Act<\/strong>) \u2013 commonly known as “Martyn’s
\nLaw” \u2013 is set to transform the way public venues and
\nevents across the UK approach security and preparedness for
\nterrorist threats.<\/p>\nThe Act is named in memory of Martyn Hett, one of the 22 victims
\nof the 2017 Manchester Arena terrorist attack. Since his death, his
\nmother, Figen Murray, has led a tireless campaign to improve public
\nsafety and ensure that lessons are learnt from that event \u2013 a
\ncampaign that led to the passing of this legislation.<\/p>\n
The Act received Royal Assent in April 2025 and is anticipated
\nto come into force around April 2027, giving businesses plenty of
\ntime to prepare. When it does, owners and operators of a wide range
\nof premises and event spaces will be subject to a new duty intended
\nto enhance venue security and improve public safety.<\/p>\n
While we wait for the Act to come into force, venues and
\norganisers should start identifying which sites and activities fall
\nwithin scope, what practical steps are needed for compliance, and
\nhow to ensure related technologies \u2013 such as facial
\nrecognition \u2013 are secure and legally compliant.<\/p>\n
In this article, we provide an overview of the new law and
\nhighlight some of the key provisions and considerations for those
\naffected.<\/p>\n
Who does it apply to?<\/h3>\n
The Act applies to “qualifying
\npremises<\/strong>” which are premises that consist of a
\nbuilding (or part of, or a group of buildings), that are wholly or
\nmainly used for certain specified purposes (such as entertainment,
\nleisure, sport, retail, hospitality, museums, visitor attractions,
\nconference centres, and higher education), and in respect of which
\nit is reasonable to expect that from time to time 200 or more
\nindividuals may be present on the premises at the same time.
\nCertain premises are specifically excluded, for example, government
\npremises and transport hubs.
\nPremises are classified according to capacity:<\/p>\n
<\/p>\n- standard duty premises<\/strong> are qualifying premises
\nwhere 200-799 individuals may be present at the same time.<\/li>\n
\n
<\/p>\n
- enhanced duty premises<\/strong> are qualifying premises
\nwhere 800+ individuals may be present at the same time.<\/li>\n
\n<\/ul>\n
Note that places of worship, childcare settings, schools, and
\nfurther education institutions are always treated as standard duty
\npremises, even if the number of individuals that might attend
\nexceeds 800.<\/p>\n
The Act also applies to “qualifying
\nevents<\/strong>” which are ticketed, members-only, or paid-for
\nevents open to members of the public held at premises that are not
\nclassified as enhanced duty premises but where 800 or more
\nindividuals may be present at the same time. For example, a
\nqualifying event might be a temporary outdoor music festival.<\/p>\nWhat is required?<\/h3>\n
The requirements depend on the classification of the
\nactivity:<\/p>\n
<\/p>\n- for standard duty premises<\/strong>, public protection
\nprocedures must “so far as reasonably
\npracticable<\/em>” be in place, with the objective of reducing
\nthe risk of physical harm being caused to individuals if an act of
\nterrorism were to occur on the premises. These procedures cover
\nevacuation, lockdown (preventing entry or exit), and clear
\ncommunication with those on site. Importantly, those responsible
\nfor standard duty premises are not obliged to install new physical
\nsecurity measures.<\/li>\n
\n
<\/p>\n
- for enhanced duty premises<\/strong> and
\nqualifying events<\/strong>, public protection measures must
\nbe in place to reduce vulnerability to terrorist attacks and
\nminimise the risk of harm caused if an act of terrorism were to
\noccur. The measures must be assessed and kept under review and must
\ncover:<\/li>\n
\n
<\/p>\n
-
\n
<\/p>\n- monitoring the premises or event, and its immediate
\nsurroundings;<\/li>\n
\n
<\/p>\n
- managing how people move into, out of, and within the
\nsite;<\/li>\n
\n
<\/p>\n
- improving physical security at the premises or event; and<\/li>\n
\n
<\/p>\n
- ensuring the security of information relating to the premises
\nor event.<\/li>\n
\n<\/ul>\n
\n<\/li>\n
\n<\/ul>\n
The procedures and measures must be documented and submitted to
\nthe Security Industry Authority (SIA<\/strong>), the entity
\nresponsible for the enforcement of the Act, along with an
\nassessment of how they are expected to reduce risk and
\nvulnerability. The extent and scope of the procedures and measures
\nrequired is likely to be clarified by the Government in guidance to
\nbe released before the Act comes into effect.<\/p>\nWho is responsible?<\/h3>\n
Responsibility for compliance falls on the
\n“responsible person<\/strong>“, which is the
\nperson or organisation with “control” of the premises or
\nevent. Where multiple parties share control, such as landlords,
\noperators, or event promoters, each will be considered a
\nresponsible person under the Act. They must, so far as is
\nreasonably practicable, coordinate and work together, especially
\nwhere premises overlap or are adjacent.<\/p>\nHow will the Act be enforced?<\/h3>\n
The SIA will have powers to advise, investigate and enforce
\ncompliance with the Act. Where it identifies a breach, the SIA can
\nissue compliance notices (requiring remedial action) or restriction
\nnotices (which can limit how, when or by whom a venue is used, or
\neven prohibit an event from taking place). Penalties for
\nnon-compliance are significant: up to \u00a310,000 for standard
\nduty breaches, and for enhanced premises or events, up to the
\ngreater of \u00a318 million or 5% of qualifying worldwide revenue,
\nwith additional daily penalties for ongoing breaches. Criminal
\nliability may arise for failure to comply with notices or for
\nproviding false or misleading information.<\/p>\n
Commercial takeaways for live music, sport and events<\/h3>\n
While we wait for the Government’s official guidance, there
\nare several practical steps that venues and organisers can take now
\nto prepare:<\/p>\n
<\/p>\n- Map out premises to identify which are likely to be caught by
\nthe standard or enhanced duties.<\/li>\n
\n
<\/p>\n
- Understand which planned events might constitute qualifying
\nevents.<\/li>\n
\n
<\/p>\n
- Identify the “responsible person” for each premises
\nor event, and, for organisations, appoint a senior individual to
\noversee compliance. Where multiple parties are involved, such as
\nlandlords, operators, or promoters, establish clear protocols for
\ncoordination and information sharing.<\/li>\n
\n
<\/p>\n
- Review and refresh your incident response plans to ensure they
\ncover the applicable protections and measures, which may include
\nevacuation, invacuation or shelter, lockdown, and effective
\ncommunication with the public (using PA systems, screens, or mobile
\nmessaging as appropriate).<\/li>\n
\n<\/ul>\n
These plans should be aligned with your existing safety and
\ncrowd management procedures, and you could consider scheduling
\ndrills or exercises to ensure staff and contractors understand
\ntheir roles and responsibilities.<\/p>\n
If you are caught by enhanced duties, you could consider
\nreviewing entry and crowd management procedures such as queuing
\nsystems, bag checks, and vehicle access controls, assessing
\nmonitoring tools like CCTV and radio communications, and
\nimplementing access controls in relation to sensitive site
\ninformation (e.g., plans or control room details).<\/p>\n
Be mindful that procedures and measures will need to work for
\ndisabled spectators, families, touring crews and other vulnerable
\ngroups, and multilingual communications should be considered where
\nappropriate.<\/p>\n
Legal considerations<\/h3>\n
We recommend that you review and update contracts with
\npromoters, hirers and contractors where needed to reflect the new
\nduties. You may also need to consider insurance and the costs of
\ncompliance as part of a wider liability discussion.<\/p>\n
In addition, any venue\/event considering deploying a technology
\nsolution (e.g., a ticketing system or an ID verification system)
\nwill need to be mindful of laws regulating:<\/p>\n
<\/p>\n- Data protection<\/strong> if the solution processes
\npersonal data of staff or attendees e.g., the Data Protection Act
\n2018. Stricter protections apply to the processing of “special
\ncategory personal data”, which includes biometric data and
\nwill therefore need to be considered as part of a data privacy
\nimpact assessment carried out for any biometric verification or
\nticketing solution.<\/li>\n
\n
<\/p>\n
- Artificial intelligence<\/strong> if the solution
\nconstitutes an “AI system” under the EU AI Act and falls
\ninto scope. If it does, compliance obligations may apply depending
\non the venue\/event’s use of the solution and its
\n“operator” classification.<\/li>\n
\n
<\/p>\n
- Equality and human rights<\/strong> to ensure that
\ndirect or indirect discrimination against individuals does not
\noccur e.g., that an automated verification solution does not
\ndiscriminate against event attendees contrary to the Equality Act
\n2010.<\/li>\n
\n<\/ul>\n
It’ll be important to ensure that third-party vendors or
\nhosting providers are subject to appropriate contractual
\nobligations and restrictions, including compliance with law
\nobligations, and that robust audit and information security
\nmeasures are in place.<\/p>\n
Staying prepared and further updates<\/h3>\n
As statutory guidance from the Home Office and the Security
\nIndustry Authority (SIA) is released, organisations should stay
\ninformed and be ready to adapt their plans and procedures
\naccordingly. We will continue to monitor developments and publish
\nfurther updates as the implementation period progresses.<\/p>\n
The content of this article is intended to provide a general
\nguide to the subject matter. Specialist advice should be sought
\nabout your specific circumstances.<\/em><\/p>\n<\/p><\/div>\n \u2018 The preceding article may include information circulated by third parties \u2019 <\/em><\/p>\n \u2018 Some details of this article were extracted from the following source www.mondaq.com \u2019 <\/em><\/p>\n","protected":false},"excerpt":{"rendered":"
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The Terrorism (Protection of Premises) Act 2025 (the
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