Martyn's Law by premises type
Martyn's Law for Shops and Retail Premises
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.
Shops
Counting your busiest trading day
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Start with peak footfall
Sales periods, product launches, tourist peaks, and opening events can matter if 200 or more people may reasonably be expected from time to time.
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Stock rooms and concessions need roles
Procedures should account for staff-only areas, concessions, click-and-collect points, queues, and public movement through exits and entrances.
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Chains need comparable evidence
Each store reaches its own tier conclusion, but a multi-site retailer needs them recorded the same way, so head office can see where every store stands and which sites sit close to the 200 or 800 line, without each manager working it out from scratch.
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A unit can qualify in its own right
A unit can qualify in its own right even when the centre also has a duty, so "the centre handles it" is not a safe assumption. The store, landlord, centre management, concessions, and security teams may need to agree who does what, and the store should record where its own duty starts and ends.
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Queues outside still shape the procedures
External queues usually do not count towards the threshold unless they are on premises or controlled land, but they still matter for immediate-vicinity procedures.
Worked example
How capacity adds up for shops
Capacity check
- Customers at peak
- 190
- Concessions, click-and-collect, or store events
- 8
- Store, seasonal, security, cleaning, and contractor staff
- 26
Reasonably expected at the same time
224
A high-street fashion store on Black Friday
On an average day this store is out of scope. But Black Friday and the January sales repeatedly push the simultaneous total over 200 once staff and concessions are counted, and those peaks are foreseeable, so the store 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
Retail peak-capacity check
Count a foreseeable peak trading period, not annual footfall or the average weekday.
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 Shops
- Capacity assessment using footfall, queueing, staffing, seasonal/event peaks, and layout assumptions.
- Store procedures for evacuation, invacuation, lockdown, and communication.
- Staff awareness records for store managers, floor teams, stock-room staff, security, cleaners, and concession staff where relevant.
- Seasonal-worker, concession, contractor, and merchandiser briefing records.
- Landlord, shopping-centre, retail-park, BID, or security-contractor coordination notes.
- Peak trading review notes after layout changes, seasonal campaigns, or store events.
- Per-store evidence export for operations, insurer, adviser, landlord, or regulator conversations.
Related resources
Martyn's Law resources for Shops
- 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 Shops
Do ordinary shops fall within Martyn's Law?
They can, if they meet the qualifying premises and threshold tests. Shops are a Schedule 1 use, but the duties depend on the expected number present and commencement.
Does annual footfall decide the threshold?
No. The test is how many people may reasonably be expected to be present at the same time from time to time, not annual visits.
Do Black Friday or January sales matter?
Yes, if repeated seasonal peaks mean 200 or more people may reasonably be expected at the same time from time to time.
If we are in a shopping centre, is the landlord the only responsible person?
No. A store can qualify in its own right even where the centre also has duties, so a landlord saying "the centre handles it" does not remove your store's own obligations. Confirm who is responsible for what with centre management, and record that coordination position.
Does standard tier mean new guards, bollards, or CCTV?
No. Standard tier is procedure-led. Physical security measures are part of the enhanced-tier framework, not an automatic standard-tier requirement.
A product drop caused a one-off crowd over the threshold. Are we now in scope?
Not automatically. A genuinely unexpected one-off surge that is not reasonably expected to recur does not by itself reclassify the store. If repeated drops or campaigns make those peaks foreseeable, reassess and record the change.
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. Retailers can start recording scope, procedures, staff awareness, and reviews now.
Official sources
Other premises types
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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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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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.