Venue operators entering new leases or event contracts should consider how responsibility for public protection will be managed. Martyn’s Law—the Terrorism (Protection of Premises) Act 2025—creates a statutory framework for certain premises and events, but its operational duties are not yet in force as at 26 October 2026.
The Act received Royal Assent on 3 April 2025. The Home Office has stated that the implementation period will be at least 24 months from that date. Its statutory guidance was published in April 2026 and updated in August. Publication of guidance does not itself commence the operational duties.
Establish whether the premises or event is covered
Attendance is only part of the test. Qualifying premises must also fall within the Act’s definition and specified uses, and must not be excluded. The assessment concerns the number of people reasonably expected to be present at the same time, from time to time, including staff. It is not simply an annual visitor total or a fire-capacity figure.
The standard tier generally covers 200–799 people; enhanced requirements generally begin at 800. There are exceptions, including particular treatment of premises principally used for worship, childcare and certain education purposes.
Events have a separate test. Among other conditions, the event must be open to the public, meet the 800-person threshold and have arrangements checking an entry condition, such as a ticket. It must not take place at premises already covered as enhanced-tier premises. A universal 200-person threshold for events would therefore be misleading.
Responsibility cannot be settled by a label alone
The responsible person is identified by control of the premises for the relevant use or event. A lease describing one party as the “operator” is relevant to the factual arrangements but does not substitute for the statutory test. The responsible person may delegate tasks to a contractor, but cannot transfer the underlying legal responsibility merely by doing so.
Review the division of control between landlord, tenant and event organiser. Contracts should support access to information, cooperation and practical delivery of the relevant procedures.
Prepare proportionately
Standard-tier preparation centres on appropriate, reasonably practicable procedures for evacuation, moving people to a safer place inside, lockdown and communication. Enhanced-tier premises and qualifying events will have additional requirements, including protective measures and documentation.
Operators can use the preparation period to assess their premises, record the reasons for their assessment and consider how staff would carry out the procedures. A purchased training course or compliance package is not, by itself, proof that the legal requirements have been met. Any external advice should address the particular premises and the responsibilities involved.
Contact Balaghi & Rose for advice on the legal and contractual allocation of responsibility, with specialist security input where appropriate.
General information only. This article concerns UK legislation, with a practical focus on premises and events in England and Wales, and reflects the position checked on 26 October 2026. It is not legal advice.
