Martyn's Law, officially known as The Terrorism (Protection of Premises) Act 2025 (the Act), received Royal Assent at the beginning of April.
The new law aims to ensure better security in places which could be a target for a terrorist attack. The Act will not come into force for at least two years, to give both the Government and those who will be responsible time to prepare.
The Act is named after Martyn Hett, one of the victims of the Manchester Arena attack. In the words of Martyn's mother who campaigned for this new law, it means "putting in place basic security procedures so that every venue and public space has a plan… Martyn's Law doesn't advocate a one-size-fits-all-approach, it's all about having a plan relevant to the threat".
What properties will the Act apply to?
Martyn's Law will apply across the UK to premises or events visited by large numbers of the public, for example shopping centres, restaurants and bars, entertainment and leisure venues, sports grounds, conference centres and hotels.
Certain premises are excluded, such as airports and railway stations which are already subject to separate requirements. Parks and recreation grounds with open access are also excluded.
The Act does not apply to office buildings, except where the premises are used mainly for providing services to visiting members of the public.
Martyn's Law applies to "qualifying premises" and "qualifying events"
For premises which are used for one of these qualifying purposes, there is a tiered approach depending on how many individuals are expected at the premises.
If 200 or more individuals (including staff) may be on the premises at the same time, then the "standard" duties will apply to the premises.
If 800 or more individuals may be present at the same time, then the "enhanced" duties will apply.
Enhanced duties will also apply to a "qualifying event". This is where 800 or more members of the public (including staff) may be present at the event and there is a condition of entry. This can be that they have paid to attend, need a ticket or pass, or are members of a club or other body.
This means that enhanced duties may apply to an event, even if the premises where the event is being held are not themselves "qualifying premises". So a large concert held in a park would be caught by the enhanced duties.
The guidance sets out how to assess the number of individuals that are reasonably expected to be present at a qualifying premises or qualifying event.
Who is responsible for ensuring compliance with the Act?
For qualifying premises, the ‘responsible person’ is the person who has control of the premises in connection with the relevant qualifying use.
For qualifying events, the ‘responsible person’ is the person who has control of the premises at which the event will be held.
In some cases, there will be more than one ‘responsible person’ and the parties must cooperate to ensure compliance.
The Security Industry Authority (SIA) will be the regulator for the Act.
What are the requirements for standard duty premises?
Premises and events with a capacity of 200-799 must, so far as is reasonably practicable, have appropriate public protection procedures in place to reduce the risk of physical harm being caused to individuals in the event of an act of terrorism.
These procedures can include evacuation, invacuation (i.e. moving people to a safe place) or lockdown. Measures are meant to be low cost for standard duty premises and can be as simple as locking a door and identifying safe routes. The responsible person must notify the SIA that the standard duties apply.
What are the additional requirements for enhanced duty premises?
Premises and events with a capacity of 800 or more must also have measures in place to reduce their vulnerability to an act of terrorism, such as monitoring and security. These measures could include bag search policies, CCTV or other monitoring and vehicle checks.
These procedures and measures must be documented and provided to the SIA.
What enforcement action will be taken if Martyn’s Law is breached?
Enforcement action will be taken by the SIA and some breaches of the Act will be criminal offences. In the most serious cases for enhanced duty premises or events, the SIA can restrict how many people are allowed at the premises or event, and impose penalties of up to the greater of £18 million and 5% of worldwide revenue.
What should landlords, tenants and event operators do now?
While many large premises and events will already have anti-terrorism and security measures in place, landlords, tenants and event operators should start thinking now about the measures and procedures they will need to have in place.
It will generally be the occupier of the property who is responsible for these duties. However, for properties such as shopping centres, the landlord will be responsible for security in the common areas, while tenants will be responsible for their units. It may be that a large individual unit is subject to standard duties, but the shopping centre as a whole is subject to enhanced duties. Landlords and tenants will need to cooperate to ensure that these new requirements are met.