Martyn’s Law: What commercial property owners and occupiers must know

The quiet progression of a vital piece of public safety legislation became official on 3rd April 2025 with the passing of the Terrorism (Protection of Premises) Act – better known as Martyn’s Law. Its formal enactment represents not only the fulfilment of a government promise, but also the culmination of years of determined campaigning by the family of Martyn Hett, who tragically lost his life in the Manchester Arena bombing of 2017.

While the legal machinery has now been set in motion, commercial property owners and occupiers must begin to take stock. The implications of Martyn’s Law are far-reaching and cut across many different sectors of property use – from entertainment venues and shopping centres to hospitality businesses, schools and medical facilities.

Here, we explore the new statutory duties, the regulatory framework to come, and what practical preparations commercial landlords and tenants alike should begin undertaking to ensure a sound and lawful response.

What is Martyn’s Law and why has it been introduced?

Martyn’s Law introduces a new legal duty on those responsible for qualifying public premises and events to implement proportionate measures to protect the public from the threat of terrorism. The law seeks to move beyond voluntary best practice by creating enforceable obligations to assess and manage the risks posed by potential attacks, in much the same way health and safety or fire risks are already regulated.

The rationale for the legislation is rooted in a series of devastating real-world events, not only the Manchester Arena attack, but other terror incidents in recent UK history that have exposed the vulnerability of crowded spaces and public gatherings. Where past regulatory frameworks fell short by failing to make counter-terror preparedness a clear legal requirement, Martyn’s Law steps in to fill that void. Its arrival therefore marks a cultural and legal shift in how public protection is framed within the commercial property environment.

Who needs to adhere to the Act?

The Act applies to a wide range of premises across the UK, specifically those which the legislation defines as “qualifying premises.” These are typically venues which are accessible to the public and can accommodate 200 or more individuals at any one time.

The requirement applies to entire buildings, and parts of buildings, or even specific units within larger complexes. For example, a restaurant operating inside a stadium or a retail unit within a shopping centre could fall within the scope of the Act independently from the wider premises.

Importantly, the Act also covers large-scale public events, particularly those with more than 800 individuals expected at any one time and where access is controlled, for example through ticketing. These may include concerts, outdoor festivals, or similar occasions that involve a definable “responsible person” overseeing the event.

Some types of premises are excluded, such as those already governed by alternative regulatory regimes. However, many commercial property settings, from leisure and hospitality venues to educational and healthcare facilities, will find themselves included and must plan accordingly.

How will the law be implemented?

Although the Act has now received Royal Assent, its provisions are not yet in force. A 24-month implementation window has been provided, offering owners and occupiers time to assess whether they fall within the scope of the law and, if so, to begin preparing. This grace period is critical. During this time, the government is expected to publish detailed statutory guidance which will help inform the practical measures needed to comply with the law’s requirements.

To support implementation and oversight, a new regulatory body, the Security Industry Authority (SIA), will be empowered to enforce the regime. This includes issuing information requests, applying financial penalties, and even ordering the closure of non-compliant premises or events in the most serious cases.

A tiered system of responsibility

Martyn’s Law adopts a tiered approach, ensuring that the nature and extent of the duty imposed is proportionate to the size and nature of the venue or event.

The “standard tier” refers to premises with a capacity of between 200 and 799 individuals. Here, the focus is on preparedness: putting in place straightforward procedures aimed at protecting the public should an incident occur. These may include basic evacuation or invacuation plans, lockdown protocols, and staff awareness training. Rather than making significant physical changes, the focus is on low-cost, procedural readiness.

Events and venues with a capacity of 800 or more are classified as within the “enhanced tier.” The obligations under this tier are more substantial and may include the installation of security infrastructure such as CCTV, reinforced access points, or hostile vehicle mitigation measures.

Additionally, responsible persons must document the measures taken to reduce risk and provide a security plan to the SIA. This enhanced duty is likely to present more significant financial implications, and with it, greater operational complexity.

Who Bears the Duty? The Role of Landlords and Tenants

One of the crucial questions for those commercial property settings will be: who is considered to be the “responsible person” under Martyn’s Law? This is very important in a landlord tenant relationship.

The legislation places the duty on the person who controls the premises in connection with its qualifying use. In a multi-occupancy setting, this may well be the tenant rather than the landlord, especially where a tenant operates the venue or event in question. However, in more complex arrangements, or where a landlord retains substantial control over the management of common parts, liability may be less clear-cut.

It is therefore essential that landlords and tenants take time to review their lease structures, service charge arrangements, and facilities management responsibilities. In many cases, contractual clarity will be needed to apportion risk and define compliance responsibilities. It might also be sensible to consider making some lease variations or side agreements to ensure that Martyn’s Law obligations are clearly defined.

What should owners and occupiers do now?

Whilst there is two-year implementation window, the time to take action is now. Identifying whether premises or events falls within the scope of the Act requires an immediate review of capacity, use, and access arrangements. Commercial landlords will need to audit their portfolios to determine where duties may arise, not only for their own operational premises, but also where tenants may be affected.

Tenants, in turn, should begin engaging with landlords to clarify who will take responsibility for what. Where uncertainty exists, legal advice should be sought to ensure the drafting of leases and management contracts does not leave parties inadvertently exposed to enforcement risk.

From a practical standpoint, both parties should begin to develop and test appropriate safety procedures, train staff accordingly, and review physical infrastructure to ensure that any enhancements, particularly for those in the enhanced tier, can be planned, funded, and implemented in a measured way.

Proactive collaboration

Martyn’s Law signals a new statutory commitment to public safety — one that will touch nearly every corner of the commercial property sector. While the challenges of compliance should not be underestimated, especially in cost-sensitive environments, this moment also presents an opportunity for landlords, tenants and their professional advisers to work collaboratively to establish clear, effective protocols that safeguard the public and satisfy the law.

At Newmanor Law, we understand the intricacies of commercial property ownership and occupation. Our team is on hand to help clients navigate the practical and legal questions that Martyn’s Law raises – from revisiting lease agreements to structuring compliance frameworks that work in practice as well as in principle.

As the statutory guidance emerges, and as regulatory expectations become clearer, our aim is to support property stakeholders in making smart, proportionate decisions that stand the test of scrutiny and time.