Martyn's Law for charities, clubs and volunteers

KEY POINTS

There is no exemption for charities, clubs or volunteer-run organisations. The same tests apply: the use of the premises, the number of people and the listed exclusions.
Volunteers count as staff. They go into your headcount, and those with a role in your procedures need to know what to do.
The responsible person is whoever controls the premises. For most charities and clubs that is the organisation itself, acting through its trustees or committee.
What is reasonably practicable takes account of your resources, including money and staffing. Standard tier duties need no building works or paid training.
Members-only access does not take premises out of scope, and a ticketed members' event of 800 or more can be a qualifying event.

The short answer

Martyn's Law, the Terrorism (Protection of Premises) Act 2025, does not treat charities, clubs or volunteer-run organisations differently. If you control premises used for a listed purpose, such as a hall for hire, a museum, a sports ground with spectator stands, a social club bar or a place of worship, and 200 or more people, including staff, can reasonably be expected there at the same time, from time to time, you are in scope.

Most volunteer-run venues that are in scope will be standard tier, which means two duties: notify the Security Industry Authority (SIA), and have procedures for evacuation, invacuation, lockdown and communication, so far as reasonably practicable. The enhanced tier applies at 800 or more. The duties are expected to start in spring 2027.

Some types of premises have special rules. Places of worship, early years settings, schools and further education premises are always standard tier at 200 or more, however large they are. Run your numbers through our free tier checker for a first view, and see exemptions and special cases for the full list.

Volunteers count as staff

The Home Office statutory guidance says that throughout the guidance, staff means everyone working at the premises or event, "whether as employees, contractors, volunteers or otherwise". That has two practical effects.

Your headcount: count volunteers on duty alongside visitors. Stewards, bar volunteers, kitchen helpers, front of house, performers' helpers and committee members on duty all count. A club with 180 spectators and 25 volunteers on match day has 205 people present.
Your procedures: volunteers will often be the people who carry them out. The guidance expects those with a role to know what the procedures are and what their part is.

Only people in the part of the premises used for the listed purpose are counted. Use your busiest predictable occasions, not an average. A fire safety occupancy figure is a useful ceiling but not the answer. The guidance gives the example of a village hall with a safe occupancy of 250 whose records show no more than 150 people at once in five years: it is out of scope. Our guide on how to calculate capacity sets out methods you can evidence.

Who is responsible in a charity or club?

The responsible person is the individual, organisation or company with control of the premises for their listed use. Ownership is not the test. A club that runs a pavilion on a licence from a council, or a charity that leases a building, may well be the party in control.

How this works depends on your legal form.

Legal form	How it is likely to work
Charitable company or CIO	The organisation itself is the responsible person. The trustees or directors run it and make the decisions.
Unincorporated association, such as many clubs and societies	The Act expressly recognises unincorporated associations, for example when the SIA serves notices and in its rules on personal liability. The guidance does not set out in detail how duties attach to them, so check the official guidance and take advice if unsure.
Charitable trust	The guidance does not specifically address trusts. Check the official guidance, and consider advice on who holds control in practice.

Two points from the Act apply whatever your structure. First, the SIA can give a notice to an unincorporated association by giving it to any person concerned in its management or control (section 29). Second, section 26 says that where an organisation commits certain offences, such as failing to comply with a compliance notice or restriction notice, a person concerned in its management or control also commits the offence if it happened with their consent or connivance or was attributable to their neglect. For an unincorporated association, the Act defines that person as "a person who is concerned in the management or control of the association". In practice, committee members and trustees should treat this as a shared committee responsibility, not a job for one volunteer.

The guidance also says the responsible person cannot delegate legal responsibility to a contracted service provider, but may delegate tasks. You can ask a volunteer to lead on the procedures, but the organisation keeps the duty. A designated senior individual is only required for enhanced tier premises and qualifying events. Where that applies to a volunteer-run body, the guidance says it should be someone responsible for managing its affairs, "such as a member of a club's management committee". See who is the responsible person.

Low-cost procedures that volunteers can run

The guidance says that deciding what is reasonably practicable should take account of the specific circumstances of the premises, "including the resources available to them, for example, financial resources and staffing levels". The Act requires no physical alterations and no specific equipment for standard tier procedures, although the guidance says small changes, such as how doors are locked, may sometimes be reasonably practicable.

Walk the building with two or three committee members. Note every way in and out, which doors lock, who holds keys during events and which internal rooms could act as a safer area.
Write each procedure in plain words on one page: how you evacuate away from danger and disperse, where people shelter inside, how doors are secured, and how you alert everyone and call 999.
Decide who leads on the day. Usually the most senior volunteer on duty, with a named deputy.
Agree a simple alert, such as a clear spoken phrase over the PA or from the stage, and a committee messaging group for key holders.
Put a short action card by main doors and behind the bar or kitchen hatch.
Brief volunteers at induction and give a refresher once a year. Record who attended.

Keep it simple. The guidance includes an example of a bar that replaced several evacuation procedures with one simple one after staff hesitated in a practice. Our guides to public protection procedures and staff training go into more detail, and ProtectUK offers free ACT Awareness e-learning that volunteers can complete at home.

Hiring your hall out, or hiring someone else's

Many charities and clubs are on both sides of a hire arrangement. The guidance (paragraphs 6.13 to 6.15) is clear about how this works.

When you hire out premises you control, you stay the responsible person. You should explain the requirements to hirers and set out what you expect of them, ideally in the hire agreement. If asked, you must be able to show the SIA you clearly specified the requirements and took reasonable steps to check the hirer followed them.
When you hire someone else's qualifying premises, the venue's responsible person usually stays responsible. Your job is to follow their procedures, brief your own helpers and tell them if your numbers will be larger than usual.
The exception is a qualifying event: an event of 800 or more, open to the public, with entry checks such as tickets. If the hirer takes control of the venue for that event, the hirer becomes the responsible person for it and must meet the enhanced duties.

A one-page hirer information sheet covering exits, the safer room, how doors are secured and who to call is usually enough for ordinary hires. Our guide to community and village halls includes a table of what to put in a hire agreement.

Community events, fêtes and members' events

Events need separate thought, because they are tested differently from premises.

Illustrative event	Likely position
Free summer fête on an open village green with no entry checks	Likely not in scope. Open-air recreation land without access controls is excluded as premises, and with no entry checks it is not a qualifying event.
Junior football tournament on an open public pitch, no stands, 200 or more present	Not in scope. The guidance gives a near-identical example.
Ticketed charity concert in a fenced field, 900 expected at peak including volunteers	Likely a qualifying event. The organiser in control of the site is responsible and must meet the enhanced duties.
Members-only ticketed music day in a park, 2,000 members and staff	A qualifying event. Membership counts as an entry condition. The guidance gives this example.
Annual fundraiser at your own standard tier hall, 300 expected	Covered by the hall's standard tier procedures. Not a qualifying event.

Membership does not take premises out of scope either. Schedule 1 to the Act says it is irrelevant that access is limited to people who have paid, hold tickets or passes, or are members or guests of a club, association or similar body. A members' club or sports club bar can be qualifying premises in the same way as a public one. The guidance gives the example of a private members' club in the standard tier.

Events held at places of worship, early years settings, schools and further education premises cannot be qualifying events. Those premises stay in the standard tier. See qualifying events for the full tests.

Common mistakes and what to do next

Assuming charities or volunteer-run organisations are exempt. They are not.
Leaving volunteers out of the headcount.
Assuming hirers take on the duty for ordinary hires.
Leaving it all to one volunteer. The organisation, and those managing it, carry the responsibility.
Paying for expensive training or equipment the Act does not require. The guidance says paid third-party products and services are not mandatory.
Forgetting to notify the SIA once the duty is in force. Under the notification regulations, existing premises will have three months from commencement.

Put Martyn's Law on the agenda for your next trustee or committee meeting. Agree your headcount, who will draft the procedures, how hire terms will change and when volunteers will be briefed. If you would like ready-made templates, our packs include procedures, action cards and a hirer information sheet written for volunteer teams.

Frequently asked questions

Are charities exempt from Martyn's Law?

No. There is no exemption based on charitable status, size or the use of volunteers. Premises are in scope if they are used for a listed purpose and 200 or more people, including staff and volunteers, can reasonably be expected at the same time, from time to time.

Do volunteers count towards the 200 threshold?

Yes. The statutory guidance defines staff as everyone working at the premises or event, including employees, contractors and volunteers. Count volunteers on duty at your busiest times.

Are trustees or committee members personally liable?

The duties fall on the responsible person, usually the organisation. Under section 26 of the Act, a person concerned in an organisation's management or control can also commit certain offences, such as failing to comply with a compliance notice, if it happened with their consent or connivance or through their neglect. Take advice if you are unsure how this applies to your structure.

Does a members-only club fall outside Martyn's Law?

No. The Act says limiting access to members or guests of a club does not stop premises being used by visiting members of the public. A members' club can be qualifying premises, and a ticketed members' event of 800 or more can be a qualifying event.

Do we need to pay for training for our volunteers?

No. There is no requirement for paid training. Volunteers with a role in procedures need to know what to do. A short briefing, a written procedure and free resources such as ProtectUK's ACT Awareness e-learning are proportionate for many organisations.

Sources

General information based on the Act and published guidance, not legal advice. Check the official statutory guidance on GOV.UK for your situation.

Martyn's Law for charities, clubs and volunteer-run venues