24 April 2026

Two major developments for the implementation of Martyn's law

The Home Office has issued its long awaited statutory guidance setting out further details of the requirements of the Terrorism (Protection of Premises) Act 2025 ('the Act') and what senior individuals and organisations affected by the Act must do to comply.

Here are the headlines:

    1. The statutory guidance provides flow charts supported by explanatory information to help organisations determine if their premises or event is in or out of scope of the Act, and if in scope, whether they have 'standard' or 'enhanced' duties.
    2. It sets out the legal responsibilities and liabilities at both the organisational and individual senior leadership level.
    3. Further information is provided on the meaning of 'public protection procedures' and 'public protection measures', and a number of case studies are provided.
    4. The guidance distinguishes between those steps or measures that a dutyholder must take, with those it should or could take.
    5. The adoption of well recognised concepts of 'reasonable practicability' and 'extent of control' are explored in the context of anti-terrorism.
    6. The guidance includes non-statutory supplementary material from the National Counter Terrorism Security Office and the National Protective Security Authority.
    7. It also covers penalties for non-compliance – including civil enforcement powers, daily penalties of up to GBP50,000 per day and prosecution.
    8. However, it still remains unclear when precisely the substantive requirements of the Act itself will be commenced.

In addition to the above Home Office statutory guidance, the Security Industry Authority, who will be the regulator for Martyn's law, are consulting on their own guidance about how they will perform their functions as regulator (Martyn's Law: draft section 12 statutory guidance - GOV.UK). Future dutyholders and interested specialists are encouraged to engage in this consultation process. This consultation invites views on:

    1. the elements of their draft guidance that set out how the Security Industry Authority propose to operate within the framework set by the Act; and
    2. the drafting of the guidance from those with a particular interest, such as regulatory and legal specialists.

This consultation closes at 11:59pm on 12 June 2026.

DLA Piper has a dedicated team of regulatory lawyers who were instructed by a central Core Participant in the Manchester Arena Inquiry – from which the Act has evolved. Our team has a unique insight into the development and enactment of the Act. Should you require any advice in relation to the matters raised in this article, please contact the authors or your regular DLA Piper contact.

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