Terrorism (Protection of Premises) Act 2025 Statutory Guidance: Background and Overview

On 21 April 2026, the UK government published the Statutory Guidance (“Guidance”) to the Terrorism (Protection of Premises) Act 2025 (“the Act”).

The guidance is aimed at clarifying and guiding the implementation of new legal responsibilities for organisations and individuals managing publicly accessible locations. 

The Act, which we have previously written about when it received Royal Ascent in April 2025, marks a significant step in ongoing efforts to strengthen the approach to counter-terrorism and public security, following a series of tragic events that highlighted vulnerabilities in how public premises are protected against terror threats.

Background to the Act

The Act is often referred to as “Martyn’s Law” in recognition of the campaign led by the family of Martyn Hett, a victim of the Manchester Arena bombing.

The Manchester Arena bombing in 2017 underscored the need for a robust legal framework to ensure that venues, businesses, and local authorities adopt proactive measures to mitigate the risks and impact of terrorism and are accountable and prepared in the event such acts arise.

The Act was shaped by extensive public consultation, engagement with security professionals, law enforcement, and victims’ families.

Its primary aim is to create a culture of security awareness and preparedness, ensuring that those responsible for public premises are not only aware of potential threats but are also equipped with practical tools and procedures to respond effectively. 

The legislation covers a wide array of premises, including entertainment venues, retail spaces, places of worship, educational institutions, hotels and other locations where the public may gather.

Key Features of the Statutory Guidance

The Guidance serves as the official interpretation and operational roadmap for the Act’s provisions. It sets out clear expectations for duty holders, those responsible for the management or operation of qualifying premises (“Duty Holders”), and details the steps required to comply with the law. 

The Guidance is structured to help organisations understand their obligations and implement protective measures in a way that is proportionate to the risk and scale of their operations.

Among the core requirements are the development of terrorism risk assessments, the creation and regular review of security plans, and the provision of staff training. The Guidance also outlines the responsibilities for premises of different sizes, recognising that smaller venues may face different challenges compared to large, complex sites.

A particular focus is placed on the need for clear communication strategies, both internally and with emergency services, to ensure swift and coordinated responses during incidents. 

The Guidance also provides practical tools, such as checklists, templates, and case studies, to support duty holders in meeting their obligations. It acknowledges the diversity of premises and aims to be flexible, enabling tailored solutions that fit the specific context and risk profile of each location.

Compliance and Enforcement

The Act, reinforced by the Guidance, introduces a tiered enforcement regime. 

Regulators are empowered to monitor compliance by inspecting premises and events, to obtain information. 

Non-compliance can result in compliance or restriction notices being issued, significant penalties, including fines, and, in severe cases, a criminal prosecution. 

The Guidance provides a comprehensive framework for ensuring that those responsible for publicly accessible locations understand and fulfil their legal obligations. 

The Guidance is intended to act as both an interpretative tool and a practical manual for implementing the Act’s requirements across a wide range of premises, such as entertainment venues, retail outlets, educational institutions, places of worship, and other spaces where the public gathers.

Central to the Guidance is the principle of proportionality. Duty Holders are expected to tailor their protective measures to the specific risks and operational scale of their locations. 

This means that while large and complex sites may require detailed terrorism risk assessments and robust security strategies, smaller venues are not subjected to a one-size-fits-all approach; instead, the Guidance recognises their unique challenges and provides flexible solutions accordingly.

The Guidance outlines several key requirements for compliance. 

Duty Holders must develop and regularly review terrorism risk assessments, ensuring they remain current and relevant to evolving threats. Security plans must be established, detailing both preventative and responsive actions in the event of an incident. 

Furthermore, all staff are to be trained in recognising suspicious activity, understanding emergency procedures, and effectively responding to potential threats. 

The emphasis on staff training underscores the importance of vigilance at every level of an organisation.

Another significant aspect of the Guidance is the emphasis on effective communication. 

Organisations are encouraged to establish clear lines of communication internally and with emergency services, ensuring that information can be quickly disseminated and coordinated responses enacted during a crisis. 

The Guidance also includes practical resources, such as checklists, templates, and real-life case studies, to support Duty Holders in meeting their obligations.

Enforcement of the Act is underpinned by a tiered regime. 

The Guidance stresses the importance of constructive engagement between regulators and Duty Holders, promoting a collaborative approach aimed at achieving high standards of security and public protection.

In addition to legal enforcement, the Guidance promotes voluntary best practice, urging organisations to go beyond the minimum requirements where feasible. It highlights the value of partnership working, both locally and nationally, and encourages information sharing to foster a collective defence against terrorism.

Key Considerations for Occupiers and Landlords

Martyn’s Law makes it clear that counter‑terrorism planning will, from now on, form a core part of property governance for premises with a capacity of 200+ individuals, sitting alongside existing fire safety and building safety legislation.  From an investment perspective, prospective purchasers of qualifying premises will expect to see that appropriate security plans are in place to protect against potential terrorist attacks, helping to promote consistency and compliance across the market.

While occupiers of retail and leisure properties are likely to feel the immediate operational impact and will bear the financial burden of compliance, landlords and investors also have a meaningful role to play. In schemes where owners retain control of common parts—such as shopping centres and mixed‑use developments—they will need to work collaboratively with tenants to co‑ordinate evacuation, lockdown and communication plans. There will, of course, be service‑charge implications, and landlords will be checking existing leases to see if existing heads of expenditure are flexible enough allow them to recover these costs from tenants. In new leases, compliance is likely to be included within the list of recoverable service charge costs.  

The Real Estate industry is generally focussed on how best to integrate the new requirements both sensibly and commercially and will welcome the further Guidance which has been published this week. Many in the industry are already engaging with specialists to conduct risk assessments during the two-year transitionary period and taking into account Martyn’s Law when considering the layout and design of new qualifying buildings, before legal enforcement takes effect from April 2027.

Looking Ahead

The publication of the Guidance represents a pivotal moment in the UK’s counter-terrorism strategy. 

By providing clarity on legal expectations and practical support for implementation, it aims to empower organisations to protect their premises and the people within them. 

The Guidance will be subject to ongoing review and refinement, reflecting new threats and lessons learned from real-world incidents.

Ultimately, the Act and the Guidance seek to embed a culture of preparedness and resilience, with the aim of ensuring the lessons of past attacks are not forgotten and that public safety and counter-terrorism innovation remain at the forefront.