Home / Martyn’s Law – What does the Terrorism (Protection of Premises) Act 2025 mean for landlords?
21st October 2025
Stacey Rees, Associate
The Terrorism (Protection of Premises) Act 2025, more commonly known as Martyn’s Law (and named after Martyn Hett who tragically lost his life in the Manchester Arena bombing of 2017) was given Royal Assent earlier this year.
Martyn’s Law requires people with control of certain (qualifying) premises or events to be prepared and ready to keep the public safe in the event of a terrorist attack. The Act separates these qualifying premises into two categories; those in the ‘Standard Tier’ (with a capacity of between 200 and 799 people) and those in the ‘Enhanced Tier’ for venues with a capacity of 800+. The requirements placed on those two tiers differ, with a greater level of planning and preparedness required for the Enhanced Tier, as you might expect.
Given the origins of the Act, there has been a natural focus on how this new piece of legislation will impact hospitality operators, but it doesn’t just apply to licensed premises. Any premises that falls within the ‘scope’ of the Act is affected.
Food, drink, and entertainment spaces are, of course, captured in that definition. However, so are sports grounds, libraries, museums, shops, visitor attractions, schools and places of worship – Schedule 1 of the Act contains the full list of ‘in scope’ premises.
Regardless of the type of premises though, the obligation to comply with the requirements of the Act falls on the ‘Responsible Person.’ The ‘responsible person’ is who ‘whoever has control of the premises (in connection with its relevant Schedule 1 use).
The ‘responsible person’ may be an individual, but the Act anticipates that it will typically be a company or other (similar) organisation and that a company can be named as the ‘responsible person’ for more than one premises. An example given in the recently published ‘Myth Buster’ document from the Home Office says that a company operating 50 qualifying (Standard Tier) premises can be the responsible person for all of them.
For Enhanced Tier premises, whilst a company can be listed as the ‘responsible person’ there must also be a named (senior) individual appointed to the role to ensure that the company complies with the requirements of the Act. In most instances, the identity of the ‘responsible person’ will be obvious; the person who runs the restaurant or manages a cinema, for example, or a company that operates a chain of bars.
However, they may not always be so easy to identify. This article looks at a couple of circumstances where things are less clear.
An event space with a capacity of more than 200 would fall within ‘scope’ of the Act, but would the owner of the hall be considered the ‘responsible person’ or would it be the hirer who wanted to host an event within it? The answer, we believe (based on the information we have at the moment) is that it will be the owner or operator of the hall, and not the person hiring it. However, consideration should be given when drafting and issuing Terms & Conditions to hirers of these sorts of premises to make express provision within them to ensure that the hirer takes steps to ensure compliance with the safety measures that have been put in place to comply with the requirements of Martyn’s Law. However, responsibility under the Act does not pass to the hirer.
Things are likely to be less clear when it comes to public realm spaces or common parts, for example within shopping centres. The responsibility for implementing the requirements of the Act may fall to one or more ‘persons’ and so who will be deemed the ‘responsible person’ may be quite difficult to determine. Landlords and tenants will need to consider their respective obligations and leases may need to include Martyn’s Law provisions.
The Security Industry Association (the SIA) have been appointed as the ‘Regulator’ and whilst their remit is one of support, advice and guidance to ensure compliance they have been given significant powers to fine and prosecute where required. It’s therefore important that conversations are had now between parties to discuss the provisions of the Act to avoid problems further down the line.
The Government has yet to publish its Guidance which will accompany the Act and which will provide much needed detail around its provisions. It’s not now expected until the Spring. Until it is, it’s hard to advise accurately those businesses and venues who will need to comply with its requirements. Whilst we wait, premises can begin to prepare by using the free resources provided on the ProtectUK website – www.protectuk.police.uk – or by speaking with one of the solicitors at Kuits on +44 (0)161 832 3434