KEY POINTS
- Section 10 of the Act requires a senior individual only where the responsible person for enhanced tier premises or a qualifying event is an organisation, not an individual.
- The senior individual must be concerned in the management or control of the organisation. The Home Office says a lower-level employee is unlikely to qualify.
- Their job is to ensure the organisation complies. They can delegate tasks, but not overall responsibility.
- They are not personally liable for SIA penalty notices, but can be prosecuted if the organisation commits an offence with their consent or connivance, or through their neglect.
- Their name, contact details, position and date of designation must be given to the SIA, and changes notified.
The short answer
If your organisation is the responsible person for premises where 800 or more people may be present at the same time, or for a qualifying event, it must designate a senior individual. Section 10 of the Terrorism (Protection of Premises) Act 2025 says the responsible person 'must designate an individual who is concerned in the management or control' of it 'as having responsibility for ensuring' that it complies with the Act.
Standard tier premises (200 to 799 people) do not need one, and nor do responsible persons who are individuals, such as a sole trader. The duties are expected to come into force in spring 2027. If you are not sure which tier you are in, use our free tier checker.
Who must designate one
| Situation | Senior individual required? |
|---|---|
| Company, LLP, charity, trust, club or public body responsible for enhanced tier premises | Yes |
| Organisation responsible for a qualifying event | Yes |
| Sole trader or other individual responsible for enhanced tier premises or an event | No, the individual is already personally responsible |
| Any responsible person for standard tier premises | No |
| Place of worship, school, nursery or further education college, however large | No, these are always standard tier |
The Act describes a responsible person who 'is not an individual', so the duty applies to any type of organisation, including partnerships and unincorporated associations. The Home Office guidance confirms that a volunteer-run organisation must still designate someone with responsibility for managing its affairs, such as a member of a club's management committee.
Who can be the senior individual
The legal test is that the person is 'concerned in the management or control' of the responsible person. The Home Office guidance explains that this means someone who has responsibility for managing the organisation's affairs, or has control of it, rather than a lower-level employee with limited responsibilities and influence. It is for each organisation to decide who is appropriate, provided they have sufficient seniority and influence to ensure compliance.
Typical choices include:
- a director or board member of a company
- a chief executive, chief operating officer or managing director
- a trustee or senior officer of a charity
- a partner in a partnership or LLP
- a member of the management committee of a club or association
- for a local authority or public body, a senior officer with authority over the relevant service
The same person can be the senior individual for several premises or events. The guidance gives the example of a cinema chain whose senior individual is a board member at head office who delegates day-to-day compliance to someone at each site, while keeping overall responsibility. It warns that procedures and measures must still be tailored to each site.
What the senior individual is responsible for
The main function, in the Home Office's words, is to ensure that, so far as it is in their power, the responsible person complies with the Act. That covers every enhanced tier duty: notification, public protection procedures, public protection measures, the compliance document, co-ordination and co-operation. See our guide to enhanced tier duties for the full list.
The guidance gives non-exhaustive examples of what a senior individual may do:
- keep protective security as an ongoing discussion or agenda point at board level
- receive regular briefings on threats and vulnerabilities to the premises or event
- make sure relevant information is cascaded to staff, as appropriate to their role
- set up or monitor reporting lines between everyone involved in procedures and measures
- review and approve the compliance document before it is submitted to the SIA
In practice, a senior individual will usually also want to:
- make sure the organisation has notified the SIA and keeps the details accurate
- secure the budget and people needed for measures judged reasonably practicable
- check that decisions not to adopt a measure are reasoned and recorded
- see evidence of training, drills and reviews
- be the point of contact if the SIA proposes a notice, and lead the organisation's representations
Delegation: what can and cannot be passed on
The senior individual can delegate actions to others, such as a head of security, a site general manager or a contracted security lead. They cannot delegate their overall responsibility for ensuring compliance. Equally, designating a senior individual does not shift legal responsibility away from the organisation: the responsible person remains the one the duties are imposed on.
For example, a hotel group with three enhanced tier hotels might designate its chief operating officer as senior individual for all three. Each hotel's general manager runs the procedures and drills day to day, the group security manager drafts the compliance documents, and the chief operating officer reviews quarterly reports, signs off each document and raises gaps at board meetings. That is the kind of structure the guidance describes.
Personal liability
This is the question most senior people ask first, so it is worth being precise.
- Penalty notices: the Home Office guidance states that the senior individual is not personally liable for the responsible person's failure to meet the requirements for the purposes of receiving a penalty notice. Civil penalties are aimed at the responsible person.
- Criminal offences: under section 26 of the Act, if an organisation commits an offence of failing to comply with a compliance notice, restriction notice or information notice, an officer or other person concerned in its management or control can also be prosecuted if the offence was committed with their consent or connivance, or is attributable to their neglect.
- For the offences of giving false or misleading information to the SIA, obstructing an inspector or pretending to be one, individual liability requires consent or connivance; neglect alone is not enough.
This liability is not unique to the senior individual. It applies to any director, manager or similar officer. But the senior individual is the person most likely to have known about, and been able to act on, an SIA notice. The main section 24 and 25 offences carry up to two years' imprisonment and/or a fine on indictment. See our guide to penalties and enforcement.
Telling the SIA
The 2026 notification regulations require enhanced tier and qualifying event notifications to include the senior individual's name, contact details, position in relation to the premises or event, and the date they were designated. The senior individual must also confirm they understand the duties to prepare a compliance document, send it to the SIA as soon as reasonably practicable and send any revision within 30 days.
If the senior individual changes, the notified information is no longer accurate, so you must update the SIA within 28 days for premises or 14 days for a qualifying event. See notifying the SIA.
How to choose and appoint the right person
- Confirm that the organisation is the responsible person and that the premises or event are enhanced tier.
- Shortlist people concerned in management or control who have real authority over budgets, staffing and operations at the relevant sites.
- Check capacity: they need time to receive briefings, review documents and follow up actions, not just a title.
- Record the designation formally, for example in board or committee minutes, with the date.
- Agree who they will delegate to, and write down reporting lines and how often they will be briefed.
- Plan for cover and succession, so a resignation does not leave a gap or a missed SIA update.
- Brief them on the Act, the Home Office statutory guidance and the SIA's approach.
Common mistakes include naming a site security supervisor with no budget authority, naming someone who has left without updating the SIA, and treating the role as a signature rather than active oversight.
Enhanced tier sites usually benefit from specialist support, and we can introduce you to a specialist.
Frequently asked questions
Do standard tier premises need a designated senior individual?
No. The section 10 duty only applies where the responsible person for enhanced tier premises (800 or more people) or a qualifying event is an organisation rather than an individual.
Can the senior individual be our security manager?
Only if they are genuinely concerned in the management or control of the organisation. The Home Office says a lower-level employee is unlikely to qualify. A common approach is to designate a director and let them delegate day-to-day tasks to the security manager.
Is the senior individual personally fined if the venue fails to comply?
No. The Home Office guidance says they are not personally liable for penalty notices. They can be prosecuted, like any senior officer, if the organisation commits an offence under the Act with their consent or connivance or, for some offences, through their neglect.
Can one person be the senior individual for several venues?
Yes. The guidance accepts one senior individual for several premises or events, provided procedures and measures are still tailored to each site.
Can an external consultant be the senior individual?
The Act requires an individual concerned in the management or control of the responsible person, so an external adviser without that role would not normally qualify. Consultants can support the senior individual, who keeps overall responsibility.
Sources
General information based on the Act and published guidance, not legal advice. Check the official statutory guidance on GOV.UK for your situation.