Martyn's Law: what sport and venue operators should do now

Martyn's Law will affect many publicly accessible premises and events. Our new guide uses football to explain the questions organisations should address now, from calculating attendance and identifying responsibility to preparing proportionately.

The Terrorism (Protection of Premises) Act 2025, commonly known as Martyn's Law, will require certain publicly accessible premises and events to have appropriate procedures in place to reduce the risk of physical harm if a terrorist attack occurs. The Security Industry Authority (SIA) will regulate the regime, which is expected to come into force in Spring 2027.

Martyn's Law in Football: The implications for non-league clubs, co-authored by TLT licensing specialists Piers Warne and Rebecca Lowe, brings together legal guidance with Football Pyramid Partnership's understanding of the operational realities of non-league football, to examine what the legislation will mean in practice for professional and semi-professional clubs.  

The issues extend well beyond football.  Hospitality and leisure venues, entertainment spaces, festivals, visitor attractions, sports organisations, retailers and other operators of publicly accessible premises may face similar questions about numbers, control of premises and shared responsibilities.  

Organisations should use the time now to understand whether they are in scope, identify ownership and dependencies, gather evidence and review current arrangements. Waiting for commencement or sector-specific guidance could leave little time to resolve issues involving multiple sites, shared premises or third parties.

Is your organisation in scope?  

The key thresholds are based on how many people can reasonably be expected to be present at the same time, from time to time: 

• 200 to 799 people: standard tier 
• 800 or more people: enhanced tier 

The count is not limited to customers, spectators, or ticket holders. At a football ground, it can include players, officials, directors, stewards, employees, volunteers, and catering teams. Predictable peaks, such as derbies or play-offs, may also affect the assessment even where average attendance is lower. 

The same issue can arise wherever numbers change by event, season, or use. Average attendance or licensed capacity will not necessarily provide the answer. Organisations need evidence of who can reasonably be expected to be on site, and a clear understanding of how the premises operate in practice.

Who is responsible for compliance?

The ‘responsible person’ is the individual or organisation that controls the premises for its relevant use or controls a qualifying event. The position may be more complex where premises are leased, spaces are separately operated, or landlords, tenants and event operators share control. 

Where more than one party has the necessary level of control, they may need to act jointly. Other parties may also have duties to co-operate. Legal, operational, property, safety, and governance teams may therefore need to work together, particularly across shared or multi-use sites. 

What should organisations do now? 

Standard-tier premises will need appropriate public protection procedures. Enhanced-tier premises and qualifying events will have additional requirements relating to public protection measures. In each case, arrangements must be reasonably practicable and proportionate to the circumstances. 

1. Understand what is in scope: Map the premises and events that could qualify, including separately operated spaces.
2. Get the numbers right: Look at everyone reasonably expected to be present and predictable peaks, rather than relying on average attendance or capacity.
3. Clarify responsibility: Establish who controls the premises or event and where landlords, tenants, operators or other parties may need to co-operate.
4. Test your readiness: Review existing procedures, evidence and governance so you know where further work may be required.

These questions can become more complicated in practice, particularly where sites have multiple uses, responsibilities are shared or attendance fluctuates. Our guide explores how they play out in a real operating environment, using professional and non-league football as the case study.

Download the guide

Martyn’s Law in Football: The implications for non-league clubs is published by Football Pyramid Partnership in association with TLT and Stadium Link. It explains the legal framework and uses professional and non-league football to explore attendance, tiering, responsible persons, shared arrangements and practical readiness – offering valuable information for organisations across a range of sectors. 

How TLT can help

With extensive experience advising organisations across hospitality, leisure, sport, entertainment and the wider public sector, TLT is supporting clients on the application and practical implementation of Martyn's Law, including:

• determining whether premises or events fall within scope;
• identifying the responsible person and duties to co-operate;
• determining whether standard or enhanced-tier requirements apply;
• reviewing existing procedures, policies and governance arrangements;
• supporting the notification process;
• reviewing compliance documents, policies and procedures; and
• preparing for implementation in a proportionate and practical way.

Starting preparations early can help organisations understand their obligations, identify any gaps in existing arrangements and avoid last-minute implementation challenges.

Contact Piers Warne or Rebecca Lowe to discuss how Martyn’s Law may affect your premises, events or operating arrangements. 

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at October 2026. Specific advice should be sought for specific cases. For more information see our terms & conditions.