Martyn's Law for venues: does the 200-person rule catch your space?

Published · 18 min read

Martyn's Law applies to a venue only if it is reasonable to expect 200 or more people, staff included, to be there at the same time from time to time; if your realistic peak, counting your own team, caterers and band, is 199 or fewer, the Act does not apply to your premises.

Martyn's Law is the Terrorism (Protection of Premises) Act 2025. To be in scope, your premises must also be a building that is wholly or mainly used for a listed use, such as a venue for hire, pub, restaurant or hotel.

From 200 to 799 people you are in the standard tier. You will have to tell the Security Industry Authority (SIA) who is responsible and have simple emergency procedures. The Act does not require building works or new equipment for this. At 800 or more you are in the enhanced tier, which asks for much more. None of these duties is in force yet. As of 26 October 2026 no start date has been set, and the SIA expects the Act to come into force in spring 2027.

This guide covers the whole UK: the venue duties apply in all four nations, with the SIA as regulator.

What does Martyn's Law ask at each size?

People reasonably expected at once, staff includedTierWhat you must doMaximum penalty
199 or fewerOut of scopeNothing under the ActNone
200 to 799Standard tierNotify the SIA; have public protection procedures£10,000, plus up to £500 a day while you ignore a compliance notice
800 or moreEnhanced tierThe above, plus protective measures, a document sent to the SIA and, for organisations, a named senior individual£18 million or 5% of qualifying worldwide revenue, whichever is greater, plus up to £50,000 a day while you ignore a notice

Places of worship, childcare settings and schools and colleges (except universities) stay in the standard tier even at 800 or more (statutory guidance paras 4.36 to 4.38).

When does Martyn's Law come into force?

The Act received Royal Assent on 3 April 2025. The Home Office says the implementation period is "at least 24 months" from that date (statutory guidance, para 2.10). The SIA's own page, published 17 July 2026, says the Act is expected to come into force in spring 2027 and that the SIA will confirm the exact date in advance.

The start date has to be set by commencement regulations (s.37(2)). Two sets have been made so far, and neither starts any duty for venues:

DateWhat happened
3 April 2025Royal Assent
10 April 2026Section 27 (Home Office guidance) in force, by SI 2026/320
15 April 2026Home Office statutory guidance published; SIA consultation on its own guidance opened (closed 12 June 2026)
15 June 2026SIA duties on guidance and advice (s.12(2)(a), (b) and (3)) and its revenue statement (s.18(5) to (7)) in force, by SI 2026/622
9 July 2026Notification Requirements Regulations made (SI 2026/793); they start when the duty to notify starts
15 October 2026Principal Use of Premises Regulations in force (SI 2026/1005)
From early 2027SIA invites volunteers to test its notification portal
Spring 2027 (expected)Duties for venues expected to start; exact date still to be set

Is your space in scope? The four tests

Section 2(2) of the Act sets four tests. Your premises are "qualifying premises" only if all four are met.

  1. There is a building. The premises must be a building, or a building and other land. "Building" includes part of a building or a group of buildings, of any size or material (guidance para 4.7). Land used with it counts too, such as a beer garden or hotel grounds (para 4.11). A field with no building is not qualifying premises, though a large ticketed event there can be a "qualifying event" (see the 800 section).
  2. It is wholly or mainly used for a Schedule 1 use. The uses most relevant to venue owners are food and drink for consumption on the premises by visiting members of the public (para 2), entertainment and leisure (para 3), "a venue for hire for events or activities", exhibition hall or conference centre (para 6), visitor attractions (para 7), hotels, hostels and holiday parks (para 8) and places of worship (para 9).
  3. 200 or more people can reasonably be expected at the same time, from time to time, in connection with those uses. For most small venues this is the deciding test (see how to count, below).
  4. It is not excluded by Schedule 2. The key exclusion here covers parks, gardens, recreation grounds and other open-air premises used for recreation or leisure, but only where there are no checks on entry such as payment, tickets or membership (Schedule 2, para 3).

"Wholly or mainly" is judged on all the circumstances, especially time. The guidance compares how long the premises are used for Schedule 1 uses with how long they are used for anything else, over a period rather than on one day (paras 4.18 and 4.19). Premises that fail this test, such as a stately home "otherwise out of scope as a private residence", can still be caught while a qualifying event of 800 or more is held there (para 4.21).

A separate part of a building used for a Schedule 1 use may be assessed on its own (para 4.8). So a converted barn or function room used mainly for events may be in scope even if the farmhouse or the rest of the building is your home.

How do you count to 200?

The number is not automatically your fire safety or licence capacity. It is the greatest number of people you can reasonably expect to be present together.

Supplementary document A lists methods you can use:

MethodWhat it uses
A: Safe occupancy for fire safetyThe maximum number the building can safely hold
B: Historic attendance dataRecords of actual numbers at peak times
C: Fixed seating or standing positionsThe number of fixed seats or places
D: Tickets and pre-registrationThe maximum tickets or registrations
E: RestrictionsA capacity limit, such as a licence condition
F: Other meansAny other method, with a justification and evidence

Fire capacity is one method, not the test itself: the village hall above had a safe occupancy figure of 250 but stayed out of scope (para 4.34).

Worked example (illustrative round numbers, not a real venue). A barn hosts weddings with up to 160 seated guests. On a full day there are also 20 catering staff, 6 bar staff, a band and DJ team of 6, a photographer and videographer, and 4 of the owner's own staff. That is 160 + 20 + 6 + 6 + 2 + 4 = 198 people. With staff, the barn is just under the line. One more table of 10 guests would take it over, if the barn also meets the other three tests.

Does a venue that only takes private bookings count?

The law and guidance do not yet answer this clearly, so be careful with anyone who says private hire puts you outside the Act.

What the Act says:

What the guidance says:

What that means in practice:

Who is the responsible person when you hire out your space?

The duties fall on the "person responsible": whoever controls the premises in connection with their Schedule 1 use (s.4(1)). This need not be the owner. If you lease a building and run the venue business in it, you are likely to be the responsible person, not your landlord (guidance para 6.3 and examples).

If your premises have two or more Schedule 1 uses, such as a hotel with a restaurant, the Principal Use of Premises Regulations 2026 (SI 2026/1005) decide which use counts for working out who is responsible. The test starts with what the premises were built or adapted for, how they are used, their physical features and how the council treats them. In the Home Office's example, a hotel with a restaurant is treated as a hotel.

When you hire your venue out, responsibility does not move to the hirer (para 6.13). You can ask hirers to deliver some procedures, but you should explain the requirements to them, and you keep overall responsibility (para 6.14). The guidance suggests writing this into the hire contract, as you would for fire safety. You must be able to show the SIA that you told hirers what was required and took reasonable action to make sure they complied (para 6.15).

The one exception is a qualifying event (800 or more people, public access and entry checks) held at standard tier premises. There the event organiser can be the responsible person for the event (para 6.13).

What will the standard tier ask of you?

1. Notify the SIA

Under s.9 and the Notification Requirements Regulations 2026 (SI 2026/793):

The information required (Schedule to SI 2026/793) includes:

Knowingly or recklessly giving false or misleading information to the SIA is a criminal offence (s.25), and the notification asks you to confirm you know this.

2. Have public protection procedures

Section 5 requires you, "so far as is reasonably practicable", to have procedures that staff follow if they suspect a terrorist attack is happening or about to happen on the premises or nearby. The standard tier factsheet groups them into four types:

  1. Evacuation: getting people out, away from danger.
  2. Invacuation: moving people to a safer place inside, or bringing people in from outside.
  3. Lockdown: stopping people entering or leaving, for example by locking doors.
  4. Communication: telling people on site what is happening and what to do.

Points that matter for a small venue:

The factsheet's example for a shop expecting 200 people is two exit routes, a lockable back room, one named person to lock the front door, and a one-page summary for staff.

What changes at 800 or more?

Enhanced tier premises, and qualifying events, must also:

Recurring large events count. In the government's examples, a hotel whose annual ticketed event reached 900 people at once is enhanced tier premises (Supplementary document A).

A qualifying event (s.3) is a separate route into the Act. It needs 800 or more people expected at the same time at some point, members of the public able to attend, and checks on entry such as tickets, wristbands or membership. The organiser must notify the SIA within 14 days of first publicising the event, or, for an event already advertised when the duty starts, within 14 days of that start (SI 2026/793, reg 3(2)).

What are the penalties?

The SIA can issue compliance notices and penalty notices. For the enhanced tier and qualifying events it can also issue restriction notices. The maximum penalties are:

The government says the SIA will "support, advise and guide" venues, with enforcement for "serious or persistent" non-compliance (sanctions and enforcement factsheet). Inspectors usually give at least 72 hours' written notice, and you can appeal a notice to a tribunal. Failing to comply with a compliance notice is an offence only for enhanced tier premises and qualifying events (s.24(1)), but giving false or misleading information is an offence for everyone (s.25).

Does it work the same in Wales, Scotland and Northern Ireland?

Yes for the venue duties. Part 1 of the Act extends to the whole UK (s.36(1)), and SI 2026/793 and SI 2026/1005 both extend to England, Wales, Scotland and Northern Ireland. The statutory guidance has been published in Welsh too.

One difference: Part 2 (s.34) changes how premises plans are shown on public licensing registers. It extends to England, Wales and Scotland only, and apart from its power to make regulations it is not yet in force. Licensing and fire safety still follow the law of your own nation; Martyn's Law sits alongside them.

What should you do before spring 2027?

  1. Count your real peak: guest numbers from your bookings, plus everyone working on the day.
  2. List your uses. Hire only, or also a bar, restaurant, rooms, open days or ticketed shows? Estimate how much of the year each takes.
  3. Decide who is responsible: whoever controls the premises for the venue use.
  4. Write a one-page assessment: your uses, how much time each takes, your numbers, your counting method and your conclusion. Keep the evidence.
  5. If you are at 200 or more, draft simple procedures under the four headings, brief your staff, and add a short clause to your hire terms telling hirers what you expect of them.
  6. Keep your advertised capacity consistent with the peak, staff included, that you give the SIA. The notification asks for both your peak number and the websites that advertise your premises.
  7. Watch for the start date. The SIA offers email updates and will invite volunteers to test its portal from early 2027.

If you run a community or church hall, our guide to hiring out a village or church hall covers the other rules hall committees face.

What we don't know

This is general information, not legal advice. For a decision about your own venue, read the official guidance or ask a qualified adviser.

Frequently asked questions

Does Martyn's Law apply to a venue that holds fewer than 200 people?

No. Premises are only in scope if it is reasonable to expect 200 or more people, including staff, to be present at the same time from time to time. If your realistic peak, counting guests and everyone working, is 199 or fewer, the Act does not apply to your premises. A one-off, unforeseen busy day does not change that.

When does Martyn's Law come into force?

No date had been set as of 26 October 2026. The Act received Royal Assent on 3 April 2025, the Home Office says the implementation period is at least 24 months, and the SIA expects the Act to come into force in spring 2027. The exact date will be set by commencement regulations.

Do staff count towards the 200-person threshold?

Yes. The figure must include everyone working at the premises in connection with the venue use, whether employees, contractors or volunteers. For a hire venue that includes caterers, bar staff, entertainers and photographers as well as your own team. Only people in the part of the premises used for the listed use are counted.

Does Martyn's Law apply to wedding venues?

It can. An invitation-only wedding reception is not a "qualifying event", but a wedding venue can still be qualifying premises if it expects 200 or more people at once and is mainly used for a listed use, such as a hotel, restaurant or venue for hire. Whether a venue used almost only for invitation-only events counts as a venue for hire for the public has not been settled, so assess your own facts and keep a written record.

Do I need to install security equipment for the standard tier?

No. The Act does not require physical alterations or the purchase of equipment for standard tier procedures, though the guidance says a small change, such as how doors are locked, may sometimes be reasonably practicable. You need procedures for evacuation, invacuation, lockdown and communication that are appropriate and reasonably practicable for your venue, and your staff must know them.

Sources


If your space holds fewer than 200 people at its busiest, staff included, Martyn's Law will not apply to it, and the useful work is keeping the space booked. You can list your venue on HostList.uk for free until 1 April 2027 (after that, publishing needs a paid plan), up to 10 venues: paste a link to your own website or an existing listing page and the listing is imported in about 30 seconds. You type the guest count by hand, so you can enter the number you have actually counted. Organisers message you directly, the site takes 0% commission and handles no payments, and there is no minimum term or notice period.