The consultancy Surelock International, whose senior security consultant Stewart Brown we featured in the June 2026 edition of Professional Security Magazine, reports on work for its first client about the requirements of Martyn’s Law.ย
We conducted an in-depth security survey-audit review and report in relation to an event that took place by a local authority, involving the presence of over 800 persons (at any one time) attending a small town centre area for a late spring/summer May Fair Festival, over a bank holiday weekend. Therefore over four days that the public came to enjoy Fun Fair rides, activities, shows, food and drink stalls and various other family activities. The ‘Event’ has been a local, yearly and entertaining activity, generating public interest and attendance for a few hundred years.
Surelock consultants attended the site numerous times over the weekend, looking in detail at the safety and security aspects of the members of the public attending the event. The local authority area of the town centre for the weekend was designed and designated entirely for the fun fair and activities, generating extra footfall and movements of the public.
All the Martyn’s Law public protection procedures and measures were considered in a systematic way to identify how the local authority, relevant organisations and entertainment contractors were dealing with the provisions they provided. Initially being an open, outside event, only ‘evacuation’ procedures were looked at, as ‘invacuation’ and ‘lockdown’ procedures clearly were not relevant or needed to be considered. ‘Communication’ procedures were also reviewed, aboutย how to identify, respond and react to potential suspicious activity or terrorist threats that could interrupt the event.
Who’s responsible
The local authority has identified the town council as the ‘Responsible Person’ and the major Fun Fair contractor/event operator as the ‘Designated Senior Individual’, which then confirms who would be registered and responsible with the Security Industry Authority (SIA), to enable this type of qualifying event to take place, and if they were to inspect the actual event.ย A simple contingency plan has been identified (involving how to react to something suspicious or untoward) for all staff and workers at the event, then how to communicate to the emergency services, public using safe protocols, direction and requirements that would not escalate the dangers to other members of the public and enable and allow the emergency services including the authorities to deal with a large-scale incident, activity or emergency.
A re-gig of staff at the event and using someone (or more than one) with an entire focus on the safety-security of attendees at the eventย has been identified, that can clearly assist with anything suspicious or of safety/security concern at the event area.
Due to the large numbers of the public counted and identified, present at any time, then enhanced tier premises and qualifying event protocols, being public protection measures, were then considered in detail, which included ‘Monitoring’ – CCTV, ‘Movement Control’ – including access control, ‘Physical Safety and Security’ – including manpower personnel, perimeters, structures, lighting and other security/safety aspects, and the ‘Security of Information’ – including security aspects of the area, activity and information at the event, which was publicly available.
These public protection measures are very similar to our usual findings when we conduct an overall security survey-audit review for any business or residential premises, but we had to reconstruct our methods of identifying and obtaining the facts or information to be able to understand any strengths and weaknesses in line with the Terrorism (Protection of Premises) Act 2025 – Martyn’s Law compliance and requirements.
The additional measure of looking at the security of information, being anything and everything that relates to the event activities (or premises) brings into detail our investigation skills and inquisitive mind to a great degree, which surprisingly identified how, far too much sensitive information is available in the public domain and on the world wide web (internet) that could be misused by terrorists, criminals and activists, who would try to attack or disrupt an event/premises attended by large numbers of members of the public.
Using the Martyn’s Law – Statutory Guidance and the provisional Security Industry Authority – Statutory Operational Guidance documents, we have been able to produce a ‘Statement and Threat Assessment Compliance Document’ that can be sent to the SIA, for them to see if the event is fitting into the regulation requirements of Martyn’s Law.
This process and project, using a different approach and open mindset, focused mainly on ‘Martyn’s Law’, then having to correctly justify our findings, facts and operational requirements, with reviewing any publicity, procedures, documentations, current practices and safety protocols in place has taken over twice as much consultancy time, as usually would be considered, in producing a Security Survey and Audit Report under normal circumstances.
Recently the Home Office and the SIA in documentation have accepted that others (consultants, advisors etc) can be involved in assisting this process on behalf of the ‘Responsible Person’ but legally they will still be responsible for the activities at the premises or event.
Next year
As time is moving quickly on to the implementation date of April 3, 2027, when Martyn’s Law comes into effect, the Home Office and the SIA have stated the following information, which is worthy to note for all owners/operators and event organisers:
1.โโโโThose responsible for qualifying premises will have three months from the date of commencement to submit the notification. After that initial period, any changes, including becoming or ceasing to be responsible, must be notified with 28 days.
2.โโโโFor those responsible for a qualifying event, the clock starts when the event is first publicised. In most cases, you’ll need to notify us within 14 days of the event date being made publicly available.
โโโโโ(published in an email by the SIA titled ‘SIA Martyn’s Law Update’ on Thursday, July 16, 2026) โโโ
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Surelock International Limited interpretation of these two phrases above are as follows:
โโโโ1.โโโโResponsible Persons for all premises within scope of the Terrorism (Protection of Premise) Act 2025 – Martyn’s Law (both Standard Tierย and Enhanced Tier premises) will have from April 3, 2027 (date of commencement) therefore at least before Saturday July 3, 2027 to submit notification and compliance documentation to the SIA.
โโโโ2.โโโ With particular regard of Event Organisers for large scale events attracting more that 800 persons, then already (NOW) if dates of the event have been arranged and being advertised to the public and for the sale of tickets, thenย you should be notifying the SIA about the โโโโโโโโ ย event and working on the protection procedures and measures required to complete the ‘Statement and Threat Assessment Compliance Document’ย
Background info
On July 14 the Home Office – Gov.UK sent the following information – Economic Note (18 pages) on the Terrorism (Protection of Premises) Act 2025 via email: gov.uk.email@notifications.service.gov.ukย that has recently costed a number of matters concerning Martyn’s Law, which is a fascinating read, but the main points we wish to bring to notice are as follows:
Monetised costs over ten years of the SIA for administration costs to responsible persons completing the notification process, build and maintain the online notification portal is ยฃ35.82m.
Estimated number of qualifying premises and qualifying events in each Standard, Enhanced and Events are:
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- Standard โโโโ- Low 124,259โโโโโโโโ- Central 139,530โโโโโโโโโโโ- High 177,515
- Enhancedโโโ – Low โ 17,036โโโโโโโโ – Centralย ย 21,238โโโโโโโโโโโ- Highย ย 29,940
- Eventsโโโโโโ – Lowย ย ย ย ย 780โโโโโโโโ – Centralย ย ย ย 975โโโโโโโโโโโ – Highย ย ย 1,270
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These figures are only estimates and true numbers will only be established once the system is live, as these figures are taken from known UK government records.
The Home Office (Martyn’s Law Team), using similar submissions to UK Companies House, have estimated that the overall time taken for a responsible person to complete the notification process (read and comprehend the notification guidance) and to fill out and submit the form would be between 19 minutes and 48 minutes with a central estimate of 33 minutes. Of course this does not take into account the new and learning required, understanding all relevant information and being able to interpret the requirements needed to comply with this legislation. There are lots of other facts and figures in the Economic Note, but we must state that everything is new and may take years to correctly follow what is necessary to effectively improve the protection of premises and events under this law.
We will be contacting the SIA in the near future, to see if our ideas, identified procedures, processes and provisional documentation is in-line with their perceived requirements, as everyone interested or associated with the Terrorism (Protection of Premises) Act 2025 – Martyn’s Law, as we all are still learning about this new law.
