bought the gun as a Two-Tone and you're not a registered player and then you paint it, you are breaking the law.
This is semi-true, only you dont have to be a REGISTERED player, you just have to be able to prove that you are an airsoft skirmisher. UKARA is NOT a legal requirement or a legally recognised governing body. It IS one method of proving you are a skirmisher but NOT the only way.
Permanently modifying a non realistic imitation firearm (painting it) to make it look like a RIF is looked at in the same way as someone modifying a deactivated firearm to fire live rounds.
Yes and no. It IS considered to be "manufacturing" a RIF, and therefore dealt with under the 2006 Violent Crimes Reduction Act which prohibits the sale, manufacture and import of RIFs. However airsoft skirmishers have a specific defence under the VCRA which allows them exemption providing they can prove they are skirmishers.
An airsoft skirmisher would have no defence however against modifying a de-activated weapon to fire live rounds as this would make it a firearm, not a RIF, and would come under firearms licencing laws worded in the 1997 Firearms Act not the 2006 VCRA, so saying that you would be treated in the same way for each "offence" is not strictly true as they are actually dealt with under totally different sections of the law.
This is why you can't order spray paint at the same time as ordering a Two-Tone gun online (from any reputable retailer).
This is true in the sense that anyone selling either RIFs, or the facility to manufacture RIFs (a two-tone gun and paint could be seen as manufacturing components for a RIF) have to make sure that they take appropriate and responsible steps to ensure that the person they are selling either a RIF or the manufacturing components to is an airsoft skirmisher (in the same way that an off-licence has to take appropriate steps to ensure they are not selling to someone under the age of 18) however it is not actually ILLEGAL for the retailers to send you a two-tone gun and some paint, providing they are 100% sure you are a skirmisher.
The reason UK retailers all ask for UKARA now is because it is an industry-standardised way of proving you are a skirmisher. In theory you could send them some ID and a whole ton of photos, witness statements or other supporting evidence and this would be just as good as UKARA membership, but the man-hours required to process that sort of information would be impractical so they use UKARA instead.
So again, just to summarise:
1) Painting a two-tone gun to look like a real gun consitutes "manufacturing" a RIF (Realistic Imitation Firearm)
2) Manufacturing RIFs is illegal under the 2006 Violent Crime Reduction Act.
3) The VCRA allows for manufacturing, selling or importing RIFs, providing the end user of the RIF is an airsoft skirmisher and the RIF is to be used as such for skirmishing.
4) The skirmisher must be able to prove their status as a skirmisher in order to be allowed the above exemption from the VCRA
5) UKARA is the method that almost every UK airsoft retailer will now use for you to prove your status as a skirmisher, however it is NOT a "licence" for a RIF, nor is it the ONLY way of proving you are a skirmisher.
I am not saying I am against UKARA or anything like that. UKARA is a fantastic tool that is used by airsoft skirmishers and retailers to cover each others backs and make sure that they are on the right side of the law, specifically the VCRA. It is also supportive to our sport for anyone airsofting in the UK who CAN join UKARA to do so, because it demonstrates that airsofters are responsible people who do everything they can to operate within the law, not try to circumvent it.
However the belief that UKARA is the ONLY legal way to own a RIF as opposed to a two-tone gun is false. If you are GENUINELY an airsoft skirmisher and have SOME means of proving as such then you are still covered by the specific defence allowed under the VCRA, however this does NOT mean that you can buy a two-tone gun, paint it black, hold up your local HSBC at gunpoint and then claim that you are an airsofter so you are allowed the gun because that sort of behaviour is the EXACT reason that the Violent Crime Reduction Act banned RIFs in the first place.
The last consideration to take into account is age. Under 18s may NOT own an IF or RIF under the VCRA, and they are NOT covered by the specific defence of being an airsoft skirmisher. Therefore if you can't join UKARA because of being under 18, then please do NOT mis-construe any of the above post to mean that you can still paint a gun, or even own one with the way the law stands currently.
IF YOU ARE UNDER 18 YOU CANNOT OWN ANY IMITATION FIREARM, WHETHER IT BE TWO-TONE, TRANSPARENT, REALISTIC OR OTHERWISE. (2006 Violent Crime Reduction Act, Provision 40)