Griffiths & Armour has updated its Terrorism Risk Management guidance following the passing of The Terrorism (Protection of Premises) Act 2025, otherwise known as Martyn’s Law. The guidance and risk assessment template have also been updated to incorporate detail provided in Pool Re’s Terrorism Threat by Sector.
Martyn’s Law has been introduced to strengthen the security of public premises and events, largely as a consequence of the Manchester Arena attack in 2017. Whilst the Act received Royal Assent on 3rd April 2025, the Government has specified a minimum 24-month implementation period before the legislation comes into force. It is recommended that organisations prepare to comply with the Act’s provisions before the implementation date.
Scope:
The legislation applies to a wide range of premises or events with at least one building (or premises within a building). The legislation applies where the minimum number of attendees anticipated exceeds 200 people, referred to as ‘standard duty premises’. Additional duties apply where more than 800 people are anticipated to attend, which are referred to as ‘enhanced duty premises’.
An event falls under the scope of the Act where the public: have paid to attend and have tickets or passes allowing access; or are members or guests of a club or association. In these instances, there must be security measures in place to enforce those requirements. Further clarification of this will be provided.
Responsible Person:
The Act specifies the role of the ‘responsible person’ in relation to both qualifying premises and events, and details their responsibilities. In all instances, the responsible person is required to ensure that, as far as is reasonably practicable, ‘public protection procedures’ must be in place. These procedures are defined as:
- Evacuation of the premises or event.
- Moving people to a safe place.
- Preventing individuals from entering or leaving the premises or event.
- Provision of information to attendees.
The responsible person must also notify the Security Industry Authority of their premises. In respect of ‘enhanced duty premises’ or events, the ‘public protection procedures’ are extended to include:
- Monitoring of the premises or event and the immediate vicinity.
- Managing the movement of individuals into, out of and within the premises or event.
- The physical safety and security of the premises or the event.
- Security of the information in relation to the premises or event.
The responsible person is required to document these procedures and state how they will reduce vulnerability and risk.
Regulator:
The Security Industry Authority (SIA) has been established as the regulator of the legislation. The SIA must produce guidance and advice to achieve compliance with the legislative requirements. This is not currently available and further advices will be provided in due co
The SIA will also have the power to:
- Issue a compliance notice, which requires the relevant person to undertake specific actions or to produce evidence of compliance.
- Issue a restriction notice, which can be placed on either a premise or an event, and will state the extent of restriction and the period this applies for, which cannot exceed six months.
The relevant person has the right to appeal against both a compliance notice and a restriction notice within 28 days.
Penalties:
In the event of non-compliance with either a compliance notice or a restriction notice, the SIA can impose a penalty notice on the relevant person for a specified amount. The maximum penalty is £18m or 5% of the organisation’s qualifying worldwide revenue for their most recent complete accounting period. In addition, the SIA may impose a daily penalty for continued non-compliance, up to a maximum of £500 per day for standard duty premises and £50,000 per day for enhanced duty premises or events.
A ‘responsible person’ may also be charged with the offence of failing to comply with a compliance or restriction notice. If found guilty, they may be imprisoned for up to 24 months and/or fined up to the statutory maximum.
For further information on how Griffiths & Armour can help support your organisation, please get in touch.
