The private security industry is becoming increasingly uneasy about the lack of detail forthcoming about Martyn’s Law, necessary for the managers of premises in the hundreds of thousands that will have to comply with the Terrorism (Protection of Premises) Act.
To recap briefly, the Act was given Royal Assent in April 2025; that sets a legal requirement on premises, typically pubs and night clubs, theatres and venues, shopping centres and hospitals, to take steps to counter the threat of terrorism. However, how to go about complying with the law (and to satisfy insurers) requires more detail from the Home Office; and the regulator and inspector as set in the Act, the Security Industry Authority (SIA).
The UK official Protect UK website has at most infographics outlining whether you’re ‘in scope’ of the Act; or short ‘top tips‘ documents. The authorities have been at pains to not set themselves any deadline for when anything will appear. As for when the Act will come into force; lately the authorities have been stating that it will take ‘at least’ 24 months from Royal Assent.
The February and March editions of Professional Security Magazine feature updates on counter-terrorism.
As featured in the February edition of Professional Security Magazine, Stewart Brown, senior security consultant at Surelock International, has produced a ‘Procedures advice document’ for potential clients, contacts, associates and anyone interested in the Act.
Stewart writes further:
Although there may be a lot of behind the scenes work being done by various civil service personnel, it appears their communication with the UK population, UK security industry and owners/operators of premises captured by Martyn’s Law seems to be lacking and will make things difficult for any premises to comply fully on the date of April 3, 2027 as required by the Act.
The delay in issuing this very important guidance until summer 2026 will only leave approximately six or seven months for owners/operators to understand properly the full requirements on the Act and work out how to comply effectively and correctly with Martyn’s Law.
It is apparent that the Security Industry Authority (SIA) has or is progressing at pace in their responsibilities to this Act, but even their Section 12 guidance (for understanding and enforcement) of the Act will not be issued until after the Statutory Guidance is published.
The knowledge and interpretation of Martyn’s Law for owners/operators is the most important aspect of the Act as they are (to be seen) as the ‘person responsible’ and legally required for its compliance. All other aspects of the Terrorism (Protection of Premises) Act 2025 are secondary to the legal requirements of the ‘person responsible’ at the relevant premises.
Also planning for any large events/gatherings (that falls under the Act) expected to take place after 03.04.27, usually is done months, if not years in advance of the actual event. Seven months is not sufficient time to work out how to comply with this law, which will over the next few years, probably affect over 90pc of the entire UK population in one way or another.
This law, has already been stated as enhancing, improving security aspects at certain premises and potentially saving lives, after learning from terrorist and serious criminal activity in the past and in the future will be seen as a standard bearer of effective security practices at premises where a large number of the public have access.
The UK Parliament and the security industry has to get this new law correct for the safety of all and therefore the instigation, process and implementation should be paramount in everybody’s mind. The writing of the Act seemed to focus on regulation and enforcement rather than how to protect premises effectively for the safety of the public.
There has been some related references to having a Competent Person In the Workplace (CPIW) and a Counter Terror Security Specialist (CTSS) by the Home Office sponsored organisation ‘Skills 4 Justice’, but the act does not mention those and it seems some official or not so official bodies have interpreted these as part of Martyn’s Law with no legal substance behind them. Of course, both these positions may in the future be required, there is no current status or requirements to have them in place.
We are all learning this new legislation as it stands and will be all guided by what is presented in the legal Statutory Guidance, giving another reason that it is urgently required. With the limited time available, it is estimated that owners/operators of premises and events will need to do the following things to effectively comply with Martyn’s Law:
- Read and fully understand the Section 27 Statutory Guidance information, that relates to their premises/event
- Identify the ‘Person Responsible’ under the Act and register that named person with the SIA
- Review all aspects of Martyn’s Law that relates to the Standard Duty (Tier) Procedures or Enhanced Duty (Tier) Procedures and Measures at the premises/event
- Have in place actions and procedures/measures that reduce the vulnerability of the premises or events to the acts of terrorism
- Have in place actions and procedures/measure that reduce the risk of physical harm being caused to individuals if an act of terrorism were to occur on the premises, at the event or in the immediate vicinity or the premises or event
- Standard Duty premises/events (presumably) have the procedures documented or identified to the satisfaction of the SIA
- Enhanced Duty premises/events to have all up to date procedures and measures documented and provide a copy to the SIA for approval of compliance of the Act
- Any changes, adaptions, enhancements or improvements to the premises/events will need to be provided in writing to the SIA for approval
- Understand the legal ramifications for non compliance of this Act
Proper consideration of each of the above points will take time, effort, experience and knowledge, as well as detailed communication with the authorities (SIA) to be legally compliant on this matter.
