Following Royal Assent of the Terrorism (Protection of Premises) Act in 2025, Government has now published statutory implementation guidance.
Status of the Act
- The Act itself has not yet commenced and its legal duties are not yet enforceable.
- The Government has confirmed a minimum 24‑month implementation period, with commencement currently expected from Spring 2027 at the earliest.
- The guidance has been published deliberately in advance of commencement to allow organisations to understand their future obligations and prepare in a proportionate way.
Government guidance: preparing ahead of commencement
On 15 April 2026, the Home Office published final statutory guidance under section 27 of the Act, which has been laid before Parliament. This guidance is intended to support organisations in scope ahead of formal commencement.
In particular, the guidance encourages organisations to:
1. Confirm whether premises are in scope
- Retail and venue operators, including those in the leisure, hospitality and food & drink sectors, should assess whether there is a reasonable expectation that 200 or more individuals may be present at the same time.
- Capacity should be assessed pragmatically (for example by reference to fire safety occupancy limits, peak trading data, or venue or site format).
- Staff working on the premises count towards capacity.
2. Understand tiered obligations
- Standard tier: premises with an expected capacity of 200–799, including many retail stores, village halls, bars, restaurants and theatres.
- Enhanced tier: premises or events with an expected capacity of 800+, for example large shopping centres, concert halls and sports stadia.
- The guidance explains the baseline duties applicable to all qualifying premises, alongside the additional risk‑reduction duties for enhanced‑tier sites.
3. Begin internal planning (without formal compliance steps)
Although there is no obligation to comply yet, the guidance explains that organisations may wish to:
- Review existing emergency procedures, including evacuation, invacuation (moving people to a safe internal area), lockdown and communication arrangements.
- Identify who would be the “responsible person” for Martyn’s Law purposes at a corporate and site level.
- Consider staff awareness and training needs, building on existing health & safety or fire safety arrangements.
- Begin collating relevant information (for example site capacity assumptions and current procedures) so this is readily available once the Act commences.
For organisations across the retail, leisure and hospitality sectors, much of the guidance is intended to align with existing health and safety, security and operational arrangements, rather than requiring entirely new systems.
4. Avoid premature or unnecessary spend
The Government and police have been explicit that:
- No organisation is expected to be legally compliant at this stage.
- The Home Office and regulator do not endorse third‑party products or consultancy services claiming to offer “Martyn’s Law compliance” before commencement.
- The guidance emphasises that requirements are intended to be proportionate and accessible, particularly for standard‑tier premises such as retail, leisure and hospitality venues.
Regulatory position: Security Industry Authority (SIA)
- The Security Industry Authority (SIA) already exists as a statutory body and has been designated by the Act as the future regulator for Martyn’s Law.
- However, the new regulatory regime is not yet operational.
- Alongside publication of the Home Office guidance, the SIA has launched a public consultation on its draft statutory guidance setting out how it intends to regulate and monitor compliance and exercise enforcement powers once the Act is in force. This consultation closes on 12 June 2026.
- This SIA guidance is not yet final, and enforcement activity will not begin until after commencement of the Act.
Practical takeaway
For organisations within the retail, leisure and hospitality sectors:
This is a preparation and familiarisation phase, not a compliance deadline.
Organisations should focus on understanding scope, tier and responsibilities, mapping these against existing store safety procedures.
There is no legal requirement to implement new measures yet, but early planning should reduce regulatory risk and implementation pressure closer to commencement.
Please get in touch to discuss further:
Hayley Riach
Natalie Larnder
