It has been coming for what seems like aeons, but at long last, Martyn’s Law, the Terrorism (Protection of Premises) Act 2025, has been signed off by the Government. Setting up the regulatory system, procedures, and compliance enforcement will still take some time, with a practical roll-out pencilled in for commencement sometime in early 2027.
Much has been written about the background to this new law and its importance, and I will not go over old ground. Here I’d like to give security managers and those responsible for the safety of qualifying premises an indication of the top 10 areas they need to be considering to not only get a head start on legal compliance, but to ensure your sites are as safe as possible from the results of terrorist action.
1. Establish Legal Obligation
Is the site/event deemed small enough for Martyn’s Law not to apply? That is to say, does it only hold a maximum of 199 persons?
Where the Act applies, does the site qualify as a “Standard Tier”, ie, a 200 – 799 person maximum site or event capacity?
or “Enhanced Tier” for sites and events over 800 people.
- If the TPPA2025 does not apply to your site due to the low capacity driven risk profile, please be aware that there may be nearby buildings or sites that may be at higher risk.
If this is the case, consider, understand, and take reasonable steps to mitigate the effect on your property or site of an incident taking place nearby. Consultation with other local businesses will have significant mutual benefits. - Should your venue or business fall in the “Standard Tier” category, the steps you will need to carry out are, on the whole, simple, basic and largely common sense.
- For “Enhanced Tier” sites or events, the Act requires somewhat more compliance activity from owners and management.
NB: For the full responsibilities of Standard and Enhanced Tier buildings or events, and the idea behind the creation of the legislation, please visit the official government announcement.
2. Review Staff CT Awareness & Perform Appropriate Training
Do you have staff on site with counter terrorism training, and is a CT incident plan in place?
- Arrange ACT online training for all staff in security roles and consider basic awareness training for public-facing and engineering/maintenance staff members as well.
- Ensure that all staff members are trained and aware of the nature of threats, likely attack methodologies, and are taught to identify the signs of hostile reconnaissance and take appropriate action.
- It is vital that regular refresher training takes place on site and is fully documented, as all staff must be clear in their responsibilities and actions if a CT plan needs to be activated.
NB: Check out the resource by ProtectUK for more details.
3. Assess Access Control
Do you have an appropriate access control system and procedure?
- Consider the use of physical restrictive access measures, technology and trained staff to detect and mitigate risks from intruders carrying concealed weapons or explosives.
NB: For advice, guidance and signposting to appropriate equipment and suppliers for all security-related hardware, I strongly recommend the Secured by Design website.
4. Evaluate Perimeter Security
Where applicable, is your site perimeter secure and are all doors and windows locks in good condition?
- Perform basic maintenance or replace any substandard locks or closing mechanisms.
NB: For detailed guidance, explore the resource by NPSA.
5. Audit CCTV
Where applicable, is your CCTV system providing clear recorded footage of all entrances, exits, external and public areas? Is it monitored when the site is open?
- Revise or update the CCTV cameras and recording system to provide full coverage of vulnerable or high-risk areas, in all light conditions.
- Where applicable, ensure that an SIA-licensed CCTV operator is on duty to monitor your system when needed.
NB: Check out ProtectUK’s resource on CCTV operation.
6. Ensure Safe Movement During Evacuation / Invacuation / Lockdown
Have you evaluated the layout of your site and designated escape routes to ensure a safe and rapid site evacuation/invacuation or lockdown?
- Keep all fire exits and escape routes clear of obstructions. Attempt to position furniture or equipment to minimise “choke points” and maximise the ease of movement in an emergency.
- Ensure effective communication measures are in place to clearly and concisely inform staff and visitors what is happening and what they need to do.
NB: Check out HSE’s resource on planning for event safety and emergencies.
7. Review External Environment
Have you examined the open areas around your site to mitigate the risk of a “vehicle as a weapon” attack?
- Review the approach to your building or site, and where appropriate, look at the built environment and methods. Use these to prevent or hinder the progress of a vehicle driven with hostile intent.
NB. Review the official Hostile Vehicle Mitigation (HVM) guidance for more details.
8. Consider Advanced Trauma Care Training Needs
Do any of your staff have advanced trauma training?
- Where appropriate, consider training a percentage of personnel in D13 / FREC3 first responder emergency trauma first aid. This will ensure the best possible outcomes for those injured in any serious incident, in or around your site.
NB: One of the most well-respected sources of advice and guidance on pre-hospital care is the Royal College of Surgeons of Edinburgh.
9. Conduct Blast Mitigation
Have you implemented blast effect mitigation measures?
- Consider minimising the use of interior glass panels or using clear plastic film on windows and areas of glass to minimise fragmentation.
- Use heavyweight materials for furniture and fittings in public areas to reduce the chance of fragmentation and to help divert blast and absorb shrapnel or debris.
NB: For more information, check out the resource by the National Protective Security Authority.
10. Monitor Threat Levels
Are you aware of the current threat levels, and where applicable, do you have a building response plan?
- Where appropriate, write an emergency response plan.
- Brief your staff when threat levels are heightened and adjust your procedures, staffing and general readiness when required.
- Assign someone to check on the “UK National threat level” and the “building response level” daily.
- Note the actions you take. If you have an emergency response team, ensure they are trained and tested regularly.
NB: Visit the official government website covering guidelines on threat levels and building response plans for more information.
Stay Compliant: What Martyn’s Law Means for Your Site’s Future
I hope that this provides a decent starting point for counter terrorism awareness and legal compliance. The body tasked with the enforcement and regulation of Martyn’s Law is our very own Security Industry Authority (SIA), which will be releasing much more in the way of guidance over the next year and a half, so please keep an eye on their website for updates.
GuardPass can support your site’s compliance journey and help you keep up with SIA licensing changes with access to licensed professionals, quick onboarding, and BS7858 vetting solutions. Tap into our trained talent pool and ensure you’re legally prepared for Martyn’s Law.