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legal update  /  30th Dec 2025

Martyn’s Law – Progress, scope and preparation

SECTION GUIDE

The Terrorism (Protection of Premises) Act 2025, commonly known as Martyn’s Law, represents a major shift in how the UK approaches public protection and preparedness for terrorist incidents.

Introduced following the Manchester Arena attack in 2017, the legislation places clear legal responsibilities on those who control certain publicly accessible premises and events to take proportionate steps to reduce the risk of harm to the public.

Although Martyn’s Law has now received Royal Assent, it is not yet in force. This provides organisations with a critical opportunity to understand their future duties and embed sensible, well-integrated protective measures ahead of enforcement.

Martyn’s Lawimpact hr ident

  • Why Martyn’s Law matters for organisations

    Martyn’s Law is not about turning everyday venues into heavily fortified spaces. Instead, it reflects an expectation that organisations:

    • Recognise terrorism as a foreseeable risk
    • Plan and prepare for emergencies in a structured way
    • Equip staff with the confidence to respond effectively
    • Integrate public protection into existing governance, health and safety and risk management systems

    For many organisations, the underlying principles will feel familiar. Martyn’s Law builds on established duties around risk assessment, emergency planning and staff training, but places terrorism preparedness on a clear statutory footing.

  • What is Martyn’s Law?

    Martyn’s Law introduces a statutory Protect Duty. This duty requires those responsible for qualifying premises and events to:

    • Consider the risk of terrorist incidents
    • Put in place reasonably practicable measures to reduce harm
    • Prepare for an effective response should an incident occur

    Importantly, the duty focuses on preparedness and resilience, not intelligence gathering or predicting attacks. Organisations are not expected to identify threats or individuals. They are expected to ensure that procedures, plans and people are ready to respond if an incident happens.

  • Implementation period and expected timeline

    While Martyn’s Law has passed into law, it will not apply immediately.

    The Government has confirmed a minimum two-year implementation period, designed to allow organisations time to prepare and to enable the regulatory framework to be fully established.

    Key points include:

    • The Security Industry Authority (SIA) has been appointed as the regulator
    • Further statutory guidance and sector-specific advice will be published
    • Registration, compliance monitoring and enforcement processes will be introduced

    Current expectation:

    • Martyn’s Law will come into force in Spring 2027
Martyn’s Law

Understanding scope: is your organisation affected?

A key early step for organisations is determining whether their premises or events fall within scope of Martyn’s Law.

Premises and events in scope

Martyn’s Law applies to publicly accessible premises and qualifying events where it is reasonable to expect 200 or more people to be present at the same time.

Premises likely to be in scope include:

  • Retail premises and shopping centres
  • Hospitality venues such as pubs, bars, restaurants and hotels
  • Entertainment and leisure venues including cinemas, theatres and sports grounds
  • Visitor attractions, museums and galleries
  • Places of worship with unrestricted public access
  • Education settings hosting large public events

  • Conference centres and exhibition venues

Qualifying events may include concerts, festivals, sporting fixtures, ticketed events and temporary events where capacity thresholds are met.

The duty applies to the responsible person, typically the organisation or individual with control over the premises or event.

Capacity thresholds and tiered duties

Martyn’s Law adopts a two-tier approach, ensuring requirements remain proportionate.

Capacity is based on the maximum number of people reasonably expected to be present at the same time, not average attendance.

  • Standard tier: 200–799 people
  • Enhanced tier: 800 people or more

Organisations should be able to explain and evidence how capacity has been assessed.

  • What is outside the scope of Martyn’s Law?

    The following are generally outside scope:

    • Premises with a capacity of fewer than 200 people
    • Private workplaces that are not open to the public
    • Private residential buildings
    • Small private functions that are not open to the public

    Mixed-use premises should be reviewed carefully, as publicly accessible areas may still fall within scope even if other parts of the building do not.

  • How Martyn’s Law aligns with existing legal duties

    Martyn’s Law is intended to complement, not replace, existing legal obligations.

    Many organisations already have relevant arrangements in place under:

    Martyn’s Law strengthens these frameworks by ensuring that terrorism risk is explicitly considered and addressed.

The two-tier duty explained in practice

  • Standard tier duties (200–799 capacity)

    Organisations in the standard tier must:

    • Negister with the SIA that they are responsible for qualifying premises or events
    • Put in place reasonably practicable public protection procedures, including:
      • Evacuation arrangements
      • Lockdown procedures
      • Clear communication plans
    • Ensure staff have appropriate awareness and understanding of what to do during an incident

    This tier focuses on planning and preparedness rather than physical security measures.

  • Enhanced tier duties (800+ capacity)

    Organisations in the enhanced tier must meet all standard tier requirements and also:

    • Maintain documented public protection procedures and measures
    • Implement proportionate steps to reduce vulnerability to terrorist acts
    • Retain clear evidence of compliance
    • Be prepared to provide documentation to the SIA

    Measures may be physical, procedural or organisational, but must always be risk-based and proportionate.

What organisations can do now to prepare

Although enforcement is still some time away, the Government strongly encourages organisations to begin preparation now. Early action allows duties under Martyn’s Law to be integrated sensibly into existing systems, rather than added under pressure closer to commencement.

  • Confirm whether premises or events are in scope

    Organisations should begin by establishing whether any of their premises or events meet the criteria for Martyn’s Law. This involves assessing whether locations or events are publicly accessible and whether it is reasonable to expect 200 or more people to be present at the same time. Where capacity fluctuates, organisations should consider peak usage rather than average attendance and record the basis for their conclusions.

  • Identify the applicable tier

    Once scope is confirmed, organisations should determine whether they fall within the standard tier (200–799 people) or enhanced tier (800+ people). This distinction is critical, as the level of duty increases significantly for enhanced tier premises and events. Clear identification of the applicable tier will shape the scale of documentation, controls and oversight required.

  • Review existing risk assessments and emergency plans

    Most organisations already have emergency arrangements in place for fire, health and safety incidents or major disruptions. These documents should be reviewed to confirm whether they adequately address terrorist incidents, or whether gaps exist. Martyn’s Law does not require separate systems, but it does require terrorism risk to be clearly considered and reflected within existing assessments and plans.

  • Ensure terrorist threats are considered alongside other foreseeable risks

    Terrorism should be assessed in the same structured, proportionate way as other foreseeable risks. This means considering how an incident might occur, how people could be harmed, and how the organisation would respond. The focus should be on realistic scenarios relevant to the premises or event, rather than speculative or extreme possibilities.

  • Develop or refine evacuation, lockdown and communication procedures

    Clear, practical procedures are at the heart of Martyn’s Law. Organisations should ensure they have documented plans for evacuation, lockdown and internal or external communication, tailored to their premises or events. These procedures should be simple, accessible and capable of being followed under pressure, rather than overly complex or theoretical.

  • Provide staff awareness training, such as ACT Awareness

    Staff play a critical role in effective response. Organisations should ensure that employees, volunteers and relevant contractors have appropriate awareness of terrorist risks and understand what to do if an incident occurs. Training should be proportionate to role and responsibility, with refresher activity planned where appropriate to keep knowledge current.

  • Begin documenting arrangements, particularly where enhanced tier duties are likely to apply

    Documentation will be a key feature of compliance, especially for enhanced tier premises and events. Organisations should begin recording risk assessments, procedures, training and decision-making processes now. This not only supports future regulatory inspection but also improves consistency and resilience across the organisation.

  • Assign internal responsibility for Protect Duty compliance

    Clear ownership is essential. Organisations should identify who will be responsible for overseeing Martyn’s Law compliance, coordinating preparation activity and monitoring ongoing requirements. This role may sit within health and safety, facilities, operations or senior management, depending on the organisation’s structure.

  • Monitor official guidance as further detail is published

    Further statutory guidance and sector-specific advice will be issued during the implementation period. Organisations should actively monitor updates and be prepared to adjust arrangements as expectations become clearer. Building flexibility into plans now will make it easier to adapt later without significant rework.

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Your Questions Answered

Everything you need to know about Martyn's Law

  • Who was Martyn Hett?Reveal

    Martyn Hett was one of the 22 people killed in the Manchester Arena terrorist attack in May 2017. He was attending a concert when the attack took place at the end of the event.

    Martyn’s Law is named in his memory following a sustained and highly influential campaign led by his mother, Figen Murray OBE, who has worked closely with government, security professionals and victims’ groups to improve public protection and preparedness. The legislation reflects a desire to ensure that lessons learned from the attack lead to meaningful, preventative change rather than reactive responses after incidents occur.

  • What is the Protect Duty?Reveal

    The Protect Duty is the legal obligation introduced by Martyn’s Law. It requires those responsible for certain publicly accessible premises and events to take proportionate and reasonably practicable steps to reduce the risk of harm to members of the public from terrorist incidents.

    The duty focuses on planning, preparedness and response, rather than prevention or intelligence gathering. In practice, this means having suitable procedures, trained staff and clear communication arrangements in place, rather than attempting to predict or stop attacks.

  • Is Martyn’s Law currently in force?Reveal

    No. Although Martyn’s Law has received Royal Assent, it is not yet in force. The Government has confirmed a minimum two-year implementation period, during which enforcement will not take place.

    This period is intended to give organisations time to understand their responsibilities, assess scope, and put proportionate measures in place. Enforcement is currently expected to begin in Spring 2027, subject to final guidance and regulatory arrangements.

  • Who will enforce Martyn’s Law?Reveal

    The Security Industry Authority (SIA) has been appointed as the regulator for Martyn’s Law.

    The SIA will be responsible for:

    • Registration of qualifying premises and events
    • Monitoring compliance with the Protect Duty
    • Providing guidance and oversight
    • Taking enforcement action where necessary

    The regulatory approach is expected to be proportionate and supportive, particularly during the early stages of enforcement.

  • Will organisations need security guards or expensive systems?Reveal

    Not necessarily. Martyn’s Law is designed to be proportionate and risk-based. For many organisations, compliance will be achieved through procedures, planning and staff awareness, rather than physical security measures.

    While some enhanced tier premises may introduce additional controls, there is no blanket requirement to employ security guards or install costly infrastructure. The emphasis is on what is reasonable and appropriate for the specific premises or event.

  • Does Martyn’s Law apply to offices and workplaces?Reveal

    Martyn’s Law does not automatically apply to offices and workplaces. It only applies where premises are publicly accessible and meet the 200-person capacity threshold.

    Private workplaces that are not open to the public are generally outside scope. However, offices with publicly accessible reception areas, visitor spaces or large public events should be assessed carefully, as those areas or activities may fall within scope.

  • Is training mandatory under Martyn’s Law?Reveal

    Martyn’s Law does not prescribe specific training courses. However, it does require that staff have appropriate awareness and understanding of procedures and how to respond in the event of a terrorist incident.

    For many organisations, ACT Awareness training will be a suitable and proportionate way to meet this requirement. Training should be relevant to staff roles and refreshed as appropriate to ensure confidence and competence are maintained.

  • Should organisations wait until guidance is finalised?Reveal

    No. While further statutory and sector-specific guidance will be published, waiting until the final stages of the implementation period significantly increases the risk of rushed, fragmented or poorly embedded compliance.

    Early preparation allows organisations to:

    • Integrate Martyn’s Law into existing systems
    • Spread activity and cost over time
    • Test and refine procedures
    • Respond calmly to future guidance rather than react under pressure

    Early, proportionate action is strongly encouraged by Government and regulators alike.

Where to find out more A collection of hand-picked useful resources for Martyn's Law from impact HR and beyond

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