Martyn’s Law: SIA consultation clarifies regulatory approach for businesses and venue operators

 The Terrorism (Protection of Premises) Act 2025, commonly known as Martyn’s Law, is named in memory of Martyn Hett, one of the 22 people killed in the Manchester Arena bombing. The law follows years of campaigning by his mother, Figen Murray OBE, to strengthen public protection against terrorist attacks.

The progress of implementation of Martyn’s Law took an important step forward on 15 April 2026 when the Security Industry Authority (SIA) launched a public consultation on its draft section 12 statutory guidance. This explains how it proposes to exercise its functions as regulator under the Terrorism (Protection of Premises) Act 2025. The SIA expressly states that it is not inviting views on the Act and its policy merits, so clients responding to the consultation should focus comments on whether the guidance is clear, workable and proportionate, and whether the SIA’s proposed regulatory processes are understandable and fit for purpose.

This is a significant development for organisations responsible for premises and events that may fall within the scope of Martyn’s Law (Martyn’s Law: Guidance for venues, premises and event organisers). While the legislation itself received Royal Assent on 3 April 2025, the detailed regulatory framework is awaited with interest by businesses, venue operators and event organisers seeking greater clarity on how it will work in practice. This consultation marks the next stage by consulting on the draft guidance that will govern the regulatory approach.

Understanding the SIA’s role

Significantly, this consultation is not about what duty holders must do to comply with the Act. The official consultation page makes clear that the SIA’s section 12 guidance is intended to sit alongside the Home Office’s section 27 guidance. In broad terms, the Home Office guidance addresses the compliance requirements of the Act, while the SIA’s guidance addresses how the regulator will oversee and enforce compliance.

For our clients, that distinction matters. The draft section 12 guidance is concerned with regulatory method and tone, and explains that the regulator intends to take a supportive, proportionate and risk-based approach. It covers how the SIA will support compliance, including when it may offer tailored advice, how it will obtain and share information, conduct inspections and assess compliance documents, as well as how it will deal with non-compliance, including enforcement and financial penalties.

That will be welcome news to organisations that have been concerned not only about the substance of Martyn’s Law, but also about how it will be policed in practice. The SIA’s published material suggests a regulator seeking to position itself as both practical and protective: one that is focused on public safety, but also conscious of the need for clarity, engagement and proportionality in the way it exercises its new powers. The consultation material suggests that the draft guidance is designed to make the legislation more accessible to operators and advisers reviewing the regime for the first time.

What comes next?

The official materials also confirm that the consultation is likely to be relevant to a wide group of stakeholders. This includes businesses and individuals responsible for premises and events that will be in scope, those advising or supporting them, people with responsibilities under the new law such as designated senior individuals; those who may owe duties of co-operation and others with a wider interest in protective security or regulation. In other words, this is not a niche consultation for regulators alone, but one that many organisations in the leisure, hospitality, retail, visitor attraction and events sectors should review carefully.

Timing is also important. The Act is expected to come into force in Spring 2027 and the SIA indicates that further practical information will follow nearer commencement, including details of how and when responsible persons should notify the SIA that they are in scope once its online system is in place. This means the consultation is one step in a wider implementation programme, rather than the final word on operational compliance.

As a follow-up to our earlier commentary on Martyn’s Law, this latest development reinforces the need for potentially affected businesses to keep the issue under review.

How we can help

At Anderson Strathern, we are monitoring the implementation of Martyn’s Law closely and continue to work with clients to provide advice on what they can expect. For clients who may be affected, this consultation is an opportunity to gain an early understanding of how the SIA expects to regulate the new regime and to shape that approach where appropriate before commencement. We can assist with reviewing whether your organisation may be affected; advising on the emerging regulatory framework and helping you prepare for the next stages of implementation.

In the meantime, the deadline for responding to the consultation is 12 June 2026. Once the consultation closes, a final version will be placed before the SIA Board and the Secretary of State for approval. A final version will be published and should be available prior to the Act coming into effect.

If you have any questions regarding Martyn’s Law, get in touch with Julia McDonald or a member of our team.

Added resources

Consultation: Martyn’s Law: draft section 12 statutory guidance – GOV.UK

The SIA are also now recruiting for an inspector: Head of Inspections for Martyns Law Regulator – Civil Service Jobs – GOV.UK