The SIA as Martyn's Law regulator: powers and approach

KEY POINTS

The Security Industry Authority (SIA), which already regulates the private security industry, is the regulator for Martyn's Law across the whole UK.
It will receive notifications through an online portal, receive enhanced tier compliance documents, assess compliance at a desk and on site, and give guidance.
Its powers include information notices, interviews, inspections (usually with at least 72 hours' written notice), and warrants in limited cases.
It can issue compliance notices, restriction notices (enhanced tier and events only) and penalty notices, and refer the most serious cases for prosecution. Notices can be appealed to the First-tier Tribunal within 28 days.
The SIA says it will be supportive, proportionate and risk-based, but will enforce where necessary. Its final guidance on how it will regulate is expected in autumn 2026.

Who regulates Martyn's Law?

Section 12 of the Terrorism (Protection of Premises) Act 2025 makes the Security Industry Authority the regulator. The SIA is a Home Office arm's length body set up under the Private Security Industry Act 2001, best known for licensing door supervisors and security guards. Its Martyn's Law work is a separate function, funded by Home Office grant rather than security licence fees, and led by an Executive Director for Martyn's Law. The SIA says it is operationally independent of government in its casework and decisions.

Because counter terrorism is not devolved, the SIA's remit covers England, Wales, Scotland and Northern Ireland. It is recruiting regional inspection teams across all four nations, and has said most office-based Martyn's Law roles will be in a new SIA location in Manchester. The SIA's chief executive has said it predicts around 155,000 standard tier and 25,000 enhanced tier premises will be in scope.

If you have not yet checked whether you are one of them, try our free tier checker.

What the SIA will do

The Act requires the SIA to exercise its investigatory powers to assess compliance, take the enforcement action it considers necessary, publish guidance on how it will use its functions, advise those in scope as it considers appropriate, and keep the effectiveness of the law under review. In practice the SIA describes three jobs:

Helping those responsible for qualifying premises and events to comply, through guidance, templates and tools.
Assessing compliance, using notifications, compliance documents, reports from the public and other intelligence, and carrying out desk-based assessments and on-site inspections.
Bringing premises and events into compliance, through advice and warnings first where appropriate, and formal enforcement where needed.

The SIA's draft guidance says it will not usually give tailored advice to individual premises unless it has identified a specific compliance issue. The SIA has also said that neither it nor the Home Office can endorse or recommend any company or service for compliance.

Its approach to regulation

The SIA has said repeatedly that it intends to be "supportive, proportionate and risk-based". Its chief executive has said the role will be primarily advisory at the start, to give premises the opportunity to get compliance right first. At the same time, it has said it will be "uncompromising in enforcing the new law where this is necessary" and expects to use the full range of its powers.

Its draft section 12 guidance explains that it must follow the Regulators' Code, the statutory principles of good regulation and the Growth Duty. It will use a risk framework, informed by intelligence and by working with other regulators and public bodies, to decide where to focus. Its focus will be on whether those in scope have taken reasonable steps to comply, including whether arrangements are in place, kept up to date and capable of being carried out effectively.

Neither the SIA nor the Home Office endorses any provider, and using a third party is optional. Be wary of any product that claims to guarantee compliance: what counts is whether your procedures fit your premises and your staff can carry them out.

The SIA consulted on its draft guidance between 15 April and 12 June 2026 and plans to publish the final version, once approved by the Secretary of State, with a consultation report in autumn 2026. Details may change in the final version, so check it once published.

Information and inspection powers

Schedule 3 to the Act gives authorised SIA inspectors these powers for a "terrorism protection investigation" into whether someone is complying:

Power	What it means for you
Information notice	A written notice requiring specified information by a set date, such as your procedures, training records or how you calculated your numbers. Failing to comply is an offence, although it is a defence to show you took all reasonable steps to comply.
Interview notice	A notice requiring someone to attend at a set time and place to answer questions. Failure can lead to a penalty of up to £5,000 and, like ignoring an information notice, is also an offence. The draft guidance says interviews will not be under caution.
Inspection without a warrant	Entry at a reasonable hour after at least 72 hours' written notice, to inspect the premises, observe activities, view and copy documents, inspect equipment, take photos and measurements, and require explanations and reasonable assistance.
Inspection with a warrant	Available from a magistrate (or sheriff in Scotland) where an inspection has been frustrated, notice would defeat the purpose, access is urgently needed, or the premises are not themselves in scope, such as a head office. A warrant may allow entry by force and seizure of evidence.

Inspectors must show evidence of identity and authorisation if asked, and may bring others, such as a technical expert. You are not required to provide information that might incriminate you, and legally privileged material is protected. The SIA can inspect premises that have not notified it, and may select premises through scheduled programmes, risk-based selection, thematic reviews of a sector or a particular procedure, or specific intelligence.

What will an inspector want to see? The draft guidance and Home Office guidance point to your capacity assessment, your procedures, evidence that staff know them (briefings, training, drills) and, at enhanced tier, your compliance document and measures. Our guide to record keeping and evidence explains what to keep.

Enforcement notices

Before giving any of these notices, the SIA must give you an opportunity to make representations, except for urgent restriction notices. The draft guidance says it will normally use advice and warnings before formal enforcement where that is likely to secure compliance in a reasonable time.

Notice	When it can be used	What it does
Compliance notice (section 13)	Reasonable grounds to believe a requirement in sections 5 to 10 has been breached, including the duty to co-operate	Requires you to comply within a set period, possibly by taking specified steps and providing evidence. Only one per breach
Restriction notice (section 14)	Enhanced tier premises or qualifying events only, where procedures or measures are deficient and restrictions are necessary to reduce the risk of harm	Can restrict how the premises are used, opening times or numbers present, or stop an event. Lasts up to six months, extendable by up to three months at a time
Penalty notice (sections 17 to 21)	The SIA is satisfied on the balance of probabilities that a relevant requirement has been breached, including ignoring a notice	A financial penalty, with at least 28 days to pay, and possibly daily penalties for continuing to ignore a compliance or restriction notice

Maximum non-compliance penalties are £10,000 for standard tier premises and £18 million or 5% of qualifying worldwide revenue (whichever is higher) for enhanced tier premises and qualifying events. Daily penalties are capped at £500 and £50,000 respectively. The SIA must set penalties at an appropriate and proportionate level, taking account of the effects of the breach, any action to put it right, and your ability to pay. See penalties for detail.

Appeals, tribunal decisions and prosecutions

Appeals: you can appeal a compliance, restriction or penalty notice (or a variation) to the First-tier Tribunal within 28 days. Grounds are an error of fact, an error of law, or that the decision was unfair or unreasonable. Compliance and penalty notices are suspended while an appeal is pending unless the tribunal orders otherwise; restriction notices stay in force unless the tribunal suspends them.
Scope decisions: under section 11, the SIA or anyone with some control of the premises or event can ask the tribunal to decide questions such as whether premises qualify, whether they are enhanced tier, their principal use, whether an event qualifies, or who is responsible.
Prosecutions: in the most serious cases, where proportionate and in the public interest, the SIA may prosecute in England, Wales and Northern Ireland, or refer to the Procurator Fiscal in Scotland. Offences include failing to comply with an enhanced tier compliance notice or any restriction notice, failing to comply with an information notice, obstructing or impersonating an inspector, and knowingly or recklessly giving false or misleading information.

There is no right under the Act for members of the public to sue for compensation for a breach, although existing claims such as negligence are unaffected.

How to prepare for the SIA

The law is expected to come into force in spring 2027, and the SIA has said you cannot notify it until then. It is building its online portal and has asked for volunteers to help test it from early 2027. In the meantime:

Confirm whether you are in scope, your tier and your responsible person, and record your reasoning. See qualifying premises explained.
Prepare the information you will need to notify, as set out in notifying the SIA.
Put proportionate procedures in place, brief staff and keep simple records of briefings and drills.
If you are enhanced tier, start your measures assessment and compliance document early, and see our enhanced tier introduction.
Sign up to the SIA's Martyn's Law email updates, and read its final section 12 guidance when it is published.

Standard tier venues that want everything in one place can use our packs, which include an SIA notification checklist and a drill and review log alongside tailored procedures. Nothing we offer is approved or endorsed by the SIA or the Home Office, and the SIA does not endorse any provider.

Frequently asked questions

Will the SIA inspect my venue without warning?

Normally no. Inspectors must give at least 72 hours' written notice to enter without a warrant. A magistrate can issue a warrant for entry without notice in limited cases, such as where notice would defeat the purpose or access is urgently needed.

Can the SIA close my premises?

For enhanced tier premises and qualifying events, a restriction notice can prohibit or restrict how premises are used, their hours or numbers, or stop an event, for up to six months at first. Standard tier premises cannot be given restriction notices.

Can I appeal an SIA decision?

Yes. Compliance, restriction and penalty notices can be appealed to the First-tier Tribunal within 28 days, on grounds of error of fact, error of law, or that the decision was unfair or unreasonable.

Does the SIA recommend consultants or products?

No. The SIA has said neither it nor the Home Office can endorse or recommend specific companies or services, and using third party products or services is not mandatory.

When will the SIA start enforcing Martyn's Law?

Only once the duties are commenced, which is expected in spring 2027. The SIA has said it will start with a supportive approach but will use its enforcement powers where necessary.

Sources

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