FAQ Charities and Martyn’s Law

The Terrorism (Protection of Premises) Act 2025, widely known as Martyn’s Law, came into force in April last year, with a two year long implementation period to allow venues and events organisers to get ready.  The Home Office published their Statutory Guidance on Martyn’s Law in April 2026.

The regulator for Martyn’s Law is the Security Industry Authority (“SIA”). The SIA’s guidance on section 12 (regulatory approach and enforcement) is currently under consultation.

Will it apply to my charity?

There are no exemptions for charities. In a short blog it is impossible to explain fully the complex rules, but as a general rule:

• An Event is one that is open to the public with some form of entry control such as tickets or membership. 
• Premises are listed in Schedule 1 of Martyn’s Law. They must be used for a wide range of purposes which include most activities a charity would get up to – it includes museums, cafes, theatres, conferences, libraries, entertainment or recreation venues, healthcare and education.

Qualifying Events or Premises come in two tiers based on how many people there may be present “from time to time or occasionally”:

• Standard tier – between 200 and 799 people
• Enhanced tier – 800 or more people.

The Statutory Guidance says that “from time to time or occasionally” could be really infrequent, with the result that it includes just once or twice a year.  Therefore, if you expect to have over 199 (or over 799) people at your premises just once or twice a year, the premises will fall into the Standard (or Enhanced) tier.  

What obligations will we have?

If you have enhanced tier premises you have to ensure that appropriate public protection measures are in place, so far as is reasonably practicable, in relation to all the activities that take place there.

For standard tier premises, events will either be standard (200-799 people) or enhanced (800 or more people).

Standard tier obligations are designed to be simple and low cost and include:

• Implement and maintain public protection procedures aimed at reducing physical harm in a terrorist incident, including evacuation, invacuation or lockdown approaches
• Ensure staff training and preparedness, including familiarity with emergency plans and roles during an incident (communication, crowd management)
• No requirement for physical alterations or new equipment unless it is reasonably practicable to do so, and would improve the effectiveness of procedures
  For sites or events that fall into the Enhanced tier, in addition to standard tier obligations, the duty holder will be required to:
• Undertake formalised risk assessments tailored to specific premises and activities
• Develop a documented security plan that may need to be submitted to the regulator on request
• Appoint a Designated Senior Individual to oversee compliance and liaise with the Security Industry Authority (“SIA”)
• Implement proportionate security measures where reasonably practicable such as controlled access, CCTV or enhanced monitoring based on risk level
• Ensure staff training and preparedness, including familiarity with emergency plans and roles during an incident (communication, crowd management)
• No requirement for physical alterations or new equipment unless it is reasonably practicable to do so, and would improve the effectiveness of procedures

For sites or events that fall into the Enhanced tier, in addition to standard tier obligations, the duty holder will be required to:

• Undertake formalised risk assessments tailored to specific premises and activities
• Develop a documented security plan that may need to be submitted to the regulator on request
• Appoint a Designated Senior Individual to oversee compliance and liaise with the Security Industry Authority (“SIA”)
• Implement proportionate security measures where reasonably practicable such as controlled access, CCTV or enhanced monitoring based on risk level

It is worth noting that educational venues (other than those delivering higher education) and those used for worship will always fall under the standard tier, regardless of size.

It is worth noting that educational venues (other than those delivering higher education) and those used for worship will always fall under the standard tier, regardless of size.

Who is responsible for the obligations?

All qualifying premises and events will have a responsible person. Usually this will be a company or organisation, but it could be an individual.

• For qualifying premises, the responsible person has control of the premises for the “Schedule 1” use.
• For a qualifying event, the responsible person has control of the premises in connection with their use for the event.

When the responsible person for enhanced tier premises or a qualifying event is a company or organisation, the responsible person must designate a senior individual to ensure the Act’s requirements are met.

Where more than one person is responsible for an event or venue (for example where a charity hires a conference venue) there is a duty to co-operate.

Are there any penalties for non compliance?

The SIA will advise on and enforce compliance with the regulatory requirements of the legislation, supporting those responsible for qualifying premises and events to meet their obligations and determine what reasonably practicable procedures and measures should be put in place.

The SIA will have powers to review a charity’s documentation, conduct site visits, and require remedial improvements where procedures fall short of statutory expectations. There are significant financial penalties for non-compliance as well as a range of new criminal offences.

When do we need to be ready?

Full implementation will occur in or after April 2027. Charities should expect more detailed regulatory guidance from the SIA as consultations progress, which will supplement the Home Office guidance published recently.

Early preparation is strongly encouraged to avoid a scramble close to implementation deadlines and to embed good practice securely and sustainably.

How do we prepare?

The first step is to assess how your charity’s events and premises might fit into the regime.

Charities should identify who is responsible for Martyn’s Law compliance and how this fits with existing roles across the charity and event organisers. Clarity here is important so that responsibilities do not fall between different teams or committees.

Finally, there is a lot that charities can do now at very low or no cost.

Free counter terrorism training, awareness materials and ProtectUK guidance are already available and can be rolled into existing staff training and induction processes.

Taken together, these steps put charities in a strong position well before the duties formally come into force.

If you would like any advice about your charity’s obligations under this new law please get in touch with Neil Burton, Richard Sykes or Tamsin Morris.

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