Martyn's Law: The Commencement Clock Has Started

The first commencement order under the Terrorism (Protection of Premises) Act 2025 has been made. S.I. 2026/320 brings section 27 of the Act into force on 10 April 2026. From that date, the Home Secretary is under a statutory duty to issue guidance about Part 1 requirements. That duty did not exist before this order. It exists now.

What just happened

Section 27 requires the Secretary of State to issue guidance about the duties the Act places on operators of qualifying premises and events. Until this month, that section was not in force. The Home Office was preparing guidance voluntarily. From 10 April, preparing it is a legal obligation.

This is the first statutory instrument made under the Act. No other sections have been commenced. The duties on operators (procedures, measures, notification, documentation) remain uncommenced and are not expected before Spring 2027.

What this means

The statutory guidance is the document that will define what "appropriate" procedures and measures look like in practice. Acting in accordance with it will tend to establish that an operator did not contravene the Act's requirements. It is the single most important document for compliance planning, and it does not exist yet.

What changes on 10 April is the legal pressure to produce it. The Home Office has said it expects to publish the guidance for consultation during 2026. The SIA's enforcement guidance under section 12 will follow after that consultation.

The timeline now looks like this: statutory guidance duty in force (10 April 2026), guidance published for consultation (expected later in 2026), SIA enforcement guidance consulted on, then commencement of operator duties (Spring 2027 at the earliest).

What this does not mean

Your pub, hotel, or venue does not have duties under the Act today. The four procedure types (evacuation, invacuation, lockdown, communication) are not legally required until the operative sections are commenced by a further statutory instrument. Nobody from the SIA will be inspecting your premises or issuing penalties. That power does not yet exist.

If anyone tells you otherwise, or tries to sell you a "compliance solution" before the statutory guidance has even been published, treat that with scepticism. The Home Office Myth Buster (November 2025) is direct on this point: neither the Home Office, the SIA, nor NaCTSO endorses any third-party product or service for Martyn's Law compliance.

What to do now

Use the implementation window. The Act is law and its structure will not change. What you can do now costs nothing and positions you well for when duties commence:

1. Work out whether your premises is likely in scope. The threshold is 200 individuals, including staff, across all areas including beer gardens and outdoor space. The test is whether that number could reasonably be expected "from time to time," not routinely.
2. Complete the free ACT Awareness e-learning from ProtectUK. It takes about 45 minutes per person and covers recognising hostile reconnaissance and understanding attack methodologies.
3. Think about what invacuation and lockdown would look like in your building. You almost certainly have a fire evacuation plan. Terrorism response includes the opposite: bringing people inside and securing the building. That is the single biggest gap between fire safety compliance and Protect Duty readiness.
4. Read the ProtectUK Top Tips document (February 2026) for practical starting points on lockdown and invacuation planning.

Do not hire consultants. Do not buy compliance packages. The government has designed the standard tier so that operators can comply without specialist help. Wait for the statutory guidance, then act on it.