MARTYN’S LAW FOR EDUCATION

Terrorism (Protection of Premises) Act 2025

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I have 22 years of Whitehall experience, specialising in counter-terrorism, serious organised crime and incident response. Heading the Department for Education’s Counter-Terrorism Protect, Prepare and Security Team, I was the first to lead on Counter-Terrorism Protect and Prepare for the education sector.

In this role, I developed Martyn’s Law proposals for the sector, working with trusted partners in education to develop legislation that was not too burdensome for the sector at the same time as improving preparedness and protecting our children and young people. I worked in partnership with Counter-Terrorism Policing colleagues to develop sector-specific support, training and guidance. I also provided bespoke support to education settings with specific concerns about protective security and incident response.

Sadly, we live in a world where security threats at education settings are evolving. This isn’t necessarily about terrorism, the rising number of young people carrying knives, the influence of gang culture, and poor mental health are all contributory factors. Putting in place sensible measures to protect settings from the threat from terrorism means they are better protected from and prepared for a range of threats — no matter the motivation. This is what makes this new legislation so important for our schools, colleges and universities.

I now work independently as a consultant supporting the education sector on counter-terrorism Protect and Prepare, incident response and lockdown. Although Martyn’s Law was enacted earlier this year, it is still not possible for any individual or company to offer guarantees of compliance. Statutory guidance is still in development and government and Counter-Terrorism Police have already provided a range of free guidance on the Protect UK Platform. I work with the education sector advising on counter-terrorism best practice to support preparedness in advance of statutory guidance for those settings that are keen to start the process of working towards compliance.

As Chair of Governors at my children’s primary school, I understand the daily pressures faced by the sector, juggling multiple priorities with limited budgets. I know that the sector needs clarity and succinct guidance to ensure it can prepare in advance of implementation of legislation. This document aims to raise awareness of new terrorism legislation, clarify what it means for the education sector specifically, and give some pointers for those settings that are keen to start preparing in advance of statutory guidance. I hope this gives a helpful insight into the legislation and what it means for your setting.

Contents

Introduction

I have 22 years of Whitehall experience, specialising in counter-terrorism, serious organised crime and incident response. Heading the Department for Education’s Counter-Terrorism Protect, Prepare and Security Team, I was the first to lead on Counter-Terrorism Protect and Prepare for the education sector.

In this role, I developed Martyn’s Law proposals for the sector, working with trusted partners in education to develop legislation that was not too burdensome for the sector at the same time as improving preparedness and protecting our children and young people. I worked in partnership with Counter-Terrorism Policing colleagues to develop sector-specific support, training and guidance. I also provided bespoke support to education settings with specific concerns about protective security and incident response.

Sadly, we live in a world where security threats at education settings are evolving. This isn’t necessarily about terrorism, the rising number of young people carrying knives, the influence of gang culture, and poor mental health are all contributory factors. Putting in place sensible measures to protect settings from the threat from terrorism means they are better protected from and prepared for a range of threats — no matter the motivation. This is what makes this new legislation so important for our schools, colleges and universities.

I now work independently as a consultant supporting the education sector on counter-terrorism Protect and Prepare, incident response and lockdown. Although Martyn’s Law was enacted earlier this year, it is still not possible for any individual or company to offer guarantees of compliance. Statutory guidance is still in development and government and Counter-Terrorism Police have already provided a range of free guidance on the Protect UK Platform. I work with the education sector advising on counter-terrorism best practice to support preparedness in advance of statutory guidance for those settings that are keen to start the process of working towards compliance.

As Chair of Governors at my children’s primary school, I understand the daily pressures faced by the sector, juggling multiple priorities with limited budgets. I know that the sector needs clarity and succinct guidance to ensure it can prepare in advance of implementation of legislation. This document aims to raise awareness of new terrorism legislation, clarify what it means for the education sector specifically, and give some pointers for those settings that are keen to start preparing in advance of statutory guidance. I hope this gives a helpful insight into the legislation and what it means for your setting.

Martyn’s Law: Background

The Terrorism (Protection of Premises) Act gained Royal Assent on the 3rd April 2025. Also referred to as Martyn’s Law, after Martyn Hett, one of the 22 victims of the Manchester Arena bombing in 2017 whose mother, Figen Murray, has campaigned tirelessly since his death for better public protection at venues and events. The legislation means that for the first time, premises and events in scope of this ‘Protect Duty’ will be legally required to consider the risk from terrorism.

The United Kingdom’s Counter Terrorism Strategy

The United Kingdom’s Counter Terrorism Strategy CONTEST is designed to reduce the risk of terrorism to the UK, its citizens and its interests overseas. CONTEST is built around four key objectives, often referred to as pillars:

Prevent

To stop people from becoming terrorists or supporting terrorism. Prevent focuses on challenging extremist ideologies, identifying individuals at risk of radicalisation, and providing early intervention and support. It operates through partnerships with schools, local authorities, police, and community organisations, ensuring that vulnerable individuals receive guidance before they engage in extremist activities. A central component of Prevent is Channel, a multi-agency program that assesses and supports individuals at risk of radicalisation.

Pursue

To disrupt terrorist attacks before they happen. The Pursue strategy aims at detecting, investigating, and disrupting terrorist activity. It involves close collaboration between law enforcement, intelligence agencies, and international partners to track and neutralise threats. Pursue focuses on identifying individuals involved in terrorism, preventing travel for extremist purposes, and cutting off financial and logistical support for terrorist networks. Advanced techniques such as surveillance, digital forensics, and financial investigations are used to dismantle plots and bring perpetrators to justice.

Protect

To strengthen security measures to prevent attacks. The aim of Protect is to enhance security measures and safeguard public spaces against terrorist threats. It focuses on reducing vulnerabilities in critical infrastructure, crowded places, and transport networks by implementing physical security enhancements, surveillance systems, and access controls. Protect also involves collaboration between government agencies, businesses, and local authorities to ensure that security measures are proactive and adaptable to evolving threats. The strategy plays a crucial role in mitigating risks, ensuring that the UK remains resilient against potential attacks.

Prepare

To minimise the impact of an attack and improve response capabilities. The aim of Prepare is to ensure resilience and effective response in the event of a terrorist attack. It focuses on emergency preparedness, crisis management, and recovery planning, ensuring that individuals, businesses, and government agencies can respond swiftly and minimise harm. Prepare includes training for first responders, public awareness campaigns, and exercises to test emergency response plans. It also ensures that victims and affected communities receive support in the aftermath of an attack.

Martyn’s Law covers both the Protect and Prepare elements of CONTEST.

A Changing Threat

Until 2020 the ‘Crowded Places Strategy’ was a key element of the Protect pillar. This initiative aimed to reduce the vulnerability of public spaces to terrorist attacks. It provided guidance for businesses, local authorities, and security professionals on how to design, manage, and protect areas where large numbers of people gather, such as shopping centres, stadiums and transport hubs. The strategy emphasised risk assessment, physical security measures, and emergency preparedness, ensuring that crowded places were resilient to potential threats.

The Crowded Places Strategy was built to protect against the threat from terrorist groups such as Al-Qaeda. Al-Qaeda’s peak period of influence was between the late 1990s and early 2000s. During this time, the group carried out major terrorist attacks, including the 1998 U.S. Embassy bombings in Kenya and Tanzania, the 2000 USS Cole bombing, and the September 11 2001 attacks in the United States. Following 9/11, the United States launched the War on Terror, leading to the invasion of Afghanistan and the dismantling of Al-Qaeda’s central leadership. While the group remained active, its influence declined as counter-terrorism efforts intensified and rival extremist organisations, such as ISIS, emerged.

The decline in influence of Al-Qaeda and the emergence of ISIS, alongside technological advancements such as the internet, led to a significant change in terrorist modus operandi (M.O.) as we moved into the second decade of the 21st Century. Terrorists no longer needed to be centrally directed by these organisations: information and propaganda was much easier to share online, and travel across the world to learn how to make or use weapons was less important as such information was now far more accessible.

In 2014, ISIS spokesperson Abu Muhammad al-Adnani, made a now infamous speech which encouraged ISIS supporters to carry out terrorist acts globally. This speech marked a shift in ISIS strategy, urging followers to use any means possible to target civilians and governments in Western nations. This led to an increase in lone-wolf attacks carried out by people inspired by, rather than directly linked to terrorist organisations. These attacks tended to be less sophisticated using less ‘conventional’ weapons such as vehicles and knives.

This change in M.O. meant that attack planning was harder to detect for intelligence services and law enforcement, as lone-wolves were not part of a wider network, and weapons being used were everyday items, the procurement of which was less likely to raise suspicion.

2017: A Catalyst for Change

Between March and September 2017 there were 5 terrorist attacks in the UK that resulted in the death of 36 people and injuring hundreds more. The Manchester Arena bombing was one of these but in fact it was the attacks at Westminster, London Bridge and Finsbury Park Mosque, where vehicles and knives were used a weapons, that led to a significant change in Government strategy from protecting crowded places and iconic sites to protecting people wherever they might go about their daily business. Inquests and Inquiries following the 2017 attacks underlined this need for change and ‘Protect Duty’ legislation was added to political manifestos prior to the December 2019 election.

The Crowded Places Strategy was eventually withdrawn in 2020 and replaced by the Publicly Accessible Locations Strategy – focussing on better protecting people wherever they are. The principles of the Crowded Places Strategy continue to influence modern counter-terrorism policies, including Martyn’s Law and the Protect Duty framework, but their influence is broader because of this change in threat. Martyn’s Law is one enabler of this wider Protect strategy. Finally, after many years of lobbying, consultation and development, the bill was enacted in April 2025.

Martyn’s Law – An Overview

The Terrorism (Protection of Premises) Act 2025 aims to improve security and emergency preparedness across the UK. It places responsibility on those managing specific locations and events to put in place emergency response plans for potential terrorist threats. Additionally, larger premises and events must implement appropriate measures to reduce their vulnerability to attacks. These larger premises sit within the ‘Enhanced Tier’ of the duty. Smaller premises sit else sits within the ‘Standard Tier’.

Scope

The Act applies to both premises and events, with specific criteria determining whether an organisation falls within its scope.

Premises

A location is considered within scope if it meets all of the following conditions:

  1. It contains at least one building or operates within a building.
  2. It is primarily used for one or more designated activities listed in Schedule 1 of the Act—for example, a cinema providing entertainment or a school offering education.
  3. It can reasonably expect at least 200 individuals to be present at times, increasing to 800 for enhanced-tier premises.
  4. It is not among the exclusions detailed in Schedule 2 of the Act.

Events

An event is covered by the legislation if it meets the following criteria:

  1. It takes place at a qualifying location under section 3(1)(a) of the Act, including land without buildings, provided it is not already classified as an enhanced-duty premises.
  2. The venue is accessible to the public during the event.
  3. It is expected to host at least 800 individuals at any one time or throughout the event.
  4. Entry conditions are enforced through measures such as ticket checks.
  5. The event is not among those excluded under Schedule 2 of the Act.

Tiers

To ensure proportionality there are two tiers of the Act: A Standard Tier and an Enhanced Tier. The Standard Tier is for smaller premises where it is reasonable to expect that between 200 and 799 people may be present. The focus of the Standard Tier of the duty is on preparedness measures to mitigate the impact of terrorist attack were it to occur (Prepare).

The Enhanced Tier is for larger premises (800 or above). As well as putting in place preparedness measures to mitigate the impact of a terrorist attack, Enhanced Tier premises will also need to have in place appropriate measures to reduce the vulnerability of the premises (Protect).

Standard Tier (200-799 people)

Focus on preparedness measures to mitigate the impact of terrorist attack were it to occur (Prepare).

Enhanced Tier (800+ people)

Preparedness measures PLUS appropriate measures to reduce the vulnerability of the premises (Protect).

Standard Duty Requirements

Premises falling under the Standard Duty must appoint a responsible person who will be required to:

  • Register the premises with the Security Industry Authority (SIA); and
  • Implement appropriate public protection procedures, where reasonably practicable.

Staff should be guided by clear procedures detailing how to respond if a terrorist incident occurs on-site or nearby. These measures could include evacuation, invacuation (moving people to a secure indoor location), lockdown protocols, as well as effective communication strategies to support these measures.

Enhanced Tier Requirements

For premises or events expecting 800 or more people, those classified under the Enhanced Tier must go beyond Standard Duty requirements by implementing additional protective measures:

Public Protection Measures

Where reasonably practicable, venues must take proactive steps to reduce their vulnerability to terrorism and minimise the risk of harm in the event of an attack. This includes monitoring the premises and its immediate surroundings.

Risk Documentation

Organisations must record and submit details of existing or planned protection measures to the Security Industry Authority (SIA), the designated regulator. This documentation—essentially a risk assessment—should outline how security strategies mitigate vulnerabilities.

Senior Responsible Person

If an entity is not operated by a single individual, it must appoint a senior responsible person to oversee compliance with the Act’s requirements.

Responsible Persons

Premises

The responsible person for a qualifying premises is the person overseeing its primary function, as defined in Schedule 1 of the Act. For example:

  • At a sports ground or hotel, this would be the person managing daily operations.
  • If a building serves multiple purposes (e.g., a church that also runs a crèche), the responsible person is the one overseeing the primary activity of the site.

Events

For qualifying events, responsibility depends on who controls the premises at the time of the event:

  • If an event company takes control of part of a public space (e.g., a concert in a park), the event company assumes responsibility.
  • If a stately home hosts a concert within its grounds but continues managing the space, the stately home remains responsible—even if some aspects (such as security or ticketing) are contracted to third parties.

Regulation

To ensure effective enforcement of the regime, a new regulatory function has been established within the Security Industry Authority (SIA). The SIA will provide support and guidance to those responsible for premises and events, helping them comply with the legislation. In cases of serious or persistent non-compliance, the SIA will have the authority to issue compliance notices, impose monetary penalties, and enforce restriction notices. Additionally, the SIA will be required to develop statutory guidance outlining how it will carry out its responsibilities under the Act.

Before the legislation comes into force, there will be a transition period to allow for its implementation. This period is expected to last at least 24 months, providing time for the regulator to be established and ensuring that those responsible for relevant premises and events have sufficient opportunity to understand their obligations, plan accordingly, and prepare for compliance.

Martyn’s Law For the Education Sector

A Special Case for Education

When developing proposals for Martyn’s Law legislation for the education sector, it was important to work closely with experts from across the sector to ensure that proposals were informed, sensible, and proportionate. The general consensus was that the sector should be within scope of the duty, but there were valid concerns about the potential financial implications on large schools and colleges already struggling with limited resources that might fall within the Enhanced Tier. It was also unclear how admission numbers, that might fluctuate from year to year, would impact where settings fall within the tiers. It was also clear that many settings were not as open as other premises within scope such as universities or shopping malls.

It was agreed that a proportionate response for education settings that already adhere to strict safeguarding legislation, was that they should all sit within the Standard Tier of the Duty; no matter the maximum capacity. So all childcare settings, schools, colleges and training providers that are within scope of statutory safeguarding legislation, that have over 200 capacity, will sit within the Standard Tier of the duty. A school with 1000 capacity for example, will still sit within the Standard Tier. A school with 180 will not be in scope of legislation at all.

For education settings sitting within the Standard Tier that host an event for over 800 people, this event will remain within the Standard Tier. Again, this is another exception for the education sector. Higher Education settings are not included in any exceptions and will fall within scope based on capacity.

Key Decision for Education Settings:

All childcare settings, schools, colleges and training providers that are within scope of statutory safeguarding legislation, that have over 200 capacity, will sit within the Standard Tier of the duty – no matter the maximum capacity.

  • A school with 1000 capacity will still sit within the Standard Tier
  • A school with 180 will not be in scope of legislation at all
  • Events hosted by Standard Tier education settings remain in Standard Tier (even if 800+ attendees)
  • Higher Education settings are not included in exceptions and fall within scope based on capacity

Complexities

There will be many education settings that are within scope of the Standard Tier that have complex sites with multiple operators (such as sports centres, theatres and so on) that are concerned where they will fall and the implications of the legislation on their sites. Statutory guidance will clarify how operators will need to work together to ensure compliance with legislation but the special consideration for education will remain.

Standard Tier Requirements for Education Settings

Applies to: Childcare settings, schools, colleges and training providers with over 200 capacity that must already adhere to statutory safeguarding legislation.

What this means: The focus of the Standard Tier is mitigating the impact of a terrorist attack were it to occur. This is about having in place effective emergency response plans that are understood by all employees. This is not about changes to physical security infrastructure. All settings within scope will be required to register with the regulator.

Emergency Response Procedures

Evacuation

Evacuation is the process of moving people away from a dangerous area to a safer location. It is commonly used in emergencies such as fires. Evacuation procedures typically involve clear communication, designated escape routes, and safe assembly points to ensure the orderly and efficient removal of people away from harm.

Most settings will already have in place evacuation plans for fire. In the context of counter-terrorism, plans may differ from fire evacuation procedures. Standard Tier settings should review their existing evacuation plans through the lens of terrorism to assess whether they would be effective. This could include considering bomb threats, suspicious packages or fire after suspicious behaviour, where dynamic decision making might be required to move people away from a specific area or even disperse if safer to do so.

Invacuation

Invacuation refers to the process of moving people to a safe location inside a building when there is a threat outside or in another part of the premises. Unlike evacuation, which involves leaving a building, invacuation ensures people remain indoors, protected from external dangers such as terrorist incidents or other violent disturbances. Invacuation is a key part of emergency response planning, helping to minimise risk and ensure safety until the threat is neutralised. Invacuation can be the first step of a lockdown. For example in a school where a threat is identified in the playground during lunch break, the first step would be to invacuate to a place of safety (inside the school). The building would then be locked down to prevent the threat from entering the building.

Lockdown

Lockdown is a security measure used to restrict movement within or access to a location in response to a threat. Lockdown ensures people stay inside to minimise exposure to a threat. Lockdown procedures typically involve locking doors, securing windows and staying out of site if possible. Where the threat is outside, lockdown can involve securing points of entry and egress. Where a threat is inside a building, lockdown can be applied to individual rooms and spaces. Where there is a significant threat to life, such as in a terror attack, the aim of lockdown is to make the building or room appear unoccupied.

Developing proscriptive guidance on lockdown is difficult as infrastructure differs between settings. Instead, the principles of lockdown should be applied across individual education settings to develop effective plans that are workable for each unique premises.

Communication

Critical to effective emergency response planning is the ability to communicate a response across a site. Without the means to communicate a specific response, plans cannot be quickly implemented and are therefore ineffective. With the introduction of new terrorism legislation, emergency communication solutions are evolving to ensure faster, more effective responses in crisis situations. Businesses, venues, and public spaces are increasingly adopting advanced alert systems, real-time monitoring tools, and coordinated response frameworks to improve safety and preparedness. These developments aim to minimise response times, provide clear guidance, and ensure swift action during threat situations.

Communication Considerations for Education Settings

Education settings are by their very nature complex, often with vulnerable people due to age or special educational needs and disabilities. Settings should consider the unique characteristics of their communities when reviewing emergency response plans; especially when considering technical solutions for communication. There are a number of options on the market that include:

Audible alerts

Visual alerts in the form of beacons

Visual alerts on networked devices

Solutions that allow for continuous comms during a lockdown such as apps

As education sites are often large with indoor and outdoor areas, any comms solutions should ideally be able to alert both internally and externally, with the ability to raise the alarm from multiple locations.

Enhanced Tier Requirements for Education Settings

Applies to: Universities and other Higher Education Providers that have over 800 capacity.

What this means:

  1. The setting must meet all the requirements as outlined above in the Standard Tier section which will be detailed within statutory guidance when published.
  2. They must also:
    • Designate a senior responsible person
    • Assess the risk from terrorism to the site and put in place appropriate public protection measures, where reasonably practicable, to minimise both the vulnerability of the premises or event to terrorism and the risk of physical harm to individuals in the event of an attack.
    • Provide the SIA, as regulator, with a document outlining existing or planned public protection procedures to address vulnerabilities and mitigate risk (as outlined in statutory guidance when published).

What can settings do to prepare prior to guidance being published?

Historically many universities were within the scope of the Crowded Places Strategy and already have in place control measures to mitigate the risk from terrorism. For those smaller universities that might not have considered terrorism risk before, doing this for the first time may appear daunting. The government’s ProtectUK website is a library of free guidance to support sectors and organisations consider the risk from terrorism.

I advise clients to look at their sites though the worst-case scenario lens; Review your site through the eyes of someone with malicious intent to assess how easy it would be for them to access your site to commit an act of terror. When you start to identify vulnerabilities, you can then assess what measures you could consider to reduce vulnerability to better protect your site.

Reference Materials and Resources

  • UK Government Factsheets: These provide official summaries and explanations of the Act. You can find them here
  • Legislation.gov.uk: This site contains the full text and explanatory notes for the Act. You can access it here

The links below give further advice and guidance on counter-terrorism best practice for settings keen to prepare in advance of statutory guidance:

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