Martyn's Law by premises type
Martyn's Law for Places of Worship
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.
Places of Worship
How the worship-use rule changes things
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Worship stays standard tier
Where the principal use is worship, the premises remains standard tier even if expected attendance reaches 800 or more. Record the basis for that conclusion rather than treating size alone as the answer.
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Service peaks matter more than averages
Ordinary weekday use may be small, but recurring services, festivals, funerals, weddings, concerts, and community events can change the number reasonably expected at the same time.
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Trustees need a minute, not a fortress
A short trustee, PCC, committee, or board record can show the capacity method, tier conclusion, and review trigger.
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Volunteers need practical records
Awareness evidence should not assume paid staff. Greeters, wardens, stewards, trustees, clergy, and regular volunteers may all need simple role-specific records.
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Hired halls need their own logic
A sanctuary used for worship, an attached hall, and a separately hired community room may not have the same answer. Record who controls each recurring use and what is handed to hirers.
Worked example
How capacity adds up for places of worship
Capacity check
- Congregants
- 850
- Security, stewards, and greeters
- 25
- Clergy and staff
- 15
- Contractors and support roles
- 10
Reasonably expected at the same time
900
Large church service
The attendance is above 800, but where the principal use is worship the premises remains standard tier. The evidence pack should record that principal-use conclusion, the capacity method, and the volunteer awareness plan.
Check separately whether an attached hall, externally promoted concert, or non-worship recurring event has different control or use facts.
Capacity checker
Your busiest moment is what counts
Place of worship capacity check
Count recurring worship and community use, then record whether the principal-use worship rule applies.
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 Places of Worship
- Trustee, PCC, committee, or board minute recording the Martyn's Law assessment, tier conclusion, owner, and review trigger.
- Principal-use note explaining why the place-of-worship rule applies, or why a separate hall or event needs its own assessment.
- Capacity assessment covering services, festivals, weddings, funerals, community events, volunteers, staff, contractors, and accompanying halls.
- Procedures for evacuation, invacuation, lockdown, and communication during worship and hired-space use.
- Volunteer and staff awareness register, including trustees or wardens where they hold operational roles.
- Hirer or event handover notes for recurring use that affects expected numbers.
- Notification data note: the charity or trust's registered details, wardens or others with control, who would be authorised to submit, and any hall or annex that makes the premises a group of buildings.
- Review log after congregation growth, festival seasons, tabletop exercises, event-pattern changes, or building layout changes.
Martyn's Law resources for Places of Worship
Martyn's Law questions for Places of Worship
Do places of worship fall within Martyn's Law?
They can. Places of worship are within the Schedule 1 categories once duties commence, and the threshold starts at 200 people reasonably expected to be present at the same time.
Can a place of worship be enhanced tier?
Where the premises is used principally as a place of worship, it remains standard tier even if expected attendance reaches 800 or more. Record the principal-use conclusion and review it if the pattern of use changes.
Does a concert in the sanctuary make it a qualifying event?
Not automatically. The place-of-worship rule can still be relevant, but the responsible person should record who controls the event, whether it is worship use, and whether any separate hall or event arrangement needs its own assessment.
Do attached church halls count the same way?
Not always. An attached or separately managed hall can have different control and use facts, so record the hall, hirer, and recurring-event position separately from the main worship space.
Do volunteers count as staff?
The capacity assessment includes people expected to be present at the same time. For awareness records, what matters is who would need to act during an incident, whether paid or unpaid.
Who in the parish is the responsible person?
It is the person or body that controls the premises and its use, which for most churches is the PCC, trustees, or committee that runs the building, not the diocese. The incumbent or minister may hold an operational role within that. Where a separately run hall hosts a large ticketed public event, the event organiser can hold duties for that event, so record who controls each use and who owns the conclusion.
Do we need a formal terrorism risk assessment, CCTV, or bag searches?
Not at standard tier. The standard duty is proportionate evacuation, invacuation (moving people to safety inside the building rather than out), lockdown, and communication procedures plus volunteer awareness, not a formal terrorism risk assessment or physical security measures. Funded physical-security help is separate and optional. The Home Office runs grant schemes for faith communities, such as the Jewish Community Protective Security Grant, the Protective Security for Mosques Scheme, and the Places of Worship Protective Security Scheme. None of these are Martyn's Law requirements.
Are duties live now?
No. The Act has received Royal Assent, but operator duties are expected no earlier than spring 2027. For now, record the principal-use conclusion, the capacity method, the procedures, and who has been briefed.
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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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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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.