Martyn's Law for places of worship: what applies

The short answer

The Terrorism (Protection of Premises) Act 2025, known as Martyn's Law, covers churches, cathedrals, mosques, synagogues, gurdwaras, temples and other places of worship. A place of worship is in scope if it can reasonably expect 200 or more people to be present at the same time, from time to time. Below that figure, the Act does not apply to the building.

Places of worship then get a special rule. Paragraph 9(2) of Schedule 1 says that where the relevant Schedule 1 use of qualifying premises (the principal use, if there is more than one) is communal worship or other communal religious practice, the premises are standard duty premises "regardless of how they would otherwise be treated". In plain terms, a cathedral that welcomes 2,000 people at Christmas is still standard tier, not enhanced tier. The Home Office statutory guidance confirms this at paragraph 4.37.

Standard tier means two legal duties: notify the Security Industry Authority (SIA), and have appropriate public protection procedures in place, so far as reasonably practicable. You do not have to make physical alterations, install equipment or buy security services. The duties are expected to come into force in spring 2027, after an implementation period of at least 24 months from Royal Assent on 3 April 2025.

Working out whether you are in scope

The test is the greatest number of people you can reasonably expect at the same time, from time to time. "From time to time" means occasionally, so your busiest predictable occasions count, not your average week. For most faith communities that means major festivals, weddings, funerals of well-known members, and special services.

Your count must include everyone present in connection with the use of the building: worshippers, visitors, clergy, staff and volunteers. The statutory guidance defines staff as all those working at the premises "whether as employees, contractors, volunteers or otherwise". Stewards, welcomers, kitchen helpers and musicians all count.

Use real evidence where you can: attendance registers, headcounts by stewards, festival records or booking numbers. The SIA can ask how you reached your figure, and the guidance says your method must be evidenced and reasonable. A fire safety occupancy figure is a useful ceiling but is not, on its own, the answer. Our capacity guide explains the methods, and the free tier checker gives a quick first view.

Halls, multi-use buildings and hiring out

The special rule only applies where the principal use of the premises is as a place of worship. The guidance is explicit about this at paragraph 5.30. Many faith buildings have a hall, café, nursery or community rooms, so it is worth thinking carefully about how your site is used.

• If worship is the main use and the hall is part of the same premises, the whole site is likely to be treated as a place of worship and stays standard tier.
• If a hall is a separate building used mainly for community hire, it may need to be assessed on its own use, as a hall for hire. It would then follow the normal thresholds. Our guide to community and village halls covers this.
• If a building is mainly something else, such as a community centre or town hall, and is used for prayers or religious events some of the time, the special rule does not apply. The guidance gives the example of a community centre used for amateur dramatics, craft markets and overspill Friday prayers: it is standard tier because of its numbers, not because of the worship.
• A nursery or school run from your site has its own special rule. Our guide to schools, colleges and universities explains it.

When you hire out the building, you stay the responsible person. The guidance gives the example of a large synagogue hired by an events company for a fundraising concert of 1,000 people. Because events at places of worship cannot be qualifying events, the synagogue stays standard tier and its governing body stays responsible. Responsibility cannot be handed over, but the hire agreement can bind the hirer to carry out public protection duties. Private occasions such as weddings and funerals work the same way: control, and responsibility, stays with you.

In practice, add a short section to your hire terms. It should explain your procedures, name who on the hirer's side will lead in an emergency, and confirm that the hirer will brief their own helpers. Keep a signed copy. If the SIA asks, you need to be able to show you set out clear requirements and took reasonable steps to check they were followed.

Festivals and events away from your building

The special rule is attached to the building, not to the faith community. When you take a celebration somewhere else, normal rules apply. Home Office supplementary document B gives two examples worth knowing.

• A Hindu temple hires and fences off part of a park for Holi. The event is free but ticketed through the temple website, and a volunteer checks tickets on entry. With 800 or more expected at once, it is a qualifying event, and the temple, as organiser, is the responsible person with enhanced duties for that event.
• Another temple holds a similar Holi celebration in its own grounds. Because the temple is a place of worship, it stays standard tier and the event is not a qualifying event.
• A gurdwara holds an open langar for 800 or more at a university that is already enhanced tier. There is no ticket or entry check, so it is not a qualifying event, and the university is responsible as part of its own duties.

The lesson is that free entry does not keep an event out of scope if you check registrations at a defined perimeter. If you are planning an off-site procession, mela, Vaisakhi celebration or open-air service, read our guide to qualifying events and events and festivals early, because enhanced duties include a written compliance document and notifying the SIA within 14 days of first publicising the event.

Who is the responsible person, and where volunteers fit

The responsible person is whoever has control of the premises for their use as a place of worship. Control usually means possession of the building and the right to make decisions about how it is run and who may stay. Depending on your faith and governance structure, this may be a board of trustees, a management committee, a parochial church council, a congregation's governing body or a diocesan or national body. Check your governing documents, and any guidance from your denomination or national body, before you notify the SIA. Our guide on who the responsible person is explains the control test in detail.

Most places of worship run on volunteers, and the Act works with that. Volunteers count in your headcount, and they can be the people who carry out your procedures. The guidance is clear that there is no statutory requirement for formal counter-terrorism training. What it does expect is that the people who will put procedures into action know what they are and what their role is. A short briefing for stewards and welcomers, a laminated card at each door and a walk-through once a year will go a long way.

Nobody is expected to take actions that would put their own safety at risk. A steward closing the inner doors, moving people away from the entrance and calling 999 is the kind of action the Act has in mind.

Practical procedures for services and festivals

Your procedures need to cover four things: evacuation, invacuation (moving people to a safer place inside), lockdown and communication. They should fit your building and how it is used. Here is how that can look for a typical service.

1. Name a duty lead for every service or gathering, usually a senior steward or warden, who can decide which procedure to use. Name a deputy too.
2. Agree how the alarm is raised. This might be a set phrase over the PA system, a message from the person leading worship, or stewards moving through the congregation. Make sure it works for people with hearing loss and for those who do not speak English well.
3. Plan evacuation routes that use more than one exit. The guidance gives the example of a standard tier church that tells people to disperse in several directions in a suspected attack, rather than gather at the fire assembly point, which could itself become a target.
4. Identify a safer internal space for invacuation, such as a vestry, side hall or a room away from the street with a solid door, and know roughly how many people it can hold.
5. Decide who locks which doors in a lockdown, how long it takes, and how people inside are kept away from glass and entrances. Include doors that are normally propped open for welcome.
6. Keep a simple grab bag or folder near the main entrance with key holder numbers, a floor plan and a list of who is on duty.

Festivals need a little more thought. Numbers are higher, people queue outside, and children and older people may be present in larger numbers. The guidance says that where a large number of people are present at a standard tier place of worship, it may be sensible to look at the extra considerations written for enhanced tier premises, even though they are not legally required. For a major festival, that could mean briefing extra stewards beforehand, checking the street outside before people leave, and agreeing with neighbouring premises how you will warn each other.

Write your procedures down. It is not a legal requirement at the standard tier, but the guidance says it may be difficult to show compliance without a record, and it is the easiest way to brief volunteers who rotate. Our guide to public protection procedures goes into each procedure in more depth.

Common mistakes to avoid

• Assuming the special rule means you are exempt. It does not. It caps you at the standard tier.
• Using only weekly attendance and forgetting festival peaks, weddings and staff or volunteers in the count.
• Copying the fire evacuation plan unchanged. A terrorist incident may call for dispersal, invacuation or lockdown instead.
• Treating an off-site festival as covered by the special rule. It is not.
• Paying for expensive courses you do not need. The guidance says paid third-party training is not mandatory, and free resources such as ProtectUK's ACT Awareness e-learning are available.
• Letting hirers run large events with no written expectations in the hire agreement.

What to do next

Start by confirming your peak numbers and who your responsible person is. Then draft your four procedures, brief your stewards and keep a simple record of what you decided and when you reviewed it. The duties are expected to start in spring 2027, so there is time to build this into existing safeguarding and fire safety routines.

If you would like a structured way to do this, our packs include templates written for volunteer-run premises, including places of worship, with procedures, briefing notes and a record log you can adapt.

Frequently asked questions

Sources

• Terrorism (Protection of Premises) Act 2025, Schedule 1 (legislation.gov.uk)
• Terrorism (Protection of Premises) Act 2025, Schedule 2 (legislation.gov.uk)
• Home Office statutory guidance on the Terrorism (Protection of Premises) Act 2025 (GOV.UK)
• Non-statutory supplementary document B: Scope, illustrative examples (GOV.UK)
• Terrorism (Protection of Premises) Act 2025: notification requirement (GOV.UK)