Do your premises sometimes host more than 200 people for events? If so, legislation which received Royal Assent in early April, creates new responsibilities and requirements with which you need to comply. The changes seek to enhance the safety of those attending events and to minimise any potential harm from a potential terrorist attack.
The Terrorism (Protection of Premises) Act 2025, commonly referred to as Martyn’s Law, was devised, developed and enacted in the wake of the 2017 Manchester Arena attack. The explosion killed 22 people, including Martyn Hett after whom the law is named. Additionally, more than 1,000 people were injured.
There will be an implementation period of two years before the new legislation comes into force. This will give premises owners and event organisers time to understand and fully comply with their obligations.
During this time, a new capability within the Security Industry Authority is being created to oversee the enforcement of the legislation. It will also draw up guidance to provide support and guidance to those affected.
Premises covered by Martyn’s Law
The legislation is tiered, and the first layer of new obligations applies to premises that can reasonably expect to host audiences of between 200 and 799 people. The rules apply to all manner of premises and include everything from community halls and sports clubs to cafes and entertainment venues.
The second layer of obligations applies to premises that can reasonably expect to have audiences of 800 people or more. In addition, they will be accessible to members of the public for the purpose of the event and have certain entry measures in place, such as ticket checks. These premises can include land without buildings such as a sports field or a park.
Obligations created by Martyn’s Law
The first tier creates two overarching obligations. These are to:
- Notify the Security Industry Authority of your premises
- Have in place, so far as reasonably practicable, appropriate public protection procedures
These measures might include simple steps such as codifying procedures to lock down venues, making plans to move people to safe spaces and creating the ability to issue clear communications to those present.
There is no requirement to put in place physical protection measures, and the legislation is not prescriptive to allow each venue the freedom to devise steps that are appropriate for its particular circumstances.
The second tier also introduces the following additional obligations that include:
- Have in place, so far as reasonably practicable, appropriate public protection measures that will reduce both the vulnerability of the premises or event to an act of terrorism, and the risk of physical harm to individuals
- Document your planned and implemented public protection measures and provide this information to the Security Industry Authority. It should include an effectiveness assessment of these measures
Sanctions for non-compliance
Martyn’s Law will apply consistently throughout England, Wales, Scotland and Northern Ireland.
Where individuals or organisations fail to comply with the legislation the Security Industry Authority will have a number of enforcement options. These range from compliance and restriction notices to financial penalties and criminal convictions.
The maximum fine for a breach of standard level duties is £10,000. For enhanced level duties, fines can be up to the greater of £18m or 5% of an organisation’s worldwide revenue.
Ensure you and your audiences are protected
Since the Manchester Arena attack, the Home Office says there have been 15 domestic terror attacks in the UK. In addition, more than 40 late-stage plots have been disrupted before they could take place. This highlights the scale of the threat and why the measures enshrined in Martyn’s Law are so important.
In addition to reviewing the guidance that the Security Industry Authority produces, individuals and organisations that fall under the scope of Martyn’s Law should examine exactly how it applies to them and what appropriate steps they should take.
As another area of risk management responsibility, Martyn’s Law is no less important than other legislative material that already exists.
If you would like to discuss how Martyn’s Law might affect your organisation and to identify the individuals who will ultimately bear responsibility, please get in touch with our expert team at Keegan & Pennykid.
