Martyn's Law by premises type
Martyn's Law for Cinemas
Where this is up to
It's law. Not in force yet. The SIA is already rehearsing.
The Terrorism (Protection of Premises) Act 2025 received Royal Assent in April 2025. The duties are not yet in force: they commence after 3 April 2027, and the SIA says it is working toward spring 2027. The notification rules arrived in July 2026, so you now know what the SIA will ask for. The regulator is running voluntary pilot inspections while it builds the regime; statutory inspections and enforcement start only when the duties do. The work now is recording your scope, your procedures, your staff awareness, and the notification data.
- Apr 2025 The Act received Royal Assent
- Apr 2026 Home Office statutory guidance first published
- Jun 2026 SIA regulatory guidance consultation closed; the final version is due in autumn 2026
- Jul 2026 Notification rules, deadlines, and data requirements published
- Spring 2027 SIA target for commencement; after 3 April 2027, exact date not set
Worth doing now
- Confirm the number behind your tier, and keep the method you used to reach it.
- Draft the four procedures (evacuation, invacuation, lockdown, communication) and brief your team.
- Gather the notification data: responsible people, licences and certificates, and the sites and socials you advertise on.
- Start building records now, so they're there before duties commence.
Cinemas
A cinema is harder to count than it looks
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The number is the whole building at once
Staggered start times spread the audience across screens, so the question is how many people are in the building together, counting auditoria, foyer, queues, concessions and staff. It is not how full one screen is.
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Staggered showtimes need a peak model
Record how overlapping admissions and exits, foyer use, and concession queues were assessed, and that the tier follows the recurring busy weekend or holiday, not the quiet weekday average.
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When several screens let out together
Five to eight auditoria emptying within minutes send people into the foyer all at once, so the procedure needs a building-wide house-lights cue, a projection stop, and floor-walking sweeps with per-screen scripts.
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Late screenings run on a skeleton team
An 11pm screening run by two staff needs its own minimum-staffing procedure card, because the communication and sweep plan cannot assume a full team.
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Dark auditoria change communication
With audiences seated across multiple screens, the message travels through house lights, on-screen messaging, a managed PA tie-in, and ushers rather than anyone speaking from a stage.
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Outsourced teams still need briefing
Outsourced cleaning teams and contractors are part of the building, and the duty stays with the operator, so their awareness should be logged. A multiplex inside a leisure park or shopping centre also needs coordination with the centre.
Capacity checker
Your busiest moment is what counts
Cinema capacity check
Count the whole cinema during the recurring peak, not one screen or a quiet weekday.
Source: Home Office capacity methods
The statutory guidance points to supplementary document A for ways to assess the “greatest number of individuals reasonably expected to be present at the same time.” Its example methods are non-prescriptive; whichever you use, include workers, and consider immediate-vicinity areas for procedures rather than the threshold count.
Read supplementary document A →What to keep on file for Cinemas
- Capacity assessment by configuration, covering normal days, school holidays, late screenings and premieres. Record the whole-premises peak across screens, foyer, queues, concessions, staff, cleaning and contractors.
- Premises-boundary record showing what the cinema controls versus the landlord or shopping centre.
- Procedure cards by role for duty managers, supervisors, box office, concessions, projection or automation, ushers and cleaners.
- Minimum-staffing rule and procedure for lightly-staffed late screenings.
- Multi-screen turnover and concourse-flow plan, with a PA cut-through test record.
- Cleaning-contractor awareness log.
- Shopping-centre or leisure-park coordination memo where the cinema sits within a larger site.
- Drill or tabletop log with follow-up actions: a threat in the mall concourse, a suspicious item in a screen, or an incident during a sold-out opening.
- Review notes after layout, schedule, or staffing changes.
Martyn's Law resources for Cinemas
Martyn's Law questions for Cinemas
Does each cinema screen count separately?
No. The assessment is premises-wide. A cinema should document how it treated the whole building at once: overlapping screenings, foyer and concession peaks, and the staff present at the same time.
Are all multiplexes enhanced tier?
Not automatically. Many multiplexes cross 800 on peak weekends and holidays, but the tier follows the number reasonably expected at the same time. Record the assessment rather than assuming the answer.
A quiet Tuesday is well under 200. Are we out of scope?
Not on its own. The test is the number reasonably expected from time to time, so a regular busy weekend or holiday peak sets the tier even if midweek is quiet.
Cleaning is outsourced. Is it our responsibility?
The duty stays with the operator of the premises. Outsourced cleaning and contractor teams should still be briefed on the procedures, and that briefing is part of the evidence.
We're a cinema inside a leisure park. Is it us or the property company?
Both can hold duties, for different premises. The cinema operator is responsible for the cinema itself; the company running the wider park is responsible for the shared concourse and common areas. The premises-boundary record is where you set out which is which, so the split is agreed rather than assumed when something happens at the threshold between them.
What does enhanced tier add on top of standard?
Standard tier is procedure-led: evacuation, moving people to safety inside, lockdown, communication and staff awareness. Enhanced tier keeps all of that and adds more, including documenting the measures in place and naming a designated senior individual responsible for the duty. For a chain site that senior individual is usually a head-office appointment rather than the site manager. So a multiplex crossing 800 at peak is a head-office conversation, not a purely local one.
Official sources
Compare another Martyn's Law scenario
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Hotels
Rooms, events, departments, night operations, and evidence across mixed-use hotels.
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Pubs and bars
Big-match peaks, beer gardens, door teams, function rooms, and staff-awareness records.
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Exhibition and conference venues
Venue, organiser, exhibitor and contractor handovers in one evidence trail.
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Community venues and halls
Recurring hires, volunteers, and the committee minute behind the call.
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Music Venues
A full room with the lights down, plus crew and security working it.
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Places of Worship
Service peaks, the place-of-worship rule, and volunteer awareness.
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Restaurants and cafes
Covers, terraces, private dining, and the staff who push a busy service past 200.
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Shops and retail
Peak footfall, seasonal staff, and surge days like Black Friday, not annual totals.
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Sports Grounds
Match-day counts and the access-control facts that set the tier.
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Theatres
Seated houses, foyers, backstage crew, and evacuating mid-performance.
Duty Room is operational compliance software: workflows, checklists, and evidence. It is not a substitute for professional legal, regulatory, or compliance advice. You are responsible for understanding and meeting the obligations that apply to your business.