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June 12, 2025
Martyn’s Law, set to come into force by April 2027, imposes new legal duties on UK venues to improve counter-terrorism preparedness. This update outlines how the law affects studios, filming locations, casinos, and stadiums and what entertainment businesses should do now to comply.
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What is Martyn's Law
The United Kingdom’s approach to public safety has entered a new era with the introduction of the Terrorism (Protection of Premises) Act 2025, widely known as Martyn’s Law. This legislation, which received Royal Assent in April 2025, is a direct response to the tragic Manchester Arena bombing and the subsequent campaign led by Figen Murray, whose son Martyn Hett was among the victims.
The Act aims to ensure that public venues and events across the UK are better prepared to prevent and respond to terrorist threats, placing a statutory duty on those responsible for a wide range of premises—including those in the entertainment sector.
Martyn’s Law is designed to address the historic inconsistency in counter-terrorism preparedness, which until now has largely been voluntary and overshadowed by other legal obligations such as health and safety. The Act’s primary objective is to ensure that public protection is not left to chance but is instead embedded in the operational fabric of venues and events that attract large numbers of people.
Who is affected?
Martyn’s Law applies across a wide range of sectors, but the entertainment industry, given its concentration of high-footfall venues, is particularly impacted.
The legislation introduces a two-tier system duty framework:
- Standard Duty applies to venues with an expected capacity of 200 – 799 people.
- Enhanced Duty applies to venues and qualifying events involving 800 or more people with controlled access (e.g. via ticketing).
This means that casinos and stadiums are all squarely within the law’s remit, as well as many movie studios and general filming locations. For example, studios which not only host large-scale film productions but also welcome thousands of visitors for public tours, are likely to be classified as enhanced duty premises. Similarly, major stadiums such as Wembley or Old Trafford, large casinos in city centres or resort destinations, and popular filming locations used for public events or open days will also be subject to the Act’s requirements.
How do the new duties work?
The duties imposed by Martyn’s Law are proportionate to the size and nature of the venue.
For standard duty premises, the focus is on procedural readiness and staff awareness. Operators are required to develop and maintain evacuation and invacuation procedures, ensure the ability to secure the premises, establish clear communication protocols, and train staff to recognise and respond to terrorist threats. These measures are intended to be fairly straightforward and low-cost, with (critically) focus on improved oversight and no requirement for physical alterations or specialist equipment.
Enhanced duty premises, by contrast, face more extensive obligations. In addition to the standard requirements, they must conduct detailed terrorism risk assessments, implement monitoring and surveillance systems such as CCTV, introduce search and screening processes, and enhance physical security where necessary. Regular reviews of security measures are required, and a senior individual must be designated as responsible for compliance. Detailed documentation of all procedures and measures must be maintained, and the Security Industry Authority (SIA) must be notified when responsibility for qualifying premises or events is assumed.
Movie studios
For movie studios – especially those that combine large-scale production with public access through tours of events – the application of Martyn’s Law presents unique challenges.
Studios are often complex environments, encompassing:
- Multiple sound stages and backlots.
- A mix of permanent and temporary occupants (e.g. production companies, contractors).
- Complex access arrangements for cast, crew and the public.
Studios must:
- Assess their maximum occupancy, particularly during peak production periods and public events.
- Determine whether public tours and events fall under enhanced duty requirements.
- Implement robust access control, perimeter security and clear responsibility structures among tenants.
- Create tailored staff training which is comprehensively documented and takes place at regular intervals for all staff, including temporary workers and contractors.
Filming locations
General filming locations present a different set of considerations. Filming can take place in a wide variety of settings, from city streets to historic buildings and open countryside. Martyn’s Law applies where:
- The location is open to the public during filming or hosts public events.
- 200 or more people may be present at the same time.
This means temporary structures or event spaces may also trigger duties under the Act.
The responsibility for compliance falls on the person or entity in control of the premises at the relevant time, which may be the location owner, the production company, or an event organiser.
Production companies should:
- Conduct terrorism vulnerability assessments for each location.
- Develop clear evacuation and lockdown procedures.
- Ensure that compliance responsibilities are clearly agreed and documented, particularly where multiple parties are involved.
Casinos
Casinos, with their high profile and large, often late-night crowds, face particular challenges under Martyn’s Law. Many UK casinos will fall within the enhanced duty category, especially those in major cities or resort destinations.
Compliance measures for casinos include:
- Robust entry controls, including ID checks and bag searches.
- Comprehensive surveillance systems and procedures for managing large numbers of patrons.
- Enhanced physical security infrastructure such as reinforced entry points and vehicle barriers.
- Comprehensive staff training ensuring all staff, from security personnel to hospitality workers, can recognise suspicious behaviour and respond appropriately.
Operators must also maintain detailed, auditable records of security procedures, training and risk assessments and co-ordinate closely with landlords or other tenants where the casino is part of a broader complex.
Stadiums
Stadiums are a (if not the) primary focus of Martyn’s Law. By design, they host mass gatherings – football matches, concerts and large-scale events – making them critical from a counter-terrorism perspective.
Under enhanced duty requirements, stadium operators must:
- Conduct comprehensive event-specific risk assessments, taking into account factors such as crowd density, ingress and egress points, and the potential for vehicle-borne threats.
- Install and maintain security infrastructure, which may include perimeter fencing, vehicle barriers, CCTV, and advanced screening technologies.
- Develop bespoke emergency response plans for each event.
- Train staff and stewards in evacuation procedures.
- Collaborate with local authorities, emergency services, and event organisers to ensure a coordinated response.
Comprehensive documentation of all security measures, risk assessments, and training activities is required. The SIA has the power to inspect and audit stadiums at any time.
Enforcement and penalties
The SIA is responsible for oversight, guidance and enforcement under Martyn’s Law. It has wide-ranging enforcement powers including:
- Issuing compliance and restriction notices.
- Imposing significant fines:
- Up to a maximum of £18 million or 5% of worldwide revenue, whichever is greater.
- Daily fines of up to £50,000 for continued non-compliance.
- Potential criminal sanctions may also apply for serious breaches, such as failure to comply with notices or providing false information.
The SIA is also tasked with providing guidance and support to duty holders, with a focus on helping organisations achieve compliance.
Next steps
With the main provisions of Martyn’s Law expected to come into force around April 2027, now is the time for entertainment businesses to begin preparations. Recommended first steps include:
- Assessing your duty status for each venue or site.
- Reviewing or creating risk assessments, response plans and staff training.
While the SIA is still preparing its guidance for stakeholders, you can access free technical guidance and operational advice on protective security on the National Protective Security Authority and ProtectUK websites.
By taking proactive steps, the entertainment sector can not only meet its legal obligations but also play a vital role in protecting the public from the evolving threat of terrorism.
The law provides a clear framework for improving public safety and organisational preparedness, ensuring that the tragic events of the past are not repeated, and that public safety remains at the heart of the nation’s cultural and social life.
For help with preparing your organisation’s compliance with Martyn’s Law, please get in touch with our property team. The team works exclusively with companies operating in the media, entertainment, sports and betting and gaming industries so we have a detailed understanding of the challengers you’ll face, and how to navigate them.
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