Martyn's Law for events: the 800 test, the duties and when they start

Martyn's Law, the Terrorism (Protection of Premises) Act 2025, will apply, in outline, to an event when the public attend it, entry is checked, and 800 or more people, staff included, can reasonably be expected on site at the same time. As at 20 October 2026 its duties are not yet in force: no commencement day has been appointed, and the Security Industry Authority (SIA) expects commencement in spring 2027.

This is general information drawn from the Act and Home Office guidance, not legal advice.

Martyn's Law for events: the key points

• Statute: Royal Assent 3 April 2025; the duties extend UK-wide. Named after Martyn Hett, one of 22 people killed in the Manchester Arena attack on 22 May 2017.
• Qualifying event: six conditions, the headline one 800 or more present at once at some point, staff included. Events have no standard tier.
• Duties: attack procedures, security measures, a document for the SIA, notification, and a senior individual for an organisation.
• Regulator: the SIA. Once in force, the person responsible for a qualifying event risks penalties of up to £18 million or 5% of qualifying worldwide revenue, whichever is greater.

When does Martyn's Law come into force?

Section 37 starts the duties on a day the Secretary of State appoints by regulations, possibly different days for different purposes. As at 20 October 2026, legislation.gov.uk lists two commencement regulations, and neither starts the duties:

• No. 1 (SI 2026/320) commenced section 27, which requires the Secretary of State to publish guidance, on 10 April 2026.
• No. 2 (SI 2026/622) commenced parts of sections 12 and 18, on SIA guidance and its revenue statement, on 15 June 2026.

Sections 2, 3, 5 and 6, which set the scope and the duties, are still marked prospective. The Home Office factsheets, updated in July 2026, say the requirements "have not yet been commenced".

The statutory guidance (para 2.10) sets an implementation period of at least 24 months from Royal Assent, which on the government's stated timetable means not before 3 April 2027. The SIA's guidance of 17 July 2026 expects spring 2027, with the exact date confirmed beforehand. Until a third commencement regulation names the duties, that is an expectation, not a date.

What makes an event a qualifying event

Section 3(1) sets six conditions. An event qualifies only if all of them hold:

1. it is held at a building, other land, or both, so a field or a park counts;
2. the premises are not enhanced duty premises, or part of them;
3. members of the public have access to attend;
4. it is reasonable to expect 800 or more people present at the same time at some point;
5. there are checks that attendees have paid, hold a ticket or pass, or are members or guests of a club or similar body;
6. it is not an excluded event under Schedule 2.

Invitation-only events, such as a wedding, lack public access and do not qualify.

The 800 figure is the peak, staff included

The figure includes staff, back-of-house too (para 5.17). It is the highest number present at any point, not an average (para 5.19), and timed entry that keeps the expected peak under 800 takes an event out of scope (para 5.20). In the Home Office events factsheet, a day festival with about 500 people until 6pm and 1,000 or more later meets the attendance condition: 800 need only be reached once.

The non-statutory Supplementary Document A lists methods for the number: safe occupancy for fire safety, historic attendance, fixed seating or standing, tickets and pre-registration, licence restrictions, or another reasoned method. Where a method leaves staff out, they are added (para 5.18).

A worked example. A show sells 1,200 day tickets. Last year's gate scans show at most 700 ticket holders on site at once, and 120 stewards, traders and crew work that hour. The assessed peak is 700 + 120 = 820, so condition 4 is met although attendance alone is under 800. For the density side of the sum, see event capacity and occupant density.

Entry checks, and areas inside a larger event

Condition 5 covers free events too if entry is checked: tickets, wristbands, QR codes and turnstiles all count. A suggested donation does not, nor do search criteria or a dress code (para 5.25), and the guidance expects a well-defined, secure perimeter (para 5.22).

Where only part of an event has entry checks, each such part is treated as a separate event (s.3(2)). A free carnival may be out of scope while a ticketed enclosure inside it, expecting 800 or more, is in. Open pavements and towpaths are out unless they are in the immediate vicinity of a qualifying event (paras 5.40 to 5.41).

Exclusions, and why there is no standard tier

Events at places of worship, childcare, schools and further education premises do not qualify, nor do events at the legislatures or at transport premises under their own security rules. An event at enhanced duty premises falls under the premises' duty. The 200-person standard tier applies only to qualifying premises, which must consist of a building, or a building and other land, wholly or mainly used for a Schedule 1 use. So a 500-person ticketed event in an open field falls outside both tests.

Who is responsible for a qualifying event

Under section 4, it is whoever will control the premises in connection with their use for the event. In the Home Office's council-park example, an event company given control of an area by its contract is responsible; if the council keeps control, the council is, even when it contracts out stewarding. Tasks can be delegated; responsibility cannot. A landowner who is not the responsible person but keeps some control of the site must co-operate so far as is reasonably practicable (s.8). A responsible company or other body must designate a senior individual (s.10).

What the duties will require

Once commenced, the procedures and measures must be in place so far as is reasonably practicable. Assessing and reviewing the measures, preparing the document, notifying the SIA and, for a company or other body, designating a senior individual are firm requirements.

• Procedures (s.5): evacuation, invacuation to a safer place within the site, lockdown, and communication. An open-air event may have no internal areas to invacuate into; the guidance suggests recording why (para 7.24). It favours dispersal over a predictable assembly point (para 7.36). The Act requires no physical alterations or equipment purchases for procedures, though some may be reasonably practicable (para 7.25).
• Measures (s.6): monitoring the site and its vicinity; controlling movement in, out and within; physical security; and security of information, such as who sees detailed plans. They may rely on people, processes or physical mitigations such as CCTV or hostile vehicle mitigation.
• Document (s.7): the procedures and measures and how they reduce risk, kept up to date. The SIA gets a copy as soon as reasonably practicable, and each revision within 30 days.
• Notification (s.9 and SI 2026/793): within 14 days of the event first being publicised, or of commencement day for an event already publicised. It gives the most people expected at once and how that was calculated. The regulations take effect only when section 9(1) is fully in force.

The regulator: SIA powers and penalties

SIA inspectors can inspect events, usually after at least 72 hours' written notice. The SIA can issue information notices, compliance notices and, for qualifying events and enhanced duty premises only, restriction notices that restrict or prohibit hosting the event. Notices can be appealed to a tribunal.

For a qualifying event, a penalty on the person responsible can reach £18 million or 5% of qualifying worldwide revenue, whichever is greater; with no completed accounting period, the cap is £18 million (s.18). Daily penalties of up to £50,000 can follow for each day a breach of a notice continues past the payment date (s.19). Failing to comply with a compliance or restriction notice is an offence, with up to two years' imprisonment on indictment (s.24). The Home Office says the SIA's core principle is to support and advise, with prosecution kept for the most serious cases.

How Martyn's Law fits with the Purple Guide, your SAG and licensing

The Act (primary legislation) and its regulations (statutory instruments) are law. The Home Office guidance under section 27 is statutory guidance; its supplementary documents A to C are not. The Purple Guide, a paid publication from the Events Industry Forum, is industry guidance, which the Home Office points events teams to. The guidance asks that security measures do not conflict with such guidance or impede safe entry and exit (para 8.22); see the Purple Guide for event safety.

On licensing, Part 2 of the Act will limit which premises plans go on public licensing registers in England, Wales and Scotland; it is not yet in force either. The section 7 document goes to the SIA and is separate from the plan for your Safety Advisory Group: see preparing an event site plan for a SAG.

Getting ready now: steps organisers can take

The guidance was published early so that those in scope can prepare:

1. Assess your peak headcount, staff and contractors included, and record the method; the notification asks for both.
2. Where only parts of the site have entry checks, test each such area, such as a ticketed arena inside a free event, against 800 on its own (s.3(2)).
3. Agree in writing who has control of the site for the event.
4. Draft the four procedures, avoiding the normal fire alarm as the trigger for an attack evacuation where possible (para 7.36).
5. Walk the approaches: vehicle access to the crowd, queues, and any security line across an exit or the emergency route.
6. Restrict who sees the security detail of your plans.
7. Train staff. ProtectUK's ACT Awareness e-Learning is free.
8. Be wary of paid compliance guarantees. The government intends the guidance to be usable without consultancy.
9. Watch for the date. The SIA plans final section 12 guidance in autumn 2026 and volunteer portal testing from early 2027.

Checking a site plan with Airship Event Designer

Airship Event Designer (the Events mode of Airship Site Designer) has a Martyn's Law readiness check. It reads the drawn site against the six section 3(1) conditions and answers qualifying event yes, no or unclear, naming the deciding condition rather than guessing. It takes your peak headcount and method, or else counts attendees plus crew and says so. Each duty is marked shown on plan, to document, or not applicable. Review and share links, quote requests and, by default, the Event Safety Plan appendix and DXF leave the security layout out; some exports still show it, and hiding it is not access control, so restrict their circulation. It is a readiness aid, not the security document, and not legal advice. Event Designer is in beta on Pro and above, switched on per account: see Martyn's Law readiness or Event Designer.

Questions organisers ask

When does Martyn's Law come into force for events?

Not yet. As at 20 October 2026 no commencement day has been appointed; the guidance allows at least 24 months from Royal Assent on 3 April 2025, and the SIA expects spring 2027.

Does Martyn's Law apply to free events?

Once the duties are in force, yes, if entry is checked by ticket, wristband, QR code or turnstile and the other conditions are met. A suggested donation is not an entry check.

Is there a 200-person standard tier for events?

No. The 200 and 800 tiers apply to premises; an event either meets the 800 test and the other conditions or does not qualify.

Does a 1,500-ticket festival qualify if people come and go?

It depends on the peak: the most people reasonably expected at the same time, staff included. Timed entry that keeps the peak under 800 takes it out of scope.

What are the penalties for a qualifying event?

Once in force, the person responsible faces up to £18 million or 5% of qualifying worldwide revenue, whichever is greater, plus daily penalties of up to £50,000 for a continuing breach of a notice.

Sources

• Terrorism (Protection of Premises) Act 2025, legislation.gov.uk
• Commencement No. 1, SI 2026/320; Commencement No. 2, SI 2026/622; Notification Requirements, SI 2026/793
• Statutory guidance and Supplementary Document A, Home Office
• Martyn's Law factsheets, Home Office
• Understanding Martyn's Law and the SIA's role as regulator, SIA
• Martyn's Law and ACT Awareness e-Learning, ProtectUK

Last reviewed 20 October 2026, against legislation.gov.uk and GOV.UK.

Whether an event qualifies, and what is reasonably practicable for it, is for its responsible person to decide; take legal advice where it matters.