10 Key Considerations for Local Authorities in preparation for Martyn’s Law

In recognition of the large amounts of preparation needed for the new obligations, the Government announced that commencement will follow an implementation period of at least 24 months after Royal Assent , ensuring those responsible for implementing changes had sufficient time to understand their new obligations and action them appropriately.  Now 15 months into this period we’ve collated a handy list key considerations Local Authorities should factor into their preparations:

1. Establish what council owned buildings will be included

Many local authority buildings will potentially fall within the scope of the Act, including but not limited to:

• Town halls and civic centres

• Libraries

• Museums and galleries

• Leisure centres

• Community halls

• Markets

• Visitor attractions

• Some education facilities

• Customer service centres

Whether a building is covered remains nuanced despite the April 2026 guidance, and requires the premises satisfy the statutory criteria relating to qualifying uses and reasonably expected occupancy, split into two tiers:

• Standard Tier: premises reasonably expected to have 200–799 people

• Enhanced Tier: premises reasonably expected to have 800 or more people

2. Understand your new legal duties

For Standard Tier premises, councils must have practical procedures for responding to a terrorist incident, including:

• Evacuation

• Invacuation (bringing people inside to safety)

• Locking down areas

• Communicating with staff and visitors

The emphasis is on preparedness rather than specific security measures. Physical security upgrades are not mandatory simply because a premises is in the standard tier.

For Enhanced Tier premises, councils have additional obligations, including:

• Undertaking terrorism risk assessments

• Identifying vulnerabilities

• Implementing reasonably practicable protective security measures having regard to the identified risk

• Documenting security arrangements

• Maintaining appropriate governance and oversight

3. Review your events programme

Local authorities organise many events that could qualify, such as:

• Festivals

• Concerts

• Christmas markets

• Christmas lights switch-on

• Fireworks displays

• Civic celebrations

• Remembrance events

If a qualifying event is reasonably expected to have 800 or more attendees and controlled public access it may fall within the enhanced requirements, regardless of whether it is held on council-owned land.

4. Update your governance arrangements

Local authorities will need to integrate Martyn's Law into large numbers of their governance arrangements, including:

• Corporate risk registers

• Emergency planning

• Health and safety management

• Business continuity planning

• Venue management

• Staff training

• Procurement for contracted venue operators

This means counter-terrorism preparedness becomes part of routine corporate governance rather than being solely an emergency planning function.

5. Plan employee training

Authorities are likely to need training on recognising threats, responding effectively, and protecting the public during an incident for:

• Front-line staff

• Reception teams

• Library staff

• Leisure centre staff

• Event managers

• Security personnel

• Facilities management

• Senior responsible officers

6. Engage with estates teams

Depending on the size of the authority you may have hundreds of buildings to review. Council estates teams will be crucial to helping:

• Identify which premises are in scope

• Determine expected occupancy levels

• Maintain records

• Review layouts

• Consider access control

• Work with building users and tenants where premises are shared

7. Procurement & commercial contract implications

If you outsource any services to third party suppliers, you may need to update your contracts to ensure that compliance responsibilities are appropriately allocated and defined.  Suppliers should also be made aware of, and confirm their understanding and agreement to, their own Martyn's Law responsibilities where applicable. Consider if you have any contracts for:

• Security

• Facilities management

• Event management

• Venue hire

• Building management

8. Offering advice to others

Although the Act is enforced by the Security Industry Authority rather than local authorities, councils are likely to receive more enquiries from businesses, charities, and event organisers about compliance.  Licensing, environmental health, emergency planning, and community safety teams should consider how enquiries will be managed, to what extent they are able and prepared to provide advice and assistance, and when organisations should be signposted to official guidance and Counter Terrorism Security Advisers instead.

9. Financial implications

Like with any significant change, authorities should anticipate associated costs associated with implementing the above. Costs are likely to vary depending on the size and complexity of the council's estate.

10. Strategic implications

For local authorities, Martyn's Law is more than a new compliance requirement. It requires terrorism preparedness to become embedded in everyday management of public spaces and events. Councils will need to demonstrate that appropriate procedures and, where applicable, reasonably practicable security measures have been considered and implemented in accordance with the Act.

For larger authorities, implementation is likely to involve collaboration between estates, emergency planning, health and safety, legal services, events teams, procurement, communications, and senior leadership to ensure a consistent, organisation-wide approach.

For further information official government can be guidance: Home Office statutory guidance on the Terrorism (Protection of Premises) Act 2025.

For further advice or to arrange training for your team please get in touch.