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Martyn's Law by premises type

Martyn's Law for Pubs and Bars

How pubs and bars should think about Martyn's Law scope, the 200-person threshold, beer gardens, event peaks, staff awareness, and evidence records.

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.

  1. Apr 2025 The Act received Royal Assent
  2. Apr 2026 Home Office statutory guidance first published
  3. Jun 2026 SIA enforcement guidance in consultation (until 12 June)
  4. 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.

Pubs

Where a quiet pub still crosses the line

A pub can sit well under 200 most of the week and fill past it for a big match, a bank holiday, or a Christmas booking. Martyn's Law turns on those reasonably expected peaks, including staff and any beer garden or function space that forms part of the premises.
  • Beer gardens and outside areas can count

    Where outdoor areas are part of the premises, include them in the expected number of people present at the same time. A quiet weekday number is not enough if summer, bank holiday, or event peaks are materially higher.

  • The licence figure is only one input

    Fire safety capacity and licence conditions help the assessment, but Martyn's Law asks who may reasonably be expected to be present from time to time, including staff.

  • Front-line staff need practical awareness

    Bar staff, door teams, duty managers, kitchen teams, and cleaners may all need to know what to do in an incident: getting people out (evacuation), bringing them safely inside if the danger is outside (invacuation), securing the building to keep a threat out (lockdown), and how to communicate any of it.

  • The queue still affects what staff do

    A pavement queue or smokers outside the premises are not normally counted for the 200 or 800 threshold, but they still matter when you decide what instructions staff should follow during an incident.

  • Standard tier is procedure-led

    For standard-tier premises, the practical work is proportionate procedures, awareness, reviews, and evidence. Do not treat it as a requirement to buy CCTV, barriers, or bag-search hardware.

Worked example

How capacity adds up for pubs

Capacity check

Indoor customers
140
Beer garden
60
Staff on shift (bar, kitchen, door)
15

Reasonably expected at the same time

215

Result Standard tier (200-799)

A town pub on a big-match Saturday

Indoor covers alone stay under 200, but the beer garden and staff on shift push the expected number over the threshold on predictable peak days, so this pub is in scope at standard 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

Count a predictable busy session, not a quiet weekday. Include the spaces and teams in use at the same time.

Pub & bar capacity check

Count a predictable busy session, not a quiet weekday. Include the spaces and teams in use at the same time.

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 Pubs

  • Capacity assessment showing the method, peak periods, staff count, outdoor areas, and final tier conclusion.
  • Evacuation, invacuation, lockdown, and communication procedures matched to the pub layout.
  • Staff awareness register covering duty managers, bar teams, kitchen teams, door staff, and regular contractors.
  • Door-team, promoter, function-room, and contractor handover notes for nights where the expected number or operating model changes.
  • Drill or tabletop exercise log with attendees, findings, and follow-up actions.
  • Review trigger log for licence variations, new screens, refurbished layouts, a new garden, or a different events programme.
  • Evidence pack for adviser, insurer, or SIA inspection readiness once duties commence.

Martyn's Law questions for Pubs

Does a beer garden count for Martyn's Law?

It can. If it is accompanying land used with the premises, include it when assessing how many people may reasonably be expected to be present at the same time.

Does a small pub need Martyn's Law procedures?

Only if 200 or more people, including staff, may reasonably be expected to be present at the same time from time to time. A smaller pub can still use the guidance voluntarily, but the statutory duties depend on scope.

Who is the responsible person for a tenanted or managed pub?

Whoever controls the premises for its food and drink use. In a tenanted or leased pub that is usually the tenant or licensee, but the guidance gives an example where a brewery that holds the licence is the responsible person, so record who actually controls the site rather than assuming it is the freeholder or pub company.

Do queues outside count towards the threshold?

Not usually if they are outside the premises, but they can still matter for the procedures staff use for the immediate vicinity.

Does standard tier mean CCTV or bag searches?

No. Standard tier is about appropriate public protection procedures and staff awareness. Physical security measures are an enhanced-tier concept.

Is Martyn's Law already in force?

No. Operator duties are expected no earlier than spring 2027, but the guidance is clear enough to start recording scope, procedures, awareness, and reviews now.

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.