Martyn’s Law – Statutory guidance published and SIA consultation launched

An important milestone in the coming into force of Martyn’s Law across the UK has been reached with the publication of the UK Home Office guidance and a Security Industry Authority (SIA) consultation launched on how it proposes to carry out its functions as regulator. 

This blog provides an update on both the UK Home Office guidance and SIA consultation and is relevant to those responsible for premises or events caught by Martyn’s Law who should be considering actions to ensure compliance now, ahead of the law coming into force next year.

Our previous blog explained the new law, borne out of the tragedy of the Manchester Arena attack. Known as “Martyn’s Law” its focus is public protection under the Terrorism (Protection of Premises) Act 2025 (“the Act”). Those responsible for ‘qualifying premises’ and ‘qualifying events’ in the UK must take steps to prepare for potential terrorist attacks and help keep people safe in the event of an attack.

As a reminder:

• Premises could be buildings or a combination of buildings and land.
• An event could be entirely indoors or outdoors or a combination of both attended by members of the public.
• Small events under 200 people are excluded and open access events without controlled entry are generally excluded.
• A standard duty applies to premises and events having between 200-799 attendee capacity (including staff), focusing on evacuation plans, invacuation, lockdown, and communication strategies.
• An enhanced duty applies to any premises and events with 800+ attendee capacity, requiring controlled entry and exit, monitoring, and physical security improvements. 

The key obligations under Martyn’s Law and operative duties are not yet in force, however the Home Office guidance is clear that "while there is no legal requirement to comply until the legislation comes into force, those in scope of the Act will wish to begin considering the requirements.” Now is the time to implement a good security culture with shared values from the top down. To assist our clients with preparations, and following the release of the Home Office guidance, we have set out matters that could be considered now and potential actions/changes to consider ahead of the operative duties eventually taking effect. 

Home Office statutory guidance 

A link to the Home Office statutory guidance can be found here.  

The guidance covers:

1. How to determine whether premises or events fall within scope, including how to calculate the number of persons likely to be present.
2. Who is responsible for compliance and the circumstances in which coordination and cooperation between multiple persons is required.
3. The types of public protection procedures and measures that can be deployed, the terrorist attack methods to be considered, training and awareness for staff and the requirements around documenting compliance. 

The guidance sets out clear steps for businesses. For example, for smaller premises like shops and restaurants with 200-799 people present at the same time, businesses must ensure evacuation routes are in place, staff know how to implement a lockdown in their building, and staff are aware of how to quickly communicate with their customers in the event of an attack. 

Larger premises and events like concerts and sports stadiums, where 800 or more people are present, businesses will be required to take further steps to reduce their vulnerability to acts of terrorism. For example, having CCTV, bag search policies, or vehicle checks where appropriate.

SIA guidance 

Separately, the SIA has launched a consultation on their draft section 12 statutory guidance. The guidance explains how the SIA plans to operate and use its powers as regulators under the Act. It sets out how the SIA will carry out its functions, including how it will monitor compliance, take enforcement action and how it will exercise its powers. 

The SIA’s draft guidance sets out how the regulator intends to oversee and support compliance. The consultation closes on 12 June 2026 and report on the consultation outcome will be published in due course. The consultation is intended for organisations responsible for premises and events within the scope of the Act, those advising them, persons with responsibilities under the legislation and members of the public.

A link to the consultation can be found here.

What Martyn’s Law means for your business  

Every premises or event in scope of Martyn’s Law will need to have a named responsible person who will be legally required to ensure that any venue and event is compliant with the law as far as reasonably practicable. The responsible person will be whomever controls the premises or controls the premises for the purposes of an event. These duties cannot be delegated, although tasks can be outsourced. Anyone with control ‘to any extent’ of premises or a qualifying event must cooperate with the responsible person as far as practicable.

Venue owners or operators will generally be the responsible person under Martyn’s Law and will need to ensure compliance. Where the premises are mainly used as an event space that is hired out, the person in control will usually be the premises operator (for example a hotel) rather than the hirer. However, even where the venue is the responsible person, the hirer is likely to have control of part of the premises and will have statutory duties to cooperate. For one off, occasional events, the responsible person could be the person responsible for the premises or the event organiser. Complications and potential liabilities could arise if restrictions were to be issued on the number of attendees after tickets were sold or if an event cannot proceed due to failure by the responsible person and/or the hirer in certain circumstances to meet the relevant duties. With the detailed guidance now available, it is crucial for event organisers to be aware of and monitor progress of the coming into force of Martyn’s Law and to consider actions that could be taken now or in the future to best protect their position. Risk registers may need to be updated to take account of the changes and guidance available. Insurers may require a response on actions taken in relation to cover.

We can help with keeping you informed of any developments or considering relevant commercial agreement/templates. For example, we can help you review any such pre-existing agreements and consider: 

• The application of Martyn’s Law and any in scope premises or events.
• Map control and accountability for an agreement that may have in scope premises or events, identifying who the responsible person would be in relation to any in scope premises or event relevant to the agreement.
• Consider the extent to which any agreement has appropriate protections for businesses based on their position and role and any changes that may be required.

Martyn’s Law represents a significant shift in how public safety responsibilities are managed in the UK. While the full obligations are still to come into force, the direction of travel is clear. For qualifying businesses operating public-facing venues and events, early preparation will be key.

Please get in touch with our Health and Safety Team or your usual Burness Paull contact for more information. 

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