terrorism bill

Martyn’s Law - Terrorism (Protection of Premises) Bill

TIAA are working closely with key stakeholders and clients in preparation for the introduction of statutory legislation which will eventually create a requirement for the enhanced protection of publicly accessible locations across the UK from terrorist attacks.

Current Position – 7th November 2023

His Majesty King Charles III recently (7th November 2023) performed one of his key duties as monarch, reading the King’s Speech at the State Opening of Parliament. This included the proposed Terrorism (Protection of Premises) Bill, also known as Martyn’s Law.

The legislation would require those responsible for certain publicly accessible locations (PALS), with a capacity of more than 100 people, to introduce training and measures to combat the threat from terrorism and implement appropriate and proportionate mitigation measures, or face sanctions.

The Bill has proved controversial amid fears the excess costs of counter-terrorism preparation could disproportionately affect  smaller venues. However, distinctions in the legislation mitigating this are expected to allow the legislation to pass through parliament in the coming year.

3rd May 2023

On 2nd May 2023, the Terrorism (Protection of Premises) Bill, also known as “Martyn’s Law”, was published in draft, along with explanatory notes, an impact assessment and a letter from the Rt Hon Tom Tugendhat, Security Minister.

TIAA are working closely with key stakeholders and clients in preparation for the introduction of statutory legislation which will eventually create a requirement for the enhanced protection of publicly accessible locations across the UK from terrorist attacks.

The strategic objectives of the Terrorism (Protection of Premises) Bill are to;

  • keep the public safe and secure;
  • reduce the impact of terrorist attacks where they do occur;
  • provide clarity on responsibility for security activity; and
  • improve consistency in security considerations and outcomes.

Terrorism Bill
Terrorism Bill

Qualifying public premises

Qualifying public premises are separated into two tiers:

  • Standard duty premises: have a capacity of between 100 and 799 people, and
  • Enhanced duty premises have a capacity of 800 or more.

Qualifying public events with a capacity of 800 or more are generally subject to the same requirements as enhanced duty premises. The legislation will require organisations to assess the potential risk and impact of a terror attack at the locations they own, operate or control. They’ll be required to take proportionate protective security and organisational preparedness measures to make it harder for a would-be terrorist to carry out a successful attack. These may include:

  • Retail stores, shopping centres and markets
  • Transport hubs and Commercial ports
  • Schools and universities
  • Medical centres and hospitals
  • Hotels, pubs, clubs and casinos
  • Sports stadium, music venues, festivals and visitor & tourist attractions
  • Places of worship
  • Government offices, including town halls and job centres
  • High streets, public squares, parks and beaches
  • Private venues, such as places of employment or other locations where there is no public access are not intended to fall within the scope of the Terrorism Bill.
  • Qualifying premises can also be contained within other premises (for example, stores within a shopping centre).

Preparing to meet your obligations

It is important to understand that the Terrorism (Protection of Premises) Bill is still only in its draft form and the criteria for meeting compliance is still not fully know at this time. TIAA can however assist you to prepare for the forthcoming legislation by conducting enhanced terrorist risk assessments and standard terrorism evaluations to ensure you meet your future legal obligations and, importantly, keep staff and visitors to your venue safe.

Our services include:

  • Security management advice on reasonably practicable security measures to be put in place.
  • Ensure simple, low-cost activities which seek to improve protective security and preparedness are implemented.
  • Undertaking an annual standard / enhanced terrorism evaluation that is reviewed with each material change to or use of the premises.
  • Providing relevant workers with appropriate terrorism protection training.
  • Advice on the requirements for enhanced duty premises and qualifying public events.
  • Advice regarding the appointment of a designated senior officer.
  • The preparation and maintenance of security plans.

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Hospitals or for the provision of healthcare will be a qualifying activity. The draft Bill is clear that ‘health care’ covers ‘all forms of health care provided to individuals, whether relating to physical or mental health, and including ancillary care’ and hospital is given the meaning in section 275 of the National Health Service Act 2006.

Any organisation, whether public sector or otherwise (including charities and not for profits) will need to consider these definitions along with the public capacity of their premises to consider if the duty will apply.

What is unclear is how the duty will be incorporated into existing requirements, including those under the Civil Contingencies Act 2004 and the NHS England Emergency Preparedness, Resilience and Response Framework.


All educational establishments will fall within the standard tier, regardless of their capacity, apart from higher education establishments.  For under 18s education, existing safeguarding requirements should provide the basis for preparing plans, with a number of response arrangements already in place.

For higher education establishments, the requirement to comply with enhanced tier obligations will only apply where capacity is over 800 people.  Universities have diverse property portfolios and will have multiple buildings which could each exceed the 800 plus capacity threshold.

Senior university staff will have liability to ensure that the governance requirements of creating and implementing the response plan are considered.

vulnerable to internal threat actors and part of their response plan should consider how it engages with the potential for a threat from its own residents/users.

Higher Education

Charity Sector, Heritage & Places of Worship

Charities and not for profit organisations, including social enterprises and community groups, operate a wide range of venues in terms of size and use.

The proposed legislation will cover libraries, museums or galleries; for recreation, exercise or leisure by visiting members of the public; as a visitor attraction of cultural, historic, touristic or educational value; as a hospital; places of worship.

Organisations will also need to consider any large events they hold and where those events are typically held given the requirements for qualifying public events.


The key clauses for employers are sections 13 and 14, which deal with terrorism protection training for relevant workers and will include introducing training and refresher courses for staff.  The requirement for terrorism training is relevant for both standard duty premises as well as enhanced duty premises and qualifying public events.

A ‘relevant worker’ is an individual who works at, or in connection with, the premises or event and who has responsibilities that make terrorism protection training appropriate.  This will include employees and non-employees and full or part-time workers.

Organisations may need to use external consulting support to assess and mitigate the risks appropriately.

The Bill states that the security plan, to be provided to the regulator, must include details of the terrorism protection training provided.

Property Owners, Landlords and Occupiers

The obligation to comply with the requirements of the Terrorism Bill will fall on the person who has control of the premises as ‘occupier or otherwise’.

The definition of ‘qualifying public premises’ includes a broad range of expected venues to which the legislation will eventually apply including, shops, hotels, food and drink retailers, nightclubs, theatres and cinemas, sports grounds and leisure venues. It excludes private dwellings and offices.

The ‘qualifying premises’ can sit within other premises – for example a large retail unit within a shopping centre and will require co-operation between retailers and the centre operators.

The regulations around capacity of premises will be determined by the Secretary of State. The current guidance indicates that “such regulations might require some types of premises to determine their capacity differently from others” and will be the subject of further updates as the Bill passes through the parliamentary process.

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