Current Position
- The Terrorism (Protection of Premises) Act 2025 (Martyn’s Law) received Royal Assent on 3 April 2025.
- The Act introduces duties for qualifying premises (those with 200+ capacity) and qualifying public events.
- The Security Industry Authority (SIA) will act as the regulator, with responsibilities for compliance, guidance, enforcement, and reporting.
Both the Home Office and SIA have confirmed there will be a minimum 24-month implementation period before duties ‘switch on’. This means the regime is unlikely to be operational until mid-2027 at the earliest.
The new duties will apply across the UK (England, Wales, Scotland, and Northern Ireland).
Anticipated Guidance Timeline
Based on published government and SIA plans:
Late 2025 – 2026
- Home Office to produce section 27 statutory guidance explaining how responsible persons can meet their obligations under the Act.
- Draft guidance expected to be issued for consultation during 2026.
- SIA to prepare its own section 12 operational guidance setting out how it will regulate, which will also be subject to consultation.
- The SIA is currently recruiting staff and designing the organisational structure for its new Protective Security Regulation Division.
2026 – early 2027
- Consultation outcomes published and guidance refined.
- Stakeholder engagement programme (including with business sectors such as retail, hospitality, and events) to explain duties and expectations.
- SIA to establish processes, systems, and staff capacity.
Mid-2027
- The new regime goes live: Martyn’s Law duties formally come into force.
- Both Home Office statutory guidance and SIA regulatory guidance will be finalised and in effect.
- Enforcement powers (warnings, fines, compliance notices, potential criminal sanctions) become available to the SIA.
What This Means for Retailers and Venue Operators
- No immediate compliance duties: obligations are not yet in force.
- Preparation period: 2025-2027 is the window to review premises, assess likely capacity, and begin proportionate planning for protective security measures.
- Use available resources: Free materials and templates are accessible through ProtectUK.
- Early action recommended: Insurers and brokers are encouraging clients to maintain written terrorism protection procedures, training records, and preliminary risk assessments even before enforcement.
- Consultation opportunity: The 2026 draft guidance will be the key stage for the retail and hospitality sectors to influence the proportionality of expectations.
We will continue to keep you informed as draft guidance is published.
Contact:
Natalie Larnder - NLarnder@keoghs.co.uk
Hayley Riach - HRiach@keoghs.co.uk
