Consider a Saturday night at a busy town-centre venue in Newcastle. A promoted event attracts more customers than expected, one member of the door team calls in sick and the clicker count no longer matches the number recorded at the entrance. Customers repeatedly use a side exit to leave and attempt to re-enter, so somebody secures the door from outside and plans to remove the fastening at closing time. This does not need a terrorist incident to become dangerous—and it does not need Martyn’s Law to become a serious safety failure.
Martyn’s Law does not create the existing safety baseline
The Terrorism (Protection of Premises) Act 2025, commonly known as Martyn’s Law, has received Royal Assent. Its substantive duties are not yet in force. As at 1 November 2026, the Security Industry Authority expects the Act to come into force in spring 2027 and says it will confirm the exact date in advance.
Venues should prepare, but they should not confuse future protective-security duties with the requirements that already apply. Existing fire-safety law requires suitable escape arrangements. Licensing law already places public safety and the protection of children among the licensing objectives. A blocked, inaccessible or inappropriately secured fire exit can therefore expose people to serious harm and regulatory action without Martyn’s Law being involved.
The practical point is simple: Martyn’s Law adds to the baseline. It does not replace the fire risk assessment, capacity control, staff competence, door management or emergency arrangements a venue should already have.
SIA: understanding Martyn’s Law and its expected commencement ↗ · GOV.UK: fire-safety duties and means of escape ↗
Check whether the venue is likely to fall within scope
A public venue will not fall within scope merely because it has a premises licence. The responsible person must assess the Act’s qualifying criteria, the principal use of the premises, public access and how many people can reasonably be expected at the same time.
The standard tier generally covers qualifying premises where between 200 and 799 people, including staff, may reasonably be expected at the same time from time to time. The enhanced tier generally begins at 800. An average attendance below 200 does not automatically put a venue outside scope if promotions, seasonal peaks or special nights mean the threshold is reasonably reached on occasion.
Use real operating information: ticket sales, clicker records, till data, staffing numbers, historic peaks and planned events. Do not rely only on the theoretical fire-safety capacity. The same records that help determine Martyn’s Law scope can reveal weaknesses in ordinary occupancy control.
Understand the four public-protection procedures
For qualifying premises, the Act requires appropriate public-protection procedures, so far as reasonably practicable. These are evacuation, invacuation, lockdown and communication. They are planned actions for staff to take when they suspect an act of terrorism is occurring or is about to occur at the premises, at an event or in the immediate vicinity.
Evacuation moves people away from danger and out of all or part of the premises. Invacuation brings people inside or moves them to a safer internal area. Lockdown secures all or part of the premises to restrict movement. Communication alerts people and gives usable instructions. The right response depends on the threat, its location and the building—not a single generic instruction.
The statutory guidance makes clear that a written procedure is not enough if relevant staff cannot implement it rapidly and effectively. Door supervisors, temporary bar staff, contractors and duty managers need to know their roles, who can make the decision, what wording to use and how the response changes when the threat is inside rather than outside.
A locked fire exit is not a lockdown procedure
A lockdown is a planned response to a suspected or actual attack. Official guidance recognises one-way, two-way, partial and zonal lockdowns. A venue may need to prevent entry while allowing people to leave, secure only the side facing the threat, or move people before restricting movement. The plan must identify how decisions are communicated, who controls the doors and how arrangements are changed or released when it becomes safe to do so.
Securing a fire exit simply to prevent unpaid re-entry, stop an alarm sounding, reduce staffing needs or make crowd control easier is not a lockdown. It is an uncontrolled obstruction. The same applies to placing stock, furniture, barriers or waste in an escape route because the area is rarely used.
Fire exits and escape routes must be kept clear and suitable doors should be immediately openable without a key or code. The available number and width of exits must also remain suitable for the people present. A procedure written for a future terrorism duty cannot make an unsafe everyday arrangement acceptable.
Test the exits, people and decisions together.
HR + SAFETY can review your current fire arrangements, staffing responsibilities and developing Martyn’s Law procedures during realistic operating conditions.
Discuss a venue-safety reviewMake fire, security and licensing arrangements work together
A fire evacuation normally directs people towards established exits and a place of safety. A terrorism-related evacuation may need to direct people away from a known threat, use selected routes or delay movement while information is checked. The statutory guidance says terrorism evacuation plans should complement and not conflict with fire-evacuation arrangements.
Consider foreseeable conflicts before an emergency. What happens if the safest fire exit faces the reported threat? Can staff prevent entry without trapping people inside? Will the fire alarm send customers towards danger? Can a message be heard over the sound system? Does the door team receive the same information as the duty manager? How will disabled customers and anybody needing assistance be supported?
The solution is not necessarily expensive equipment. It begins with decisions, responsibilities, communication methods and a realistic understanding of the building. Enhanced-tier premises will have additional duties concerning public-protection measures and documentation, but every venue benefits from testing whether its procedures can work together.
Inspect the venue while it is genuinely operating
A quiet-afternoon inspection cannot show how a venue behaves at midnight. Furniture moves, smoking areas develop, glass and waste accumulate, deliveries arrive, temporary workers join the shift and customers stand where the written plan assumes they will keep moving.
Walk the venue during a busy operating period without obstructing the business. Check every required exit, the complete route beyond it, the occupancy count, emergency-service access, lighting, audible and visual communication, radio coverage, staffing and the way door supervisors manage entry, re-entry and queues. Speak to the people expected to act rather than assuming a signed policy proves understanding.
Record the findings, name an owner and close each action. Repeated warnings without verified completion indicate a management failure, not a paperwork shortage.
Venue-safety and Martyn’s Law readiness checklist
Law and official guidance were checked on 1 November 2026. The substantive Martyn’s Law duties are not yet in force; this guide distinguishes preparation for the Act from fire-safety and licensing responsibilities that already apply. Venue decisions should reflect the building, licence, fire risk assessment, expected attendance and current official guidance.
- Confirm the venue’s current maximum occupancy and how live numbers are controlled.
- Assess whether 200 or more people, including staff, are reasonably expected from time to time.
- Check that every required escape route is clear for its full length.
- Confirm fire-exit doors are immediately usable when the premises are occupied.
- Remove unofficial fastenings, improvised barriers and re-entry workarounds.
- Define who can order evacuation, invacuation or lockdown.
- Plan how decisions will be communicated to staff and customers in a noisy venue.
- Brief door supervisors, temporary staff and contractors on their specific roles.
- Include disabled people and anybody who may need assistance.
- Test fire and terrorism procedures for conflict rather than reviewing each in isolation.
- Walk the arrangements during a representative busy period.
- Record actions, responsible people, deadlines and evidence of closure.
Do not wait for Martyn’s Law to fix an existing venue-safety weakness. Start with clear and immediately usable exits, accurate occupancy information and staff who understand the current emergency plan. Then build evacuation, invacuation, lockdown and communication procedures on foundations that work during the busiest part of the night.
This guide provides general information for UK employers. It is not legal advice and should not replace advice based on the facts of a specific matter.