On 3 April 2025, the Terrorism (Protection of Premises) Act 2025, widely known as Martyn’s Law, received Royal Assent, heralding a transformative shift in how public safety is managed across UK commercial properties. Named in tribute to Martyn Hett, one of the victims of the 2017 Manchester Arena bombing, this landmark legislation mandates enhanced security measures for public venues and events. Driven by the tireless advocacy of his mother, Figen Murray, Martyn’s Law introduces reforms designed to safeguard the public against terrorist threats. For landlords, property managers and tenants alike, Martyn’s Law introduces significant new responsibilities and opportunities to enhance safety – here’s what you need to know to navigate this landmark change.
1. What’s happening, and why now?
After the heart-breaking Manchester Arena attack in 2017, Martyn Hett’s mother campaigned for stronger legal protections at busy public spaces. Until now, no law required venues to prepare specifically for terrorist incidents — Martyn’s Law addresses this gap. It introduces a new statutory duty requiring those responsible for certain public premises and events to implement measures to mitigate risks and respond to terrorist attacks.
The practical effect of this is that anyone in control of certain places or events — including shopping centres, hotels, stadiums, campuses, hospitals, sports/leisure venues and even some heritage sites — must demonstrate that they have seriously considered how to keep people safe from terrorist attacks.
With Royal Assent secured, the Government has set a minimum 24-month implementation period, likely pushing enforcement into early 2027.
2. Who will Martyn’s Law affect?
The legislation applies to premises and events across England, Wales, Scotland, and Northern Ireland, where the public has access for “qualifying activities,” such as concerts, sporting events, markets, cinemas, shopping centres, schools, hospitals, and places of worship.
It uses a tiered approach based on capacity:
- “Standard Tier” premises (with a capacity for 200–799 people); and
- “Enhanced Tier” premises and events (with a capacity for 800 or more people).
An estimated 250,000 premises fall within scope, making this one of the most far-reaching security laws in recent years – and landlords and tenants in retail, hospitality, and mixed-use developments are particularly affected.
Exclusions apply to open-access areas without ticket restrictions. Purely private offices with no public access (for example, those restricted to employees) are also excluded, unless they host qualifying activities (such as large public events). However, offices where the public has access — such as co-working spaces or business centres — are likely to fall within the scope of the legislation.
3. What are the requirements?
Martyn’s Law adopts a proportionate approach, tailoring obligations to venue size:
- “Standard Tier” premises (200–799 people): There is a requirement to implement “public protection procedures,” such as evacuation, invacuation, lockdown and communication plans. These measures are designed to be low-cost and practical, requiring no physical alterations or the purchase of any equipment.
- “Enhanced Tier” premises and events (800+ people): In addition to the above, stricter requirements apply, including conducting formal risk assessments, notifying the Security Industry Authority (“SIA”) of the event, and implementing proactive “public protection measures” such as CCTV, bag searches and/or vehicle barriers tailored to each property’s risk profile. For some commercial properties, this may require upgrading physical infrastructure.
4. Who is responsible?
Martyn’s Law places duties on the “responsible person,” typically the individual or entity controlling the premises or event — such as a landlord, tenant, property manager, venue operator or event organiser. For example, at a concert in a public park, the event organiser bears responsibility, while in multi-tenanted properties, such as shopping centres, the landlord is likely accountable for common areas, while tenants may bear responsibility for their leased spaces. For multi-let or complex sites, this may involve co-ordination between landlords, tenant and managing agents — a clear delineation of responsibilities in leases will be critical to avoid disputes.
5. Enforcement and consequences
The SIA will oversee compliance, with powers to inspect premises and issue civil sanctions or, in serious cases, pursue criminal penalties. Non-compliance could result in fines up to £18 million or 5% of worldwide revenue for Enhanced Tier premises or qualifying events, reflecting the Government’s commitment to robust enforcement.
6. Practical steps: how should you prepare?
With enforcement looming in early 2027, it is advisable to act now:
(a) Assess scope: Start by assessing whether your premises fall into Standard or Enhanced Tiers based on capacity and use;
(b) Conduct risk assessments: Conduct a terrorism risk assessment to identify vulnerabilities;
(c) Update emergency plans: Develop or refine evacuation, lockdown, and communication protocols;
(d) Invest in infrastructure: For Enhanced Tier premises, conduct a thorough risk assessment, and consider proactive measures such as CCTV and access controls as appropriate; and
(e) Communicate: Initiate discussions between landlords, tenants, managing agents and service providers to prepare for compliance, and keep abreast of forthcoming Government guidance.
7. Understanding the implications
Martyn’s Law represents a fundamental shift for commercial real estate, embedding security into the fabric of property ownership and management. Beyond compliance, it offers a chance to enhance asset appeal — tenants and visitors increasingly prioritise safety, and secure premises can command premium rents and higher footfall. Thoughtfully implemented, Martyn’s Law could redefine industry standards, positioning safety as both a compliance necessity and a competitive advantage.
However, challenges loom: smaller property owners and occupiers may face resource constraints, multi-tenanted properties risk disputes over shared responsibilities, and the SIA faces a monumental task in regulating over 250,000 premises. The tiered approach mitigates some concerns, but forthcoming SIA guidance will be pivotal in clarifying what constitutes “reasonably practicable” measures.
Martyn’s Law, born from tragedy and driven by Figen Murray’s resolve, is a testament to the power of advocacy. The law’s passing marks not only a legal milestone, but also sets a new standard for how the sector approaches the protection of people and places.
If you wish to discuss any of the issues raised in this article, please reach out to your usual Linklaters contact.