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Terrorism (Protection of Premises) Act 2025, UK wide

Martyn's Law Compliance Support

Martyn's Law will require the people who control public premises to plan for a terrorist attack with the same discipline they already apply to fire. AL23 Safety helps you settle which tier you fall into, draft your public protection procedures and rehearse them with your teams, for premises and events UK wide.

What is Martyn's Law?

A preparedness duty on premises, not a duty to stop an attack

Martyn's Law is the working name for the Terrorism (Protection of Premises) Act 2025. It received Royal Assent on 3 April 2025 and places duties on the responsible person for qualifying premises and qualifying events. The purpose is to reduce harm if an attack happens at or near your site. There is no duty to prevent an attack and none to buy any particular product.

Be clear on the timing. The substantive duties are not yet in force. As at August 2026 only preparatory provisions have commenced, namely section 27 on publishing guidance from 10 April 2026 and parts of section 12 on Security Industry Authority guidance from 15 June 2026. Government policy is an implementation period of at least 24 months from Royal Assent, which puts expected go live in spring 2027. That is an expectation rather than a statutory date. The SIA notification portal is targeted for the same point.

Home Office statutory guidance under section 27 was published on 15 April 2026. Final SIA guidance under section 12 is due in autumn 2026 and has not been published. Anyone claiming the detail is fully settled is ahead of the evidence.

Who needs one

Who the Act catches and at what headcount

The trigger is occupancy rather than sector alone. Getting the expected headcount defensible decides everything that follows.

Standard tier

A reasonable expectation of 200 to 799 individuals present at the same time.

Enhanced tier

A reasonable expectation of 800 or more individuals. Qualifying events at 800 or more are treated as enhanced tier.

Always standard tier whatever the capacity

Places of worship, childcare premises, primary, secondary and further education premises.

The qualifying premises test

All four limbs must apply. A building or a building and land, wholly or mainly used for a Schedule 1 use, a reasonable expectation of 200 or more present at the same time, not excluded by Schedule 2.

Schedule 1 uses

Shops, food and drink, entertainment, sport, libraries, museums and galleries, halls, visitor attractions, hotels, places of worship, healthcare, transport stations, aerodromes, childcare, education and public authority premises.

The responsible person

Whoever has control of the premises for the Schedule 1 use. The duty is not delegable, although co-operation duties arise where several parties share a building.

The regulations that apply

Your legal framework, in plain terms

The Terrorism (Protection of Premises) Act 2025 is the source of the duty. It does not sit on its own. Section 3 of the Health and Safety at Work etc. Act 1974 already requires you to conduct your undertaking so that non-employees are not exposed to risk. Regulation 8 of the Management of Health and Safety at Work Regulations 1999 already requires procedures for serious and imminent danger. The Regulatory Reform (Fire Safety) Order 2005 already requires an evacuation plan and trained staff. Integrate Martyn's Law with those duties rather than running a separate paper exercise.

Section 5, public protection procedures

Both tiers must put procedures in place across four types. Evacuation, invacuation, lockdown and communication.

Section 6, public protection measures

Enhanced tier only, in four categories. Monitoring, movement, physical safety and security, security of information.

Notification to the regulator

Both tiers must notify the Security Industry Authority that the premises are in scope.

Documentation and submission

Enhanced tier must document the procedures and measures with an assessment of how they reduce vulnerability and harm, then submit that document to the SIA.

Senior responsible individual

Where the enhanced tier responsible person is a body rather than an individual, it must designate a senior responsible individual accountable for compliance.

The SIA is the regulator, with compliance notices, restriction notices for enhanced tier, monetary penalty notices and criminal offences at its disposal. The maximum monetary penalty is £10,000 at standard tier. At enhanced tier and for qualifying events it is the greater of £18 million or 5 per cent of qualifying worldwide revenue.

What the service covers

From tier determination to a rehearsed procedure

  • Occupancy modelling for each building, using door counts, ticketing data, licensed capacity and peak trading patterns rather than a guess.
  • A written tier determination recording the Schedule 1 use relied on, the Schedule 2 exclusions considered and the reasoning behind the headcount.
  • The four public protection procedures for evacuation, invacuation, lockdown and communication, written as instructions staff can follow under pressure.
  • Reconciliation with your existing fire evacuation plans so that a lockdown instruction never contradicts a fire alarm response.
  • For enhanced tier, an assessment across the four measure categories covering monitoring, movement, physical safety and security, security of information.
  • The enhanced tier document itself, structured to show how each procedure and measure reduces vulnerability and harm, ready for submission to the SIA.
  • Advice on designating and briefing the senior responsible individual.
  • Staff briefing and scenario exercises, including a table top run through of a lockdown and a partial invacuation.
  • Integration with your emergency planning and business continuity arrangements so that recovery is planned as well as response.

Our process

Five steps, run before the duties bite

  1. 01

    Scoping call

    We establish your portfolio, the use of each premises, the events you run and who holds control, then say early where we expect tier boundaries to fall.

  2. 02

    Site visit and occupancy work

    We walk the premises, look at entrances, circulation and the places people would be moved to, then test your figures against real data.

  3. 03

    Tier determination and gap analysis

    We issue the determination and set out what is in place, what needs writing and what needs rehearsing.

  4. 04

    Procedures and, at enhanced tier, measures

    We draft the documents and work them through with your operational managers until the instructions match how the site actually runs.

  5. 05

    Training and exercise

    We brief staff, run an exercise and agree a review date so the pack is current when the duties commence.

What you get

Documents that will hold up in front of the SIA

  • A written tier determination with the occupancy evidence behind it.
  • A public protection procedures document covering all four procedure types, with role cards for front of house, security and management.
  • For enhanced tier, the public protection measures assessment and the submission ready document for the SIA.
  • A gap register with actions, owners and dates set against the expected spring 2027 go live.
  • Exercise notes and a debrief recording what needs changing.
  • A one page staff summary for induction and for agency or seasonal workers.

What we need from you

A short list, gathered once

  • Occupancy and attendance data, licensed capacities and any ticketing or footfall reports.
  • Current fire strategy, evacuation plan and any existing lockdown procedure.
  • Lease, concession and management agreements where control of the premises is shared.
  • Access to a manager who knows how the site runs at its busiest.
  • Names of the people you expect to hold the senior responsible individual role at enhanced tier.

Why AL23 Safety

Counter-terrorism planning built on fire discipline

Accountable

Where your occupancy figure will not survive scrutiny or your lockdown cannot be delivered with the staff on shift, we say so and set out the fix.

One team, three disciplines

Health and safety, fire safety and fire engineering in-house, which matters when an invacuation instruction has to coexist with a fire evacuation strategy.

Practical, not just compliant

We write procedures a duty manager can act on in seconds, not a policy that helps nobody at the moment it is needed.

UK wide

We support premises, venues and event organisers across the UK from our Manchester base.

Get ahead of commencement

Quiet preparation now beats a rushed programme in 2027

Nothing requires you to wait. The tier determination, the occupancy evidence and the four procedures can be completed while the duties are dormant, which spreads the cost and removes the scramble.

Common questions

Answers, up front

Cannot see your question? Get in touch and we will answer it directly.

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No. The Act received Royal Assent on 3 April 2025 but the substantive duties have not commenced. Only preparatory provisions covering guidance are live. Go live is expected in spring 2027 based on the stated implementation period of at least 24 months. That is an expectation rather than a fixed statutory date.

It turns on the number of individuals it is reasonable to expect at the same time. Between 200 and 799 is standard tier. From 800 upwards is enhanced tier. Places of worship, childcare and education premises stay standard tier whatever their capacity.

Price is driven by the number of premises, your tier, how many parties share control and whether you want exercises as well as documents. A single standard tier venue is a modest piece of work, with a site visit and a draft inside a few weeks. A multi-site enhanced tier portfolio takes longer, since the measures assessment and the SIA document need input from security, facilities and senior management. Call us and we will scope it against your estate rather than quote a figure blind.

No. The Act is framed around what is reasonably practicable and proportionate, with no requirement to purchase specific equipment. Standard tier is expected to be largely procedure and training at low or nil cost.

It is a strong start and exactly where we begin. It does not cover invacuation, lockdown or the communication duty. On its own it will not satisfy section 5. We build the counter-terrorism procedures onto your existing fire risk assessment rather than starting a parallel system.

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