Preparation and Love: Churches and Martyn’s Law

In May 2017, 22 people were sadly killed and over 1,000 people were injured when terrorists targeted a music concert in Manchester.

This, along with other incidents in which members of the public have been the target of terrorist activities, has been the catalyst for new legislation designed to improve security and preparedness in venues where the public gather.

The Terrorism (Protection of Premises) Act 2025 (also known as ‘Martyn’s Law) will come into force in April 2027, and new statutory duties will apply to buildings across the UK, including churches, where larger numbers of people gather. 

Premises where more than 200 people could be reasonably expected to gather will be covered by the legislation and divided into two tiers: standard and enhanced. All churches who could reasonably expect more than 200 people will fall into the “standard tier”; the provisions for the enhanced tier (more than 800 present) do not apply to churches.

Churches who do not expect over 200 people to gather, do not fall within the scope of the legislation and do not have statutory duties. However, they may wish to consider whether any measures are appropriate as part of their wider emergency planning.

The guidance sets out that “the greatest expected number of individuals at the premises at the same time” should be used to decide if a building is within the scope of the legislation, rather than regular attendance or capacity limits set by other legislation (for example safe occupancy under fire safety legislation).

Churches will therefore need to consider all their events across a year; for example, a church with a regular attendance of 150 people may have over 200 people attend their carol service and so they will be required to comply with the statutory duties.

Churches who meet in rented premises (for example a community centre or school) will be required to cooperate with the person responsible for the building to comply with any duties.  The organisation or individual with whom the church has the letting agreement or their representative is likely to be the responsible person.

Implementation of the requirements is not required until the Act comes in to force in April 2027, but the statutory guidance was published in April 2026 to allow organisations to prepare.

Identify who will be the ‘responsible person’

The statutory guidance indicates that the ‘responsible person’ should be the individual or legal entity with control of the premises. For churches this will usually be the trustees collectively.

The ‘responsible person’ cannot delegate their responsibility but may delegate tasks such as producing guidance for premises users, organising training, or overseeing practice drills.

In a church this might mean that the trustees delegate the day-to-day tasks to a deacon with responsibility for the property or to a member of staff such as an operations manager or facilities manager.

The Security Industry Authority (SIA) will be the regulator for the new legislation; they are expected to announce later in 2026 how premises will be required to register – registration itself will take place when the Act comes into force.

Put in place appropriate public protection measures

The Act does not require physical measures, such as changes to the building or bag checks, to be implemented in standard tier premises but does require the implementation of simple, low-cost public protection measures.

Churches should consider planning for:

• Evacuation: the process of getting people safely out of the premises
• Invacuation: the process of bringing people safely into, or to safer parts of, the premises
• Lockdown: the process of securing some or all of the premises to prevent individuals from entering or leaving
• Communication: the process of alerting people on the premises to the danger

Churches will need to carry out an assessment both of the risks specific to their location and premises and of what public protection measures are ‘reasonably practicable’ (a phrase taken from health and safety legislation and explored in this article).

The implementation of the required public protection measures will vary from church to church. However, every church within the scope of the legislation will need to make plans for each of the measures and assess whether further steps (such as practice drills) are appropriate.

Training

Whilst the Act does not make training mandatory, the guidance makes clear that a paper exercise without clear provision for rapid and effective implementation in the event of an attack would not meet the requirements; it is therefore likely that some training and guidance for relevant staff and volunteers will be necessary. 

Churches will need to consider who might need to take action and equip them to do so with information and guidance; this might include staff, stewarding teams, and those who lead groups or ministries which use the church premises.

For some, simply asking them to read a document and confirm that they have done so may suffice; for others, training may be more appropriate. Churches may also wish to consider printed quick reference guides for stewarding teams or group leaders.

Free online training is available covering identifying the risks and public protection measures (see below).

Whilst it is likely that a number of organisations will offer services to help those responsible for buildings falling within the scope of the legislation, the guidance from the Home Office is very clear: organisations do not need to spend any money on using specialist consultants or make physical changes to their premises to comply with the ‘standard tier’ requirements of the Act.

It is not a requirement of the statutory guidance that organisations adopt a policy, but it can be a helpful way of documenting the risks identified and the protective measures put in place. To that end we have produced a model document for those churches who would like to adopt a policy.

Where written policies or risk assessments are completed, it would be wise to ensure that while these should be made available to the appropriate individuals, they should not be widely accessible as such information could be used by an individual or group targeting a building to plan their attack.

For many churches, the risk of their activities being targeted may not feel high. But the consequences of any potential attack are significant.

The new legislation is designed to both increase preparedness and increase public confidence in security at venues where larger numbers gather. 

But, especially for churches, it is also a practical outworking of how we love, care for, and protect those who are part of our community.