Regulatory Update for Property Professionals. Martyn’s Law – Terrorism (Protection of Premises) Act 2025

Introduction

On the 3rd April 2025, Parliament passed the Terrorism (Protection of Premises) Act 2025.

The new Act was as a direct response to the bombing of the Manchester Arena on the 22 May 2017. The Act, previously known as Martyn’s Law, is designed to ensure that those who are in control of certain premises or events take steps to reduce the vulnerability of the premises (or outdoor event) and the risk of physical harm to individuals arising from acts of terrorism.

The Act applies across the whole of the UK and impacts a significant number of different types of buildings.

Requirements

The new Act will require responsible persons {persons who have control of a qualifying premises – known as standard duty premises) will be subjected to various duties including:

• Registering and notifying the Security Industry Authority (who are to act as a Regulator) that their building is a qualifying premises.
• Undertaking an evaluation and assessment of risk relating to terrorism and security.
• The development and implementation of public protection procedures, covering evacuation, invacuation, lockdown and communication as a
• The provision of training and undertaking of exercises with staff.
• Coordinating and cooperating with other responsible persons where there is more than one person in control of the premises.

Qualifying premises and uses

Premises deemed to be a Qualifying Premises are outlined below, but the Act only applies where it is reasonable to expect that from time to time 200 or more individuals may be present on the premises.

In addition, there are a set of “enhanced duties” where it is reasonable to expect that from time to time 800 or more individuals may be present within a qualifying premises or a qualifying event. These duties include appointing and designating a Senior Individual, and developing Enhanced Public Protection Procedures over and above those for standard duty premises, as well as producing a document justifying and outlining compliance arrangements.

Those identified within the Act as Qualifying Premises include those used as:

• Shops
• The sale of food and drink
• Entertainment and leisure activities
• Sports grounds
• Libraries, museums and galleries,
• Halls (such as venues for hire for events or activities)
• Exhibition halls and conference centres
• Visitor attractions
• Hotels (including hostels and holiday parks)
• Places of worship
• Health care
• Transport hubs (bus stations, railway stations )
• Aerodromes and airports
• Childcare facilities (depending upon where in the UK the facility is located)
• Education facilities {primary and secondary schools, further education colleges and universities – depending upon where in the UK the facility is located)
• Public buildings – excluding parliamentary

Generally, these will only be applicable where the use, space, display, or service provided is principally to-or for-the benefit of visiting members of the public (whether for payment or not).

Parliamentary buildings, as well as parks and gardens (including recreation grounds, non-designated sports grounds and or open-air premises used for recreation or leisure), where visitors are not required to pay for entry, hold a ticket for entry or be a member of a particular club or association, are excluded from the requirements of the Act.

The effect of the legislation is wide ranging especially for property professionals.

Shops and shopping centres will be considered as qualifying premises if they are capable of holding more than 200 people, that’s anything between 140m2 and 1,400m2 in size depending upon what type of store. Where they are capable of holding 800 persons (anywhere between approximately 560 and 5,600m2 in size for example), then the enhanced duties will apply.

Even residential lounges and multi-use games areas within residential blocks could fall into the current definition, especially if they are hired out for events that allow visitors to attend and/or if they are capable of capable of holding 200 or more people – that’s approximately 100m2 in size.

Where a qualifying premises forms part of other qualifying premises, a shop for example within a shopping centre, then those two or more premises are to be treated as one qualifying premises, although each person in control of the premises will be required to meet the standard duties, and they are required to cooperate and coordinate with each other.

Notification to the Security Industry Authority will be the subject of secondary legislation to be issued by the Secretary of State which will also consider what type and form of information shall be provided.

Conclusion

In conclusion, the Terrorism (Protection of Premises) Act 2025, commonly known as Martyn’s Law, represents a significant shift in the legal responsibilities of those managing qualifying buildings, public spaces and events across the UK. By mandating risk assessments, security procedures, staff training, and coordination among responsible persons, the Act aims to enhance public safety and reduce the risk of harm from terrorist acts.

Its broad scope impacts a wide range of premises, from shops and entertainment venues to transport hubs and healthcare facilities, with additional obligations for larger venues and events. As secondary legislation is introduced, further clarity will emerge on the specific requirements for compliance, reinforcing the need for proactive security planning in public spaces.