Are flags armorial in nature?

I am having a very interesting conversation elsewhere about the initiatives of The Flag Institute, a private society for flag enthusiasts, "Creating Local & Community Flags"; their website states that they are “currently being consulted by a number of civic organisations throughout the United Kingdom, who are in the process of selecting and adopting their own flags”. The Institute makes it quite clear that in Scotland any initiative must be undertaken in consultation with the Lord Lyon and this is quite obviously because in the view of the Lord Lyon almost all flags can be considered to be armorial in nature. In England however, the College of Arms appear to have taken their usual laid back approach and appear to have sat back and just handed the reigns over to The Flag Institute.

Some of the design proposals are quite stunning but, so far as I can tell, they are (as the Lord Lyon quite clearly and astutely already knows in his own domain) armorial in nature. The College of Arms will not grant arms to a non entity; for example, whilst they will grant arms to a County Council, they will not grant arms to an historical ceremonial county because there is no body corporate to whom the grant could be made. So, how can these proposed new flags trans-morph into reality given that in England flags and armorial bearings can only belong to real entities. A ceremonial county is not a corporate body or a person in law; it is simply a geographical line on a map. Other than the fact that a private organisation (the Flag Institute) has accepted a particular flag through some local participation, how can the flag have any status?

I realise that that the College of Arms has little or no power but it is stretching it a bit to say that flags do not come under the remit of the College of Arms. If the College had the same bite as the Lord Lyon (who must be consulted in the matter of flags in Scotland) I am sure that they would argue that such flags as the ones I have seen designed are indeed VERY armorial. The Lord Lyon would and does argue that they are indeed armorial.

The College of Arms has recently offered reduced fees to Parish Councils but now we have The Flag Institute, apparently with the blessing of the College of Arms, offering to organise and assist with the design of “Local & Community flags” which experience has shown are very heraldic in nature.

I can not help but wonder if this is yet another nail in the coffin of the College of Arms. Once it’s on a flag which has gained some pseudo authority via an “Institute” which is the guardian of “The UK Flag Registry” why not also display the design on a shield?

Perhaps, in all fairness, I ought to add that I believe that the initiative by the Flag Institute is commendable and whilst I have some reservations, or unanswered questions, as to the legal status of the flags they have registered, my real concern is that, yet again, the College of Arms has shown that it has no control over armorial designs and that it appears to have simply left this initiative to others.

The "village" flag of Evenley, Northamptonshire, adopted 18th November 2014. Image courtesy of The Flag Institute and used under the terms of fair reporting.