Martyn's Law Explained: What UK Venues Must Do Before 2027

The Terrorism (Protection of Premises) Act 2025, known as Martyn's Law, received Royal Assent on 3 April 2025. This landmark legislation will fundamentally change how venues and events across the UK approach counter-terrorism security. With enforcement expected from mid-2027, venue operators, event organisers, and business owners have roughly two years to prepare.

Named after Martyn Hett, who died in the Manchester Arena attack, this law aims to improve protective security at publicly accessible locations. Unlike many regulations that apply broadly, Martyn's Law uses a tiered approach based on venue capacity — meaning your obligations depend on how many people your premises can hold.

Who Does Martyn's Law Apply To?

The Act covers qualifying premises and qualifying events that are publicly accessible. Understanding whether your venue qualifies is the first step in determining your obligations.

Qualifying Premises

To qualify, premises must:

Include at least one building — outdoor-only spaces like car parks don't qualify
Be publicly accessible — members of the public can enter, even if they need to pay or register
Have capacity for 200 or more people — this includes customers, staff, and visitors combined

This covers a vast range of venues including shopping centres, hotels, restaurants, pubs, cinemas, theatres, sports facilities, places of worship, schools, care homes, and office buildings with public access.

Qualifying Events

Events qualify if they:

Have capacity for 800 or more people
Control access — typically through ticketing, registration, or security checks
Are publicly accessible — not limited to specific groups like employees

This includes concerts, festivals, sporting events, conferences, and large public gatherings where organisers control who enters.

Who Is the Responsible Person?

The "responsible person" under Martyn's Law is whoever has control over the premises or event. This could be:

Venue owners or operators — for permanent premises
Event organisers — for qualifying events
Tenants with control — where lease terms give operational responsibility
Management companies — for managed properties

If control is shared, multiple parties may have responsibilities. The key test is who makes decisions about security arrangements and public access.

The Two-Tier Approach

Martyn's Law divides obligations into two tiers based on capacity. This proportionate approach recognises that a village hall needs different security measures than a major sports stadium.

Standard Tier (200-799 Capacity)

Standard Tier premises must implement:

Public protection procedures — documented processes for responding to terrorist incidents
Staff training — ensuring relevant personnel know how to implement these procedures

These requirements focus on preparedness rather than prevention. The procedures must cover how to respond if a terrorist incident occurs, including evacuation routes, lockdown procedures, and communication with emergency services.

Enhanced Tier (800+ Capacity)

Enhanced Tier premises and events have additional obligations:

Terrorism risk assessment — identifying vulnerabilities and threats specific to the venue
Security plan — measures to reduce terrorism risks identified in the assessment
Designated senior responsible individual — a named person with overall accountability
Annual review — keeping assessments and plans current

The risk assessment must consider the venue's attractiveness as a target, potential attack methods, existing security measures, and surrounding environment. The security plan then details proportionate measures to address identified risks.

What This Means for Different Sectors

Martyn's Law will affect diverse sectors across the UK. Here's how it applies to key industries:

Hospitality Venues

Pubs, restaurants, hotels, and clubs with 200+ capacity will need procedures and training. Large venues like major hotels or entertainment complexes may fall into Enhanced Tier, requiring full risk assessments. This builds on existing fire safety obligations but focuses specifically on terrorism threats.

Event Organisers

Organisers of events with 800+ attendees will need comprehensive security planning. This includes festivals, concerts, conferences, and sporting events. The temporary nature of events doesn't reduce obligations — risk assessments must consider the specific location and circumstances of each event.

Schools and Education

Schools with 200+ capacity (including students and staff) must develop terrorism response procedures and train relevant personnel. Large secondary schools and universities may need Enhanced Tier measures. School governors and senior leadership teams will need to understand their new duties alongside existing health and safety responsibilities.

Care Homes

Care homes with 200+ residents and staff must implement Standard Tier measures. The vulnerability of residents will be a key consideration in developing appropriate procedures. Managers must balance security needs with the dignity and freedom of residents, similar to their approach to fire safety in care environments.

Sports Clubs and Facilities

Sports venues regularly exceeding 200 capacity will be affected. Large stadiums will clearly fall into Enhanced Tier, but smaller clubs may also need to consider their obligations during peak times or special events.

Places of Worship

Churches, mosques, temples, and synagogues with 200+ capacity must implement security procedures. This raises sensitive issues about balancing security with the open, welcoming nature of religious communities.

Enforcement and Penalties

The Security Industry Authority (SIA) will regulate Martyn's Law. The SIA already oversees private security services and door supervisors, giving them relevant expertise in security matters.

SIA Powers

The SIA will have powers to:

Inspect premises — including unannounced visits
Issue compliance notices — requiring specific actions within set timeframes
Impose monetary penalties — fines for non-compliance
Prosecute serious breaches — leading to criminal sanctions

Financial Penalties

The potential penalties are substantial:

Standard Tier — fines up to £10,000
Enhanced Tier — fines up to £18 million or 5% of worldwide annual turnover, whichever is higher

These penalty levels reflect the seriousness with which the government views counter-terrorism security. Large organisations cannot treat fines as a cost of doing business.

Criminal Offences

Serious or repeated non-compliance can result in criminal prosecution. Responsible persons could face unlimited fines or imprisonment for up to two years. This personal liability mirrors the approach taken in other safety legislation like the Health and Safety at Work Act 1974.

Preparing for Martyn's Law Now

With implementation expected from mid-2027, venues have time to prepare. The Home Office will publish detailed statutory guidance during the implementation period, but you can take practical steps now.

Immediate Actions

Determine if you're covered — Calculate your venue's capacity including all staff, customers, and visitors. Don't forget peak times or special events that might push you over thresholds.

Identify who's responsible — Clarify whether you're the responsible person or if duties are shared. Check lease agreements, management contracts, and partnership arrangements.

Review existing security — Document current security measures, even basic ones. This provides a baseline for future risk assessments.

Start planning procedures — Begin thinking about how your venue would respond to a terrorist incident. Consider evacuation routes, lockdown procedures, and communication systems.

Building Security Awareness

Staff engagement — Introduce security awareness gradually. Staff who understand the rationale are more likely to comply with new procedures.

Integration with existing training — Link terrorism security to existing safety training. Many venues already train staff on fire safety procedures — terrorism response can build on these foundations.

Customer communication — Consider how you'll explain any visible security changes to customers. Transparency about your commitment to safety can enhance rather than damage customer confidence.

Enhanced Tier Preparation

If you're likely to be Enhanced Tier, start more detailed preparation:

Familiarise yourself with risk assessment — Understanding risk assessment principles will help when terrorism-specific guidance is published.

Identify your senior responsible individual — This person needs sufficient authority and knowledge to oversee security arrangements. Consider what training or support they'll need.

Map your venue — Create detailed plans showing entrances, exits, potential hiding places, and security equipment. This will be essential for risk assessments.

Review your supply chain — Consider security implications of deliveries, contractors, and service providers accessing your premises.

Professional Help vs Self-Implementation

The government has emphasised that Martyn's Law is designed to be implemented without specialist consultants. The forthcoming statutory guidance aims to provide clear, practical advice that responsible persons can follow themselves.

When You Can Self-Implement

Most Standard Tier venues should be able to develop procedures and training using official guidance. This mirrors the approach many businesses take to fire risk assessments — using competent internal staff rather than external consultants.

Enhanced Tier venues with straightforward layouts and operations may also manage self-implementation, particularly if they have experienced security or facilities management staff.

When Professional Help May Be Needed

Complex Enhanced Tier venues might benefit from specialist advice, particularly:

Large multi-use developments — shopping centres, mixed-use complexes
High-profile venues — locations likely to be attractive targets
Complex events — festivals, outdoor events with multiple venues
Historic or unusual buildings — where standard security measures are challenging

Even then, professional help should supplement rather than replace internal understanding. Responsible persons must understand their duties and maintain ongoing compliance.

Useful Resources

Several resources can help with preparation:

ProtectUK — The government's protective security website (protectuk.police.uk) provides free guidance on counter-terrorism security. Their resources cover threat awareness, security planning, and incident response.

SIA guidance — As the regulator, the SIA will publish detailed guidance on compliance. Monitor their website for updates as implementation approaches.

Home Office consultation — The Home Office conducted extensive consultation before the Act. The responses and government analysis provide insight into how the law will work in practice.

Frequently Asked Questions

When does Martyn's Law come into force?

The Act received Royal Assent in April 2025, but enforcement won't begin for at least 24 months. This means compliance is required from mid-2027 at the earliest. The government will confirm exact dates during the implementation period.

How do I calculate my venue's capacity?

Include everyone who can be on the premises at the same time — customers, staff, contractors, and visitors. Use your maximum occupancy, not average numbers. If you have existing capacity limits for fire safety or licensing, these may provide a starting point.

What if my capacity varies seasonally?

If your venue regularly exceeds 200 (or 800) people, you're likely covered even if quiet periods fall below the threshold. Consider your busiest trading periods and any special events you host.

Do I need to hire a security consultant?

No. The government has designed Martyn's Law to be implemented using official guidance without specialist help. Most venues, particularly Standard Tier, should manage compliance internally. Consider professional help only for complex Enhanced Tier premises.

What about venues with multiple tenants?

Responsibility depends on who controls security and public access. In shopping centres, the management company is typically responsible for common areas, while individual retailers handle their own units. Lease agreements should clarify responsibilities.

How does this relate to existing security requirements?

Martyn's Law adds to rather than replaces existing obligations. You'll still need to comply with licensing conditions, fire safety rules, and health and safety requirements. The terrorism security measures should integrate with your existing safety management systems.

What about temporary events?

Events with 800+ capacity are covered regardless of duration. A one-day festival has the same obligations as a permanent venue. Event organisers must consider the specific location and circumstances of each event in their risk assessments.

Can I be prosecuted personally?

Yes. The responsible person can face criminal prosecution for serious breaches, potentially resulting in unlimited fines or up to two years' imprisonment. This personal liability emphasises the importance of taking obligations seriously.

What training do staff need?

The Act requires training on your public protection procedures, but doesn't specify the format or duration. Training should ensure staff understand their roles in responding to terrorist incidents. This might include recognising threats, evacuation procedures, lockdown protocols, and communicating with emergency services.

How often must I review my arrangements?

Enhanced Tier venues must review risk assessments and security plans annually. Standard Tier premises should review procedures regularly, particularly after incidents elsewhere or changes to their venue. Good practice suggests annual reviews for all venues.

What to Do Now

Martyn's Law will significantly impact how UK venues approach security. While full implementation is still two years away, responsible persons should begin preparing now:

Calculate your venue capacity — determine which tier applies to you
Identify the responsible person — clarify who has duties under the Act
Review existing security measures — document what you already have in place
Monitor official guidance — watch for Home Office and SIA publications
Begin staff engagement — introduce security awareness gradually
Plan integration — consider how terrorism security fits with existing safety procedures

The cost of preparation is minimal compared to the potential penalties for non-compliance. More importantly, these measures could save lives if the worst happens. Don't wait for enforcement to begin — start planning your response to Martyn's Law today.

If your venue falls within scope of Martyn's Law, regular safety briefings for staff will be essential. Our Fire Safety and Emergency Preparedness toolbox talks provide ready-to-deliver briefings. Browse all toolbox talks.

Need Help?

If you're unsure how Martyn's Law applies to your venue, or you need help understanding your obligations, get in touch. We can help you assess your requirements and point you towards the right resources for your situation.