Martyn’s Law: SIA provides further details on compliance support, templates and pilot inspections
This latest update builds on a series of developments since the introduction of the Terrorism (Protection of Premises) Act 2025, referred to as "Martyn's Law" and our previous coverage of the legislation, including:
- Martyn's Law: What's the latest and what steps should businesses be taking? (7 February 2024)
- Martyn's Law receives Royal Assent (4 April 2025)
- Martyn's Law: An update following final statutory guidance (23 April 2026)
With Martyn's Law expected to come into force in spring 2027, attention is now turning from the requirements of the legislation itself to how compliance will work in practice.
On 11 September 2026, Laura Gibb, Executive Director for Martyn’s Law at the SIA published a further update covering scope assessments, the development of compliance templates, the SIA's pilot assessment and inspection programme, and plans for the forthcoming notification portal. The update gives organisations a better indication of what to expect from the regulator, although important parts of the regulatory model are still being developed.
Greater clarity on compliance
Determining whether premises or events are in scope remains the first practical challenge. Recognising that many organisations are still uncertain whether the legislation applies to them, the SIA has highlighted the availability of flowcharts on ProtectUK and examples contained within the Home Office’s Section 27 guidance. In addition, the SIA is developing an online assessment tool that will help organisations determine whether Martyn’s Law applies to their premises or events. These tools should help with straightforward cases, but more complex premises will still require judgement.
Compliance templates in development
The SIA is developing separate templates for standard tier and enhanced tier premises and events. The standard tier template is intended to help organisations record the procedures they have implemented, or plan to implement, to respond to a terrorist incident. The enhanced tier template will also address the additional requirements applicable to larger premises and events, providing a framework for documenting both procedures and security measures.
Once published, these templates should prove a valuable tool for organisations preparing for the new regime, but they should not be treated as a shortcut to compliance. It is important that plans remain proportionate and site-specific arrangements are in place.
Pilot assessments and inspections continue
The SIA has completed an initial round of pilot exercises, designed to test and refine both its compliance tools and future inspection approach. Accordingly, the pilots have provided useful insight into the practical challenges organisations may face when implementing Martyn’s Law and have helped inform how inspectors can gather information without disrupting the day-to-day operation of premises and events.
A second round of pilot assessments and inspections is scheduled to begin during autumn 2026. The SIA has expressed its appreciation to volunteers participating in the programme and indicated that feedback from these exercises is directly influencing the development of its regulatory approach.
Guidance on “principal use” of premises
The update also draws attention to recent Home Office guidance on determining the "principal use" of premises, this is particularly relevant where a single premises is used for multiple purposes. Responsibility will generally fall on the person who controls the premises for its principal use, which is assessed by reference to factors including its purpose, design, physical characteristics and overall use, rather than simply which activity attracts the most people. For example, a sports stadium may remain principally a sports ground even where it also hosts conferences, meetings and tours.
The guidance is helpful, but as the examples illustrate, determining a premises' principal use is a fact-specific exercise. Operators of mixed-use premises should therefore document the basis on which they identify the principal use and responsible person.
Progress on the notification portal
The SIA also provided further detail on the forthcoming notification portal, which will be used by organisations to notify the regulator of premises and events falling within the scope of Martyn's Law.
The portal will be available through GOV.UK and is being actively tested with volunteers to help refine its functionality and ease of use. The focus on testing is encouraging and should help ensure the process is workable for organisations of different sizes, although its effectiveness in minimising the administrative burden will only become clear once the portal is launched and used in practice.
Looking ahead: preparing for implementation
The SIA's latest update shows useful progress. The development of compliance templates, the continued programme of pilot assessments and inspections, and progress towards the launch of the notification portal all demonstrate a clear focus on making the new requirements as practical and accessible as possible. However, it is important to ensure that compliance does not become a "tick-box" exercise focused solely on documentation, but instead supports meaningful preparedness, staff awareness and effective response planning.
In light of this, duty holders may wish to:
- assess whether their premises or events are likely to fall within scope of Martyn's Law, making use of the available Home Office guidance and ProtectUK resources;
- identify the appropriate responsible person, particularly where premises have multiple uses or complex management arrangements;
- review existing incident response procedures to consider whether they align with the response-focused requirements of the new regime;
- begin documenting procedures, governance arrangements and decision-making processes ahead of the publication of the SIA's compliance templates;
- ensure that relevant personnel are aware of the forthcoming obligations and responsibilities that may arise under Martyn's Law; and
- continue monitoring guidance and updates from the SIA, particularly in relation to inspections, compliance expectations and the notification portal.
Organisations do not need to wait for the remaining SIA tools and processes to be finalised. The implementation period should be used to test existing arrangements, address gaps and be ready to demonstrate the practical steps taken to prepare.