Here is my take (writes Stewart Brown, Senior Security Consultant at Surelock International) on Martyn’s Law, officially known as the Terrorism (Protection of Premises) Act 2025, which received Royal Assent on Thursday, April 3.
Requirements
This new Act of Parliament is the first piece of UK legislation that puts the onus on businesses, companies and owners of premises to actually consider the ‘vulnerability of premises or event……from, acts of terrorism’ not security, although police, victims, HM Government, local authorities, other official bodies, corporate enterprises and individuals may quote Martyn’s Law when in the future, inadequate protection of premises and events is seen to be a contributing factor to crime, violence or incidents occurring at the premises.
The act is approximately 46 pages long, 17,479 words with three (3) parts being: (Part 1 – Public Protection Requirements), (Part 2 – Licensing: Disclosure of Plans of Premises) and (Part 3 – General). There are four (4) Schedules comprising of: (Schedule 1 – Specified Uses of Premises). (Schedule 2 – Excluded Premises and Events), (Schedule 3 – Investigatory Powers) and (Schedule 4 – Licensing: Disclosure of Plans of Premises)
Premises or Events that have more than 200 ‘visiting members of the public’ and ‘it is reasonable to expect that from time to time 200 or more individuals may be present on the premises at the same time’ in or at the venue will be the ‘Standard Duty Requirement’ or ‘Standard Tier’ which will be expected to have at least four (4) types of ‘Public Protection Procedures’ being detailed as:
Evacuation: the process of getting people safely out of the premises
Invacuation: the process of bringing people safely into, or to safer parts of the premises
Lockdown: the process of securing the premises to prevent individuals entering or leaving the premises, e.g. to restrict or prevent entry by an attacker by locking doors, closing shutters or using available barriers
Communication: the process of alerting people on the premises to the danger, e.g. providing instructions to remain in place or move away from any danger
There is expected to be ‘supporting activity’ also considered but the standard duty premises / standard tier is to focus on simple low-cost activities surrounding policies and procedures with no requirement to put in place physical measures in this tier.
The wording ‘Reasonably practicable’ is used often and a concept found in other regimes, such as Fire Safety, and Health and Safety.
Premises or Events that have more than 800 in or at a venue will be the ‘Enhanced Duty Requirement’ or ‘Enhanced Tier’ which are expected to have the following ‘Public Protection Procedures and Measures’:
Notification: A responsible person must notify the Security Industry Authority (SIA) when they become responsible for the premises or event.
Designate a Senior Individual: Where the responsible person is not an individual they must designate a senior individual, who has responsibility for managing the affairs of the relevant body as a whole and complies with the relevant legislative requirements.
Evacuation: the process of getting people safely out of the premises
Invacuation: the process of bringing people safely into, or to safer parts of the premises
Lockdown: the process of securing the premises to prevent individuals entering or leaving the premises, e.g. to restrict or prevent entry by an attacker by locking doors, closing shutters or using available barriers
Communication: the process of alerting people on the premises to the danger, e.g. providing instructions to remain in place or move away from any danger
Measures in relation to monitoring the premises or event and their immediate vicinity
Measures in relation to controlling the movement of individuals into, out of and within the premises or event
Measures in relation to the physical safety and security of the premises or event
Measures in relation to the security of information
Developing and implementing plans for public protection procedures and ensuring that they are routinely rehearsed
Ensuring that induction and probation periods for new staff include awareness training packages for all those working at the premises or event relating to safety, security and counter-terrorism
Developing policies for perimeter and entry checks as well as queue management and ticket checks
Using internal radio systems and mobiles for communication between relevant individuals working at the premises or event
Introducing interim tabletop activities and walk-through scenarios that are designed and led by designated individuals
Employing a mixture of salaried and contracted door staff to sufficiently protect ingress and egress areas
Developing policies for suspicious or restricted items including bag checks and storage
Having effective CCTV with an adequately staffed monitoring and control room
Documenting compliance, the person responsible must record in a tailored document the public protection procedures and the reasoning as to how those public protection procedures and measures reduce the vulnerabilities and/or risk of harm, were a terrorist attack to occur.
The above list is non-exhaustive and subject to change over time.
Purpose of the Act – official statement
“An Act to require persons with control of certain premises or events to take steps to reduce the vulnerability of the premises or event to, and the risk of physical harm to individuals arising from, acts of terrorism; to confer related functions on the Security Industry Authority; to limit the disclosure of information about licensed premises that is likely to be useful to a person committing or preparing an act of terrorism; and for connected purposes.”
Security Industry Authority (SIA)
The SIA will be the regulator, investigator and have an enforcement role to exercise compliance as well as preparing and providing guidance under this act and has 24 months, therefore until April 2027 to assist and advise premises and businesses, but as yet there has been no action or involvement with the UK Security Industry, from them and only the organisations ProtectUK and the Home Office through GOV.UK has provided any information to the industry.
About Surelock International
Surelock International Limited is an independent UK Security Consultancy that can provide relevant involvement, up to date information, guidance and advice on how clients, small/large businesses, local authorities, other properties/premises and corporate enterprises in how to deal with the requirements under this legislation. Visit www.surelock.org.
For part two of Stewart Brown’s digest, visit https://professionalsecurity.co.uk/news/commercial-security/martyns-law-view-part-two/.
