“Martyn’s Law”, formally the Terrorism (Protection of Premises) Act 2025, introduces a new statutory framework aimed at improving preparedness and public protection at publicly accessible premises. The legislation follows a series of terrorist incidents, most notably the Manchester Arena attack in 2017, and reflects a policy decision that venues hosting members of the public should have proportionate plans in place to reduce harm should the worst occur.
The Act received Royal Assent in 2025 and is subject to an implementation period of at least 24 months before full commencement.
A key milestone was reached in April 2026 with the publication of statutory guidance by the Home Office under section 27 of the Act. This guidance is intended to explain the new duties in practical terms and to support organisations in understanding what compliance looks like in practice. Importantly, it emphasises that the regime is designed to be workable and proportionate, rather than prescriptive or overly burdensome.
Core structure and obligations
Martyn’s Law applies to qualifying premises and events that are publicly accessible and meet defined capacity thresholds. It adopts a tiered approach:
- Standard tier premises are those where it is reasonable to expect between 200 and 799 people to be present at the same time.
- Enhanced tier premises and events are those where 800 or more people may be present at the same time, from time to time.
All premises within scope must notify the regulator, the Security Industry Authority (“SIA”), and provide details of the “responsible person”. The responsible person is the individual or organisation with control of the premises or event and legal responsibility for compliance. Where the responsible person is an organisation, a senior individual must be designated to ensure the duties are properly discharged.
Across both tiers, duty-holders must ensure that appropriate public protection procedures are in place, so far as reasonably practicable. The Act identifies four such procedures:
- Evacuation – moving people safely away from danger.
- Invacuation – moving people to safer locations within the premises.
- Lockdown – securing the premises to restrict entry or movement.
- Communication – ensuring timely and clear information is provided to those on site.
For enhanced tier premises, there is an additional requirement to put in place appropriate public protection measures designed to reduce vulnerability and the risk of harm. These are grouped into four broad categories: monitoring, movement controls, physical safety and security, and security of information. Enhanced tier duty-holders must also document their procedures and measures and provide this information to the SIA.
What this means in practice
For many established venues – including stadiums, large event spaces, clubs and other busy public venues – these obligations will look familiar. Existing contingency planning, safety management systems, licensing conditions and risk assessments often already address evacuation, crowd management, communication and baseline security controls.
In that sense, Martyn’s Law will not require a wholesale reinvention of operational practices for many operators. Instead, it formalises and standardises expectations across the sector. Organisations may find they are already broadly compliant in substance, even if their current arrangements are not explicitly structured or labelled by reference to the Act.
Proportionality and risk management
A central theme of both the legislation and the guidance is proportionality. The duties are qualified by what is “reasonably practicable”, requiring organisations to balance risk against cost, time and operational impact. The intention is not to mandate expensive or intrusive security measures in all cases.
There is, however, a real risk that some organisations may be encouraged to adopt excessive or costly measures based on overly cautious interpretations or opportunistic third-party advice.
Dr Steve Frosdick is an independent expert in safety at sports grounds. He says:
“I am advising my clients to avoid the snake oil salesmen who say you must buy this and that and upgrade the other to comply with Martyn’s Law. Venues which hold a general safety certificate were already responsible for counter-terrorism security under the Sports Grounds Safety Authority’s wider definition of safety to include security for violence, disorder and terrorism.
“They will almost certainly find that the four public protection procedures form part of their current contingency plans and that the four public protection measures are already covered in their current security plans. Of course, venues will want to review their arrangements to make sure everything is properly in place, but the work required to demonstrate compliance should be fairly minimal.”
We agree that Operators should be wary of “one size fits all” solutions and focus instead on demonstrably reasonable steps that address the specific risks associated with their premises or events.
Why the guidance matters
The publication of formal Home Office guidance is a significant and welcome development. It provides structure, clarity and reassurance for duty-holders and sets out the government’s expectations in a clear, accessible way. It also reinforces that compliance should be achievable without unnecessary expenditure or reliance on specialist consultants.
As the SIA prepares for its regulatory role, the guidance offers a practical benchmark against which compliance will be assessed, helping organisations to plan with greater confidence.
Next steps for organisations
Operators of publicly accessible premises should now take the opportunity to:
- Review existing policies, procedures and risk assessments.
- Map those arrangements against the Act and the section 27 guidance.
- Identify any gaps, areas requiring formalisation, or minor refinements.
Taking these steps early will allow organisations to approach Martyn’s Law in a measured and proportionate way, building on existing good practice while ensuring they are well placed for the regime’s formal commencement.
A comment from Tim Williamson, partner and head of our regulatory team, who works closely with Safety Officers and Directors of sports clubs advising on legal and health and safety risk at stadia across the country, notes:
“Many clients and organisations already have robust risk mitigations in place to counter the threat of terrorist activity at their stadium or venue. However, we have seen the regulatory framework evolve, notably**, through “Martyn’s Law”, and it is very important that stadium and venue operators are aware of the latest developments** and use official guidance to inform their review of such controls, to ensure they are fit for purpose.
“The issuing of such guidance is often no substitute for judgement based on experience; however, we would urge everyone involved in stadium safety to pay close attention to the guidance recently issued. We shall be pleased to assist with any queries regarding stadia specific risks and mitigations, in collaboration with experts such as Steve Frosdick with whom we work on an ongoing basis.”
If you would like to discuss these matters in more detail, please contact Tim Williamson or Steve Frosdick.
Written by Tim Williamson and Steve Frosdick
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