Martyn's Law by premises type
Martyn's Law for Hotels
Where this is up to
It's law. No one's checking yet. You've got time to get ready.
The Terrorism (Protection of Premises) Act 2025 received Royal Assent in April 2025. The duties are not yet in force: commencement is expected no earlier than spring 2027, after a 24-month implementation period. Nothing has to be submitted to the SIA today, so the work now is recording your scope, your procedures, and your staff awareness.
- Apr 2025 The Act received Royal Assent
- Apr 2026 Home Office statutory guidance first published
- Jun 2026 SIA enforcement guidance in consultation (until 12 June)
- Spring 2027 Earliest the operator duties commence
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.
- Start building records now, so they're there before duties commence.
Hotels
How the numbers stack up across a hotel
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Multiple uses can stack
Restaurants, bars, function rooms, conference spaces, leisure areas, guests, visitors, contractors, and staff may all affect the expected number present at the same time.
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Events can move a standard site to enhanced
A hotel below 800 on normal days may need a different conclusion where large recurring conferences, banquets, or public events are part of the expected use. A private wedding is not automatically a qualifying event, but it can still affect the hotel's capacity.
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Responsibility is shared across teams
Front desk, duty managers, event teams, housekeeping, leisure staff, security, and contractors need a shared procedure record and awareness trail.
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Night operations are different
A hotel procedure has to work for sleeping guests and night teams. A fire alarm plan alone is not a substitute for incident-specific communication, invacuation, lockdown, and route choices.
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Control should be mapped
Leased restaurants, spas, car parks, concessions, branded operators, and management agreements can complicate who controls which Schedule 1 use. Keep the responsibility map with the evidence.
Worked example
How capacity adds up for hotels
Capacity check
- Resident guests
- 160
- Non-resident restaurant & bar
- 35
- Staff & event suppliers
- 25
Reasonably expected at the same time
220
A 90-room hotel on a wedding weekend
Bedroom count is not the test. Guests, non-resident diners and staff present together take the property past 200. A large public gala in a ballroom could push a single day beyond 800 and into enhanced tier.
Illustrative example applying the official capacity method. It is not a determination, so record your own assessment and the data behind it.
Capacity checker
Your busiest moment is what counts
Hotel capacity check
Count simultaneous use across rooms, public areas, food and drink, events, staff, and suppliers.
Source: GOV.UK capacity methodology
GOV.UK says to determine the “greatest number of individuals reasonably expected to be present at the same time.” Its factsheet also says to include workers, and to consider immediate-vicinity areas for procedures rather than the threshold count.
Read the GOV.UK factsheet →Records
What to keep on file for Hotels
- Site-level capacity assessment across hotel functions, with event-day assumptions separated from ordinary operation.
- Procedure pack covering guests, public areas, event spaces, staff-only areas, and overnight duty management.
- Staff awareness register by department, including night teams and contractors where relevant.
- Premises-control map covering hotel-operated areas, leased or concession areas, shared spaces, car parks, and grounds.
- Event handover checklist for recurring high-capacity functions and conferences.
- Tabletop or exercise records for lobby incidents, conference evacuation, night-time communication, and outdoor event scenarios.
- Enhanced-tier document and senior individual record where the 800-person threshold is reached.
Related resources
Martyn's Law resources for Hotels
- Martyn's Law
Martyn's Law: Does Your Venue Meet the 200-Person Threshold?
How to calculate whether a venue meets the 200-person capacity threshold under the Terrorism (Protection of Premises) Act 2025.
7 min read - Martyn's Law
Martyn's Law: The Statutory Guidance Is Out
The Home Office has published the section 27 statutory guidance, and the SIA's enforcement guidance is open for comment until 12 June. What the document settles, and what still has to wait until commencement.
2 min read - Martyn's Law
Martyn's Law: The Commencement Clock Has Started
The first commencement order under the Terrorism (Protection of Premises) Act 2025. What S.I. 2026/320 does and does not trigger.
3 min read
Martyn's Law questions for Hotels
Do hotel bedrooms count for Martyn's Law?
The assessment depends on the premises use and who may reasonably be expected to be present at the same time. Hotels need to document how they treated guests, visitors, staff, event attendees, and public spaces.
Can one hotel have both standard and enhanced issues?
The Act classifies qualifying premises by thresholds. A hotel operator should record the method and conclusion for the property, especially where event peaks approach 800.
Does a private wedding become a qualifying event?
Not automatically. A private event that is not open to the public is not usually a qualifying event, but the attendees can still matter when assessing the hotel's own capacity.
Who holds the duty for a hotel?
The duty falls on the person or organisation in control of the premises, usually the hotel operator. An external wedding or event organiser, or a leased spa, restaurant, or concession, does not remove your duty for the parts of the site you control. Map who controls each Schedule 1 use so the boundaries are clear in your evidence.
Is the fire evacuation plan enough?
No. Fire plans and your fire risk assessment are useful inputs, but Martyn's Law procedures also cover invacuation (moving people to safety inside the building), lockdown, and communication where the safest route may not be the normal fire route.
When does a hotel need a senior individual record?
Only enhanced-tier premises and qualifying events have the senior individual requirement where the responsible person is an organisation.
Is Martyn's Law in force yet?
No. The Act received Royal Assent in April 2025 with an implementation period of at least 24 months, and duties are expected no earlier than spring 2027. Hotels can start recording capacity, procedures, department awareness, and reviews now.
Official sources
Other premises types
Compare another Martyn's Law scenario
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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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Cinemas
Staggered showtimes, packed foyers, and who is in the building at once.
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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.
Keep Martyn's Law procedures, staff awareness, and evidence in one place.
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.