The Terrorism (Protection of Premises) Act 2025, also known as Martyn’s Law, received Royal Assent on 3 April 2025. Named after Martyn Hett, a victim of the 2017 Manchester Arena bombing, Martyn’s Law is intended to improve public safety and protect against the threat of terrorism by enacting wide-ranging implications for owners and operators of ‘qualifying premises’ and ‘qualifying events’.
You can read more about the implications of Martyn’s Law for property owners and business operators in our previous update here.
In this follow up article we provide a brief overview of the requirements under Martyn’s Law, the expected implementation period, intended oversight of regulatory compliance with its requirements and the offences imposed under the legislation.
Sections 5 to 10 of Martyn’s Law establish requirements for venues and events to mitigate against terrorism risks. Venues with a capacity exceeding 200 attendees must assess potential terrorist threats and implement appropriate security measures, including staff training and emergency procedures. Larger venues accommodating over 800 attendees are subject to enhanced security obligations, such as installing alert systems and developing publicly visible security plans.
The requirements apply to both:
The responsibility for ensuring these requirements are met lies with the person or entity who has been nominated as the responsible person for the premises or event, for example, the premises owner or event organiser, who must then implement and maintain the necessary measures.
Although Martyn’s Law received Royal Assent on 3 April 2025, it's expected that the implementation period will be at least two years. During this period the Home Office will publish statutory guidance to assist those responsible to understand the requirements set out in the legislation.
While individuals and entities falling within the scope of the legislation aren't required to comply until it officially comes into force, it's advisable that they begin preparing early. Planning ahead will ensure readiness to meet the requirements outlined in sections 5 to 10 and achieve full compliance by the time the law is enacted.
Martyn’s Law establishes regulatory functions to ensure its successful implementation, with the government confirming that these will be carried out by a new arm of the Security Industry Authority. While the authority’s primary mission will be to support, advise, and guide those responsible for premises and events in fulfilling legal obligations, its regulatory powers under the legislation will enable it to investigate and enforce compliance when necessary.
The authority will utilise a variety of powers and sanctions to address serious or repeated breaches of the relevant requirements that are outlined in sections 5 to 10. This includes:
In addition to the above, the is authority is awarded various powers under Schedule 3 of Martyn’s Law to enable it to carry out’s it’s regulatory functions. This includes powers relating to entry of premises, inspection and information gathering.
Section 24 of Martyn’s Law confirms that a person will be a committing a criminal office if they fail to comply with a compliance or restriction notice issued by the Security Industry Authority. There is a potential defence to this if the accused can provide sufficient evidence to illustrate that they took all reasonable steps to comply with the notice, although this is only applicable if the contrary is not proven beyond reasonable doubt.
It's also an offence, under section 25 of Martyn’s Law, for a person to provide false or misleading information to the Security Industry Authority in compliance, or purported compliance, with a requirement imposed, where the person knows that, or is reckless as to whether, the information is false or misleading. A person who commits an offence under sections 24 or 25 of Martyn’s Law could be subject to potential imprisonment, a fine, or both.
There are also offences outlined in Schedule 3 of Martyn’s Law, including failing to comply with an information notice, impersonating an authorised inspector and obstructing an authorised inspector from carrying out their investigatory powers. The first two of these offences could result in a fine, whereas the latter could result in imprisonment, a fine, or both.
If a body, such as a company or partnership, commits one of the abovementioned offences, section 26 of Martyn’s Law confirms that if the offence occurs with the consent, connivance, or neglect of a relevant person within the body, that individual, in addition to the body itself, is liable to face legal action and punishment. The term 'relevant person' refers to those involved in the management or control of the body, including officers, members, partners, or others with responsibility over the body’s operations. This ensures that both the body and its responsible individuals can be held accountable for offences under the legislation.
While Martyn's Law may not be fully implemented for at least two years, businesses and event organisers should begin preparing now. The obligations set out in the legislation, including stringent security measures, may take time to develop and implement.
With the Security Industry Authority granted broad powers to issue penalties, enforce compliance, and take action against non-compliant entities, it's crucial that required standards are met ahead of the legislation’s full implementation. The consequences for non-compliance can be severe, ranging from significant fines, potentially exceeding £18 million in some cases, to imprisonment. Starting early will be essential to avoid these penalties and to ensure full compliance.
For further information, please contact our business risk and regulation team.
