Martyn’s Law – what you need to know as an independent retailer (and actions to take)

Martyn’s Law will introduce new legal duties for certain publicly accessible premises to prepare for potential terrorist incidents. Independent retailers should now assess whether they are in scope and begin proportionate planning ahead of implementation from 2027 at the earliest.

The Terrorism (Protection of Premises) Act 2025, widely known as Martyn’s Law, received Royal Assent on 3 April 2025. The legislation is designed to improve protective security and organisational preparedness in the event of a terrorist attack.

There will be an implementation period of at least 24 months from April 2025, meaning the Act is not expected to come fully into force until 2027 at the earliest. During this time, the government will publish statutory guidance to help those in scope prepare for compliance. However, it’s vital to know relevant information now in order to fully prepare.

If you are an independent retailer, you may fall within the scope of the Act depending on the size and use of your premises. When the Act was initially proposed, the tier system was designed around the physical floor space of your premises, much like fire safety regulations, but through consultation with organisations like Bira, the tiers were changed to focus on reasonable expectation of visitor and employee capacity at any one time[.

You do not need to take action immediately but early planning will make compliance simpler and more cost-effective. If you are extremely unlikely to ever see 100+ people inside your premises, which may apply to most Bira member, you will be outside of scope, but we still encourage you to make considerations and be prepared should the worst case occur.

What is Martyn’s Law?

Martyn’s Law (formally the Terrorism (Protection of Premises) Act 2025) introduces legal duties on those responsible for certain premises and events to consider the risk of terrorism and to put proportionate protective measures in place.

There are tiers to the Act designed to help keep expected changes proportional.

Standard Tier

Applies to qualifying premises with a capacity of 100–799 individuals.
Requirements focus on:

• Having appropriate procedures in place in the event of a terrorist incident.
• Ensuring staff understand how to respond.

This tier is designed to be straightforward and low-cost.

Enhanced Tier

Applies to premises and events with a capacity of 800 or more individuals.

Requirements are more detailed and may include:

• Documented risk assessments.
• Additional protective security measures.
• Formalised security planning.

For most independent retailers, the standard tier is the more likely category, particularly for high street shops, small supermarkets and retail units in shopping parades. However, larger destination stores or those operating any sort of event spaces may need to consider enhanced requirements.

The Security Industry Authority (SIA) will act as the regulator, and detailed statutory guidance is expected from the Home Office during the implementation period.

What Martyn’s Law will cost for independent retailers

Martyn’s Law is designed to be proportionate, meaning most independent retailers are not expected to face significant upfront costs. The emphasis is largely on procedures and preparedness rather than expensive physical security upgrades.

The government has made clear that there is no requirement to purchase specific products or services, and no obligation to comply until the Act comes into force (expected from 2027 at the earliest).

Standard tier (100–799 capacity)

For most independent retailers, costs are likely to be low and largely time-based rather than capital expenditure.

Typical areas of investment may include:

• Management time to document emergency procedures.
• Reviewing or updating evacuation, lockdown and communication plans.
• Staff awareness training (free ACT Awareness and SCaN courses are available).
• Minor updates to signage or internal processes.

Many retailers will already have health and safety procedures in place, meaning compliance may involve formalising and recording existing practice rather than introducing new systems.

Financial impact: Minimal to low

Enhanced tier (800+ capacity)

Larger retail premises may face moderate additional costs, depending on current arrangements.

• Potential areas of spend could include:
• Professional risk assessment support (if external advice is sought).
• More detailed documentation and security planning.
• Reviewing physical security measures where reasonably practicable.

The legislation does not mandate major security or blanket installation of equipment, with measures proportionate to risk and premises size.

Financial impact: Moderate (depending on existing security maturity)

Overall cost outlook

• No immediate compliance costs before the Act comes into force.
• Free government-backed training and guidance are already available.
• For most independent retailers, investment is expected to focus on planning, documentation and staff awareness, not infrastructure.

Early preparation may also reduce future compliance pressure and potential disruption once Martyn’s Law is fully implemented.

What independent retailers need to think about when it comes to Martyn’s Law

1. Are you in scope?

Start by considering:

• What is the maximum capacity of your premises?
• Is your shop accessible to the public?
• Do you host events (e.g. launches, late-night shopping, markets)?
• Are you located within a larger premises (e.g. shopping centre)?

Retailers within shopping centres may have shared responsibilities alongside centre management.

To better understand scope, retailers can access official factsheets and updates via ProtectUK, the government’s counter-terrorism protective security platform, here.

2. Your existing security arrangements

Martyn’s Law builds on good practice many retailers already have in place.

Consider:

• Do you have a documented emergency plan?
• Are lockdown, invacuation and evacuation procedures defined?
• Do staff know what to do in a serious incident?
• How would you communicate with staff and customers?

For many independent retailers, compliance may involve formalising and documenting procedures that already exist informally.

3. Staff awareness and training

Under the standard tier, the emphasis is on preparedness rather than physical security upgrades.

Retailers should review:

• Are staff aware of the current terrorism threat level?
• Would they recognise suspicious behaviour?
• Do they know how to respond quickly and safely?

Free awareness training is already available, including:

• Act Awareness e-learning (via ProtectUK)
• See, Check and Notify (SCaN) training

While completing these courses does not itself make a business compliant, they help build a strong security culture.

4. Proportionate measures

The Act is intended to be proportionate, and for retailers can be instead thought of in terms of:

• Clear procedures
• Staff briefings
• Simple communication plans
• Defined leadership during incidents

For most small and medium-sized retailers, procedural preparedness will be the key requirement.

Actions to take now

Although the Act is not yet in force, retailers can prepare in practical ways.

1. Confirm whether you are likely to fall within scope: Review your maximum capacity and how your premises operate.

2. Assign responsibility: Identify who in your business is responsible for security planning — owner, store manager or operations lead.

3. Review your emergency procedures: Document your approach to:

• Lockdown
• Evacuation
• Invacuation (bringing people inside to safety)
• Communication during an incident

4. Upskill staff: Encourage staff to complete free awareness training and include terrorism preparedness in induction processes.

5. Monitor official guidance: Follow updates from:

• ProtectUK
• The Home Office
• The Security Industry Authority
• Statutory guidance will clarify exactly what is required for compliance.

6. Contact your health and safety advisor: Bira Legal are available to advise Bira members on all aspects of Health & Safety for your business.

Wider good practice for independent retailers

Even if your premises fall below the 100-person threshold, developing a security-aware culture is good business practice.

Consider:

• Regularly reviewing CCTV placement and maintenance.
• Encouraging staff vigilance without causing alarm.
• Establishing a clear reporting route for suspicious activity.
• Coordinating with neighbouring businesses and BIDs

Terrorist attacks on retail locations are rare, but retail premises are publicly accessible spaces. Proportionate planning reduces risk and supports faster response.

Key dates at a glance

• 3 April 2025 – Royal Assent granted.
• 2025–2027 (minimum 24 months) – Implementation period.
• From 2027 (expected) – Legal duties come into force.
• During implementation – Government and SIA guidance to be published.

The key takeaways for independent retailers

Martyn’s Law introduces a legal duty to consider and prepare for the risk of terrorism in publicly accessible premises. For most independent retailers, this will centre on clear procedures, staff awareness and proportionate planning rather than major capital expenditure.

There is no requirement to act immediately. However, early preparation, particularly around documentation and staff awareness, will reduce pressure once the Act comes into force.

Retailers who take steps now to review and strengthen their emergency procedures will be better placed to protect staff, customers and their businesses when Martyn’s Law becomes law in practice.

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