Martyn's Law for gyms and leisure centres

Counting mixed facilities

Gyms, leisure centres and swimming pools fall under Schedule 1, paragraph 3 (entertainment, leisure or recreation for visiting members of the public). Paragraph 18 says it does not matter that access is limited to paying members, so a members-only gym can still be in scope. The question is whether 200 or more people, including staff, may reasonably be expected on the premises at the same time, from time to time (section 2).

A leisure centre often needs more than one method. Supplementary document A lists options including fire safety occupancy, historic attendance data, fixed seating and other evidenced methods, and notes that some methods may only work for parts of the premises. For example, you might use entry gate or booking data for the gym floor and classes, pool session limits for swimmers, fixed seats for spectator seating, and a staff rota for everyone working on site.

Cafés, physiotherapy clinics or shops inside the building need care. If they form part of your premises, the people in them count towards your figure. If one is run independently and is controlled by someone else, it may also be separate premises in its own right, assessed only on its own numbers (guidance paragraphs 4.13, 4.14 and 4.30). Count the people who are genuinely on your premises; do not leave out parts you control, and do not add in neighbouring buildings that are not part of your premises.

Peak times

The guidance says to consider the busiest times, and that "from time to time" means occasionally, with some predictability (paragraphs 4.24 and 4.31). For a leisure centre that might be a weekday evening when classes, the gym and a swimming club overlap, January membership surges, school holiday sessions or a gala with spectators.

A one-off spike that could not have been foreseen and is not expected to recur does not bring premises into scope (paragraph 4.34). But planned events such as an annual swimming gala or tournament that regularly takes you over 200 are likely to count. Keep the evidence behind your figure, because the SIA can ask how you assessed it.

Multi-site operators

If you run several gyms or centres, each site is assessed on its own numbers. The guidance gives the example of a supermarket chain whose stores are each separate premises with their own circumstances, and says a responsible person with several premises should avoid a one-size-fits-all approach (paragraphs 4.9 and 6.6). Some sites may be out of scope, some standard tier and a few large centres possibly enhanced tier.

The responsible person is whoever has control of each site for its leisure use (section 4). Where a council owns a centre but a leisure trust or contractor runs it, control usually depends on who has possession and makes the operating decisions under the contract, so check the agreement. A central template is useful, but each site's procedures should reflect its own exits, layout, staffing and pool or studio arrangements.

What the duties require

At the standard tier (200 to 799), the responsible person must, so far as is reasonably practicable, ensure appropriate procedures are in place for evacuation, invacuation, lockdown and communication (section 5), and notify the SIA (section 9 and SI 2026/793). There is no statutory requirement to make physical alterations or buy equipment (guidance paragraph 7.25), and no specific training course or certificate is required. Staff who would carry out the procedures need to know them and their role (paragraph 7.51).

At 800 or more, a centre would be enhanced tier. The responsible person must also assess and put in place appropriate public protection measures so far as reasonably practicable, prepare a compliance document and give a copy to the SIA, and, if the responsible person is an organisation, designate a senior individual (sections 6, 7 and 10).

Writing your procedures down is not a legal requirement at the standard tier, but the guidance says you should, as it may be hard to show compliance without it (paragraph 7.32). The duties are expected to start in spring 2027; no commencement date has been announced.

A practical checklist for gyms and leisure centres

Use this as a starting point and adapt it to each site.

• Confirm who has control of each site, especially where a council, trust or contractor is involved.
• Choose and record a counting method for each area, then add staff.
• Identify your peak periods and any recurring galas, tournaments or events.
• Plan for people in pools and changing rooms who may not be dressed or able to move quickly.
• Agree how music in studios is stopped and how warnings reach the pool hall and changing rooms.
• Brief reception, lifeguards, instructors and casual staff on their role in each procedure.
• Agree with any independent café or clinic operators how procedures fit together.
• Plan SIA notifications per site once the duties are commenced.

Common questions

Read next

• How to calculate your capacity
• Martyn's Law for multi-site operators
• Who is the responsible person?
• Notifying the SIA
• Procedure packs for standard tier venues