Preparing for Martyn’s Law: understanding the SIA’s regulatory approach

The Charity Commission (the Commission) has recently held a training session in partnership with the Security Industry Authority (SIA) to prepare faith-based charities and churches for the implementation of the Terrorism (Protection of Premises) Act 2025 (the Act), otherwise known as Martyn’s Law. 

The Act requires certain public premises and events to be prepared and ready to protect people in the event of a terrorist attack. Whilst the Act is expected to come into force in Spring 2027, the Commission and SIA are urging trustees to begin preparing now.

There are two tiers within the scope of the Act: Standard and Enhanced. The standard tier applies where it is reasonable to expect that between 200 and 799 people will be present at the premises at the same time, from time to time. The enhanced tier generally applies where it is reasonable to expect 800 or more individuals to be present.

However, places of worship are given special consideration under the Act, which means they will sit within the standard tier even if their attendance numbers reach 800 or more. They are, however, also included in the standard tier if attendance at seasonal or occasional events can reasonably be expected to exceed 200 people, even if they do not meet the requirements weekly (i.e. for the weekly services).

The Act means that where it is reasonable to expect 200 or more people to be present at the same time, practical proportionate steps should be taken to reduce the risk of harm. The four main public protection procedures that organisations need to consider are: Evacuation, Invacuation, Lockdown and Communication. When deciding what procedures are required, organisations should consider what is appropriate for their premises and what is reasonably practicable in the circumstances.

Each venue or event covered by the Act will have a ‘responsible person’ who is responsible for ensuring compliance with its requirements, so far as reasonably practicable. Organisations must provide the SIA with the responsible person’s details and the address of the relevant property or premises.

The SIA indicates it will be proportionate, supportive and robust in its approach to regulation, always seeking to advise before enforcing non-compliance. The SIA will assess compliance through assessments and on-site inspections using a risk-based approach. If the SIA finds that an organisation has not taken reasonable steps to comply with the Act (considering the circumstances of the premises/event), then it has three enforcement powers, being: a compliance notice, a penalty notice and a restriction notice. The restriction notice only applies to those in the enhanced tier. 

Importantly, for most churches and faith-based charities, the standard-tier requirements are intended to be simple and proportionate. The focus is on having appropriate procedures for responding to an attack, rather than investing in expensive physical security measures. Trustees should nevertheless begin considering who would take decisions in an emergency and how evacuation, invacuation, lockdown and communication procedures would operate in practice.

The Commission and SIA suggest trustees keep up to date with the guidance and implementation and use the resources, guidance and tools on Protect UK: 

• Understanding Martyn's Law and the SIA's role as regulator
• Martyn's Law frequently asked questions

If you require any governance advice, please get in touch.