Are you ensuring compliance with the duties imposed by Martyn’s Law at your venue and/or events? 

Martyn’s Law – what is it?

Martyn’s Law is the informal name for The Terrorism (Protection of Premises) Act 2025 (the T(PP)A/the Act), which was introduced to better protect the public from terrorism. The T(PP)A imposes duties on the person responsible for qualifying premises and/or qualifying events to put in place public protection procedures and to prepare against terrorist attacks.

When does Martyn’s Law take effect?

Whilst the T(PP)A received Royal Assent on the 3rd April 2025, it is expected that the implementation period will be at least 24 months, giving organisations the time to seek legal advice, if needed, and implement the necessary changes to their premises and events to ensure compliance.

The framework

Under the T(PP)A, those responsible for qualifying premises and qualifying events have certain obligations – either standard duties or enhanced duties, depending on the relevant circumstances.

Qualifying Premises

The T(PP)A is far-reaching and covers many settings including a number in the cultural, heritage, educational and healthcare sectors. Qualifying premises under the Act are premises which consist of a building or a building and other land which is used for one or more of the purposes specified in Schedule 1. These purposes include use as a library, museum or gallery where admittance is principally to visiting members of the public and use as a visitor attraction of cultural, historic or educational value.

The Act may not apply to smaller venues, as organisations will only be caught where there is an expectation that from time to time 200 or more individuals may be present on the premises at the same time in connection with one or more of the Schedule 1 uses. Also, certain premises will be excluded under Part 1 of Schedule 2. Examples of excluded premises include parks and gardens.

Enhanced Duty Premises

Qualifying premises are “enhanced duty premises” if there is a reasonable expectation that from time to time 800 or more people may be present there at the same time in connection with a Schedule 1 use. (Otherwise, they will be treated as “standard duty premises”). There are certain exceptions to this 800-person rule. For example, places of worship and some childcare and education settings which have a “special consideration” in place are treated as standard duty premises, even if they expect that from time to time 800 or more individuals will be present.

For more information on the duties applying to qualifying premises see below.

Qualifying events

An event is a qualifying event under the Act if:

• the premises at which the event is to be held consist of a building, other land or a building and other land,
• they are not enhanced duty premises (see definition above) and do not form part of enhanced duty premises,
• members of the public will have access to the premises for the purpose of attending the event,
• it is reasonable to expect that at some point during the event 800 or more individuals may be present on the premises at the same time in connection with their use for the event,
• measures will be in place to secure or check that members of the public who wish to access the premises for the purpose of attending the event have paid to do so, have tickets or passes or are members or guests of a club, association or similar body, and
• the event is not an excluded event under Part 2 of Schedule 2 of the Act. Excluded events include events to be held at premises wholly or mainly used for worship, childcare or primary, secondary or further education.

What duties are imposed under the T(PP)A?

The T(PP)A requires, so far as reasonably practicable, that persons responsible for qualifying premises or qualifying events should ensure that appropriate public protection procedures are in place to reduce the risk of physical harm being caused to individuals if terrorism were to occur on the premises, at the event or in the immediate vicinity of the premises or event.

Public protection procedures are procedures for evacuating individuals; moving individuals to somewhere where there is less risk of physical harm; preventing individuals entering and leaving; and providing information to individuals. They must be followed by individuals working at a qualifying premises or event if there is a reason to suspect that an act of terrorism is occurring, or is about to occur, there.

Persons responsible for enhanced duty premises and qualifying events must also:

• ensure measures are in place to further the objectives of reducing the vulnerability of the premises or event to acts of terrorism and reducing the risk of physical harm being caused to individuals if an act of terrorism were to occur on the premises, at the event or in the immediate vicinity of the premises or event.
• assess and keep public protection measures under review to further the objectives above. Public protection measures in this context are measures relating to:
  • the monitoring of the premises or event and the immediate vicinity of the premises or event,
  • the movement of individuals into, out of and within the premises or event,
  • the physical safety and security of the premises or the premises at which the event is to be held,
  • the security of information in relation to the premises or event.

The measures that are reasonably practicable at each qualifying premises or event will inevitably vary; the person(s) responsible for complying with the T(PP)A should consider their specific situation and may need to seek advice.

Enhanced duties – the obligation to prepare a document

Persons owing enhanced duties are required to ensure that a document is prepared and kept up to date containing:

• a statement of the procedures in place,
• an assessment of how those procedures may be expected to reduce the risk,
• a statement of the measures in place or proposed to be put in place,
• an assessment of how those measures may be expected to reduce the vulnerability and risk, and
• such further information as the Secretary of State may specify in regulations.

A copy of the document must be provided to the Security Industry Authority (SIA) as soon as reasonably practicable after it is prepared, and if it is revised, before the end of the period of 30 days beginning with the day of its revision.

Who is the person responsible? 

The requirements under the T(PP)A fall on the person responsible for qualifying premises or a qualifying event. In practice, the person responsible for qualifying premises would typically be the individual who has control of those premises in connection with their principal relevant use. For the purposes of a qualifying event the person responsible is the individual in control of the premises at which the event will be held, for the purpose of the event. If more than one person is responsible for qualifying premises or a qualifying event, those persons must, so far as reasonably practicable, co-ordinate with each other in complying with the requirements imposed under the Act.

What penalties or offences may be imposed for non-compliance?

The SIA is the enforcement authority under the T(PP)A. Adverse consequences for non-compliance with the Act include civil sanctions on premises, events and individuals (not just persons responsible). They include:

• compliance notices requiring an individual to comply with a relevant requirement within a specified period if the SIA have grounds to believe there has been a contravention,
• penalty notices of varying amounts depending on the circumstances of the non-compliance, including but not limited to:
  • fixed financial penalties for contravention of the T(PP)A up to a maximum of £10,000 for standard duty premises, and a maximum of either 5% worldwide revenue or £18 million, whichever is greater, for enhanced duty premises,
  • daily fines of up to £50,000 for continuing non-compliance, and
  • restriction notices requiring compliance by a person responsible for enhanced duty premises or qualifying events with specified prohibitions or restrictions.

The T(PP)A also introduces a criminal offence for non-compliance with a compliance or restriction notice and/or for providing misleading information.

How we can help

If you need support in understanding whether your organisation’s premises and/or events are in-scope of Martyn’s Law, or you want support in meeting the requirements of this legislation, please contact Matthew Smith, Partner and Head of our Public & Regulatory team.