Martyn’s Law: Counting Down to ‘Live’ Implementation

The Terrorism (Protection of Premises) Act 2025 (‘Martyn’s Law’) became an Act in April 2025 and will come ‘into force’ in Spring 2027 (based on current estimates).  Its purpose is simple: to save lives.

The coming year is an important period to think about changes that need to be phased in now to ensure compliance from ‘day 1’.  

Our previous article provided some advanced thinking on that topic. A key message is to do some thinking now about how you might / will be impacted.  Don’t assume you won’t be in scope: the Act has broad reach and significant compliance duties which will affect organisations across a wide range of sectors. 

More detailed analysis can now be found in the new Home Office Guidance, designed  to help organisations assess whether they fall in scope, and the SIA is consulting on its draft regulatory approach until 12 June 2026.  We will provide practical takeaways on these in an upcoming post. 

In the meantime, we suggest four priority actions for organisations.

Four things to do now

1. Carefully assess whether you are in scope

   • Identify who your ‘responsible person’ is
     • Apply the definitions to establish what is ‘in scope’
     • Consider how the Act applies to your specific operational model 

2. Understand what compliance requires of you

   • Out of scope
     • Standard tier
     • Enhanced tier
3. Plan your transition and integration
   • You may be able to build on things you already have
     • You will need to integrate new duties into existing systems ahead of implementation.
     • Consider particularly training, risk mitigations, procedures, and governance

4. Engage with the consultation

   • The preparatory phase is an opportunity to participate in shaping how the Act will operate in practice. 

     • The SIA’s consultation allows organisations to comment on the clarity and practicality of the proposed guidance

The new Home Office Guidance assists with these priority actions by bringing the Act to life with worked examples. 

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If you would like to discuss how Martyn’s Law may affect your organisation, please get in touch with Charlotte Whitaker, Lloyd Nail or Marie-Elizabeth Bailey in our Corporate Crime and Investigations Team. 

This article was written by Marie-Elizabeth Bailey  

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Further Notes to Readers: 

A significant legal shift

Martyn’s law was introduced in response to the 2017 Manchester Arena Attack and is named after Martyn Hett who was sadly killed in the attacks. Its purpose is simple: to save lives.

The Act shifts the dial on terrorism risk from a previously often largely reactive approach to one focused on prevention and preparedness.

The Act aims to improve security and preparedness by requiring those responsible for certain premises and events to consider how they would respond to a terrorist attack. In addition, certain premises and events will be subject to enhanced duties in order to further lower their overall vulnerability to terrorism. 

To ensure consistency, it will apply across the UK.

The basic structure 

The Act introduces a tiered system with duties determined by: 

• Whether the premises or event is “qualifying” (public access + capacity thresholds)
• The number of people reasonably expected to be present
• The nature of the activity

Key features are:

• Standard‑tier premises may only need simple measures e.g. basic emergency procedures such as evacuation or lockdown.
• Enhanced‑tier premises and qualifying events however will face more robust requirements for example, physical security such as CCTV or operational security such as bag searches or vehicle checks.
• Some premises are excluded where other security frameworks already apply or where compliance would be impractical.
• The Security Industry Authority (SIA) will regulate and enforce the Act
• The Act will be backed by both civil penalties and criminal sanctions to ensure compliance (fines up to £50,000 daily; and penalties up to £18 million or 5% of global turnover).
• The Act also creates criminal offences, including failing to comply with notices, providing false information, or obstructing inspectors.
• Senior individuals may be personally liable where offences occur with their consent, connivance, or neglect.

Understanding whether and how the Act applies to your organisation is critical.