Martyn's Law And Places Of Worship

A survey of key points to note with regard to Martyn's Law and its application to places of worship.

The Terrorism (Protection of Premises) Act 2025 (the Act) became law on 3 April 2025. It is commonly referred to as Martyn's Law in honour of Martyn Hett, one of the 22 people who lost their lives in the 2017 terrorist attack on Manchester Arena. This article highlights key points to note in relation to the new law and its application to places of worship.

What is the purpose of The Terrorism (Protection of Premises) Act 2025?

The Act aims to improve protective security and organisational preparedness across the UK in relation to the terrorism risks, making those in control of certain premises and events, including places of worship, responsible for reducing the impact of any potential future terrorist attacks.

When will Martyn's Law come into force?

Although the Act was passed in April 2025, the government intends that there will be an implementation period of at least 24 months before its provisions come into force to allow those responsible for premises and events adequate time to understand and prepare for their new obligations under the law.

What are the general requirements under the Act?

The Act provides for a tiered approach (a 'standard tier' and an 'enhanced tier') based on the number of people expected to be present at premises or events at the same time.

In general:

• standard tier requirements will apply to premises with an expected capacity of 200 to 799 individuals; and
• enhanced tier requirements will apply to:
• • premises with an expected capacity of 800 or more individuals, and
  • events in relation to which it is reasonable to expect that 800 or more individuals, including staff and volunteers, may be present at some point during the event and access to the event will be controlled by means of payment, ticketing or membership requirements.

'Expected capacity' in this context means that it is reasonable to expect that from time to time that number of people will be present on the premises at the same time.

Premises to which the standard tier requirements apply will need to have public protection procedures in place, including, specifically, procedures for:

• evacuation (to get people out of the premises)
• invacuation (moving people to a safe place within the premises)
• lockdown (to secure the premises against attackers)
• communication (to alert people to the danger and provide them with instructions)

Where the enhanced tier requirements apply, it will be necessary to have physical public protection measures in place for the relevant premises/event in addition to public protection procedures.

Whichever tier applies, premises or an event falling within the scope of the Act will also need to notify the Security Industry Authority (SIA), the appointed regulator under the Act, of the responsible person(s) for the premises. A responsible person is anyone who has control of the premises for the purpose of the use or event that brings the premises within the scope of the Act.

It is important to note that detailed information on the types of procedure and measure that will need to be put in place to comply with the requirements of the Act is not currently available. Statutory guidance on compliance requirements is to be issued by the government in due course. This guidance will be subject to stakeholder consultation prior to publication.

While premises with a capacity of below 200 are not within the scope of the Act, they are nonetheless encouraged to have preparedness plans in place for the safety of their staff and visitors.

What are the specific provisions in the Act in relation to places of worship?

Places of worship only fall under the standard tier requirements, even if they have an expected capacity of 800 or more individuals.

Accordingly, places of worship with an expected capacity of 200 individuals or above will need to have public protection procedures in place, and to notify the SIA of their responsible person(s), but will not be required to put physical security measures in place.

A 'place of worship' is defined in the Act as premises used for the purpose of:

1. communal worship, or
2. other communal religious practice,

in accordance with the tenets of a particular religion or religious denomination.

At present, the precise scope of this definition is uncertain. It is not clear, for example, whether it extends to encompass halls annexed to the building where communal religious activity takes place. It is hoped that the government's statutory guidance once issued may help clarify these points.

What action should those responsible for places of worship take now?

With guidance on the detailed compliance requirements under the Act yet to be published, the main step that those responsible for places of worship can be taking at this stage to prepare for implementation of the Act is to familiarise themselves with the latest advice, guidance and learning materials on guarding against the terrorism risk.

A useful resource in this regard is the Protect UK website operated by the National Counter Terrorism Security Office (NaCTSO) and the Home Office (https://www.protectuk.police.uk/). This website provides a range of helpful guidance covering not just terrorism, but also other forms of vulnerability to which premises are potentially subject, such as vandalism and theft. The site also offers a 1 hour e-learning course, 'Act Awareness e-Learning' aimed at helping interested parties to increase their security awareness and learn about good practices in countering the risk of terrorism.

Factsheets on a range of topics relating to the Act are also available from the gov.uk website (https://www.gov.uk/government/publications/terrorism-protection-of-premises-act-2025-factsheets).

In addition, premises can be reviewing whether they have an expected capacity that will bring them within the scope of the Act. Useful reference sources in this regard could include any historic attendance data held for the premises, the amount of fixed standing or seating space at the premises and the safe occupancy level specified under any fire safety assessment carried out for the premises.

Given that compliance requirements under the Act are not yet known, one action that bodies such as NaCTSO and Historic England stress definitely should not be taken at this stage is to purchase equipment or services from commercial entities purporting to assist with compliance with the Act.

In coming months, as well as guidance we can expect more information to emerge to help all those in scope of the Act to prepare and, in time, comply. The CEO of the SIA, Michelle Russell (who will have knowledge of the faith sector from her time working at the Charity Commission) recently published an update on what the SIA has been doing to prepare as well as its likely approach to regulating compliance with the Act (https://www.gov.uk/government/news/update-from-michelle-russell-on-martyns-law). The update also links to a helpful myth buster document from the Home Office (https://assets.publishing.service.gov.uk/media/69281f35b3b9afff34e960f0/martyns-law-mythbuster.pdf).

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.