Martyn's Law for churches and places of worship

The special standard tier rule

Schedule 1, paragraph 9 of the Act covers use for communal worship, or other communal religious practice, in accordance with the tenets of a particular religion or religious denomination. Paragraph 9(2) says that where this is the relevant Schedule 1 use of qualifying premises, the premises are standard duty premises "regardless of how they would otherwise be treated". The statutory guidance confirms that places of worship in scope are standard tier even if 800 or more people are expected (paragraphs 4.36 and 4.37).

The rule changes the tier, not the starting point. The premises must still meet the normal tests in section 2: a building (or building and land) wholly or mainly used for Schedule 1 uses, where 200 or more people may reasonably be expected at the same time from time to time. Below 200, the Act does not apply to the building.

The relevant Schedule 1 use is the principal use where a building has more than one use (section 4(2)). So the rule only applies where worship is the principal use. The guidance says a religious event at premises mainly used for something else, such as a town hall, does not benefit from it (paragraph 5.30). The Home Office principal use guidance gives the example of a place of worship that also hosts regular concerts of 800 or more: because it was built and continues to be used for worship, its principal use is worship and it stays standard tier.

Events held at premises wholly or mainly used for worship are also excluded from being qualifying events (Schedule 2, paragraph 6). The guidance gives the example of a concert of 800 or more in a church, which is not a qualifying event, so the building stays under its standard tier duties (paragraph 5.29).

Who is responsible

The responsible person is whoever has control of the premises in connection with their use as a place of worship (section 4). The guidance describes control as ordinarily meaning physical possession, with the right and ability to make decisions about how the premises are managed and used, including who may stay on site (paragraph 6.3). In the synagogue example in the guidance, it is the primary governing body with control of the building.

Who that is varies by faith and structure. Depending on your governance, it may be a board of trustees, a management committee, a parochial church council, the minister together with officers such as churchwardens, a diocese or another national body. Ownership alone does not decide it. Check your governing documents and any guidance from your denomination before notifying the SIA, and record why you reached your view.

Where a separate body runs the church hall, or a hall management committee controls it, that body may be the responsible person for the hall if the hall is separate premises. Where more than one person shares control of the same premises, each is responsible and they must co-ordinate, so far as reasonably practicable (sections 4(4) and 8).

Volunteers and stewards

Volunteers count. The guidance defines staff as everyone working at the premises, whether as employees, contractors, volunteers or otherwise, and staff must be included in your figure (paragraph 4.23). Stewards, welcomers, sound desk operators, musicians, kitchen helpers and children's leaders all count.

Volunteers can also be the people who carry out your procedures. There is no statutory requirement for specific counter-terrorism training, but those who would put procedures into action must be made aware of them and their role (paragraph 7.51). The guidance gives the example of a village hall that briefs volunteers at onboarding and displays the procedure in the staff room, and decides an expensive course is unnecessary (paragraph 7.55).

A short briefing at the start of each rota, a prompt card at each door and an occasional walk-through are practical ways to do this. Free resources such as ACT Awareness e-learning on ProtectUK can help with general awareness.

Church halls and shared or hired rooms

If the hall is part of the same premises as the place of worship, for example attached to the church and used with it, it is likely to be treated together with the church and fall under the same standard tier rule. Its users count towards your figure.

If the hall is a separate building used mainly as a venue for hire, it may be separate premises with a principal use as a hall (Schedule 1, paragraph 6). It would then be assessed on its own numbers, the special worship rule would not apply to it, and a large public ticketed event there could in principle be a qualifying event. Look at how the hall is actually used and controlled.

When you hire out the building, you normally remain the responsible person. The guidance says the hire agreement can require the hirer to carry out public protection tasks, and that you should be able to show you set out clear requirements and took reasonable steps to check they were followed (paragraphs 6.13 to 6.15 and the synagogue example at 5.29).

Services, weddings, funerals, festivals and concerts

All of these count towards your figure if they happen from time to time and are reasonably expected. A wedding or funeral for invited guests is a private occasion rather than a public event, but the people present are still on your premises and count. A genuinely unforeseen one-off, such as an unexpectedly large funeral that is not expected to recur, does not on its own bring premises into scope (guidance paragraph 4.34).

Concerts and festivals in a building whose principal use is worship do not create qualifying events, but they may affect what procedures are appropriate. The guidance says larger standard tier premises, which may include some places of worship, may find it useful to consider the extra points written for enhanced tier procedures, even though they are not legally required (paragraphs 7.30 and 7.31).

The special rule is tied to the building. A ticketed or registered celebration held elsewhere, such as in a park, is treated like any other event and could be a qualifying event if it meets the section 3 tests.

A practical checklist for places of worship

A starting point for volunteer-run premises. Adapt it to your building and community.

• Confirm your peak numbers, including volunteers, and keep the evidence, such as headcounts or festival records.
• Agree who has control and is the responsible person, using your governing documents.
• Decide whether your hall is part of the same premises or separate, and record why.
• Name a duty lead and deputy for every service or gathering.
• Write simple evacuation, invacuation, lockdown and communication procedures.
• Brief stewards and welcomers, and put a prompt card by each door.
• Add public protection expectations to your hire agreement.
• Plan your SIA notification for when the duties are commenced, expected in spring 2027.

Common questions

Read next

• Martyn's Law for places of worship: full guide
• Who is the responsible person?
• How to calculate your capacity
• Procedure packs for standard tier venues