Terrorism (Protection of Premises) Act 2025: an overview of the standard and enhanced duties

On 3 April 2025, the Terrorism (Protection of Premises) Act 2025, also known as “Martyn’s Law” received Royal Assent.

Martyn’s Law is intended to improve protective and organisational preparedness across the UK by requiring (i) those responsible for certain premises and events to consider how they would respond to a terrorist attack (“standard duty”), and (ii) for certain larger premises and events to take appropriate steps to consider appropriate  measures to reduce vulnerability (“enhanced duty”).

In broad terms, the standard duty applies to premises or events, where it is reasonable to expect at least 200 people, whilst the enhanced duty will apply where more than 800 people are expected. Amongst the premises and events covered, are shops, restaurants, museums, sports grounds, concerts, hotels, places of worship, transport hubs, schools/ colleges, and hospitals. There are certain exceptions, for example, parks and gardens which have free and open access.

Guidance as regards compliance is yet to be published and there is an intention for an implementation period of at least 24 months before the Act comes into force. Amongst other reasons, this is to allow those responsible for premises and events to have sufficient time to understand their obligations, plan and prepare appropriately. The Act includes provision for penalties and restriction notices for non-compliance, the maximum monetary penalty being set at £18m, and offences which could result in imprisonment.

Looking at a specific example, a hotel (for instance, a large hotel which could expect to accommodate more than 800 guests), is covered by the Act, because it is a qualifying premises, and would be subject to the enhanced duty.  A person, designated by the hotel, would be responsible for:

(i) Standard duty

Ensuring that appropriate public protection procedures are in place in order to reduce the risk of physical harm being caused to individuals if an act of terrorism were to occur at or in the vicinity of the hotel.

Public protection procedures include, (i) evacuation, (ii) invacuation, (iii) prevent entering/leaving the premises  and (iv) provision of information (see paragraph 5(3) of the Act).

It can be envisaged that complex and fluid procedures and training will be required to ensure compliance, for example, where and when to evacuate, if at all, bearing in mind the procedures include evacuation and preventing leaving the premises.

(ii) Enhanced duty

Assessing and keeping under review public protection measures, to reduce the vulnerability of the hotel to acts of terrorism, and/or reduce the impact of such act of terrorism.

Public protection measures include, (i) monitoring the premises and its immediate vicinity, (ii) the movement of individuals, (iii) physical safety and security, and (iv) the security of information relating to the hotel.

One may reasonably expect this to include, in the context of a hotel, CCTV and other surveillance, and various resident security measures, for example, mag lock doors. The Guidance, when published will likely provide detail.

The Act covers most reasonably sized premises, and it is anticipated will require significant time and investment as steps are taken to comply with it (and ensure continued compliance with it).