Martyn’s Law for parish and town councils
A council often holds several buildings and runs several events, and the Act looks at each of them separately. Here is how to work through the list, and what to record.
Parish and town councils are in an awkward position with Martyn’s Law: they often hold several premises, none of which they staff, and they are used to being the body that has to have an answer. The good news is that the answer for most council assets is short.
Assess each premises separately
There is no council-wide test. The Act looks at each qualifying premises on its own, so a council with a pavilion, a small hall, a cemetery chapel and an office has four separate answers — and in most cases four separate “out of scope”s.
The rule, in three lines
- Fewer than 200 people reasonably expected at once — you are out of scope. This is true for every kind of premises, including churches and schools. A chapel that seats sixty is out.
- 200 to 799 — standard tier.
- 800 or more — enhanced tier, except places of worship and childcare or education settings, which stay standard tier however large they get.
Count everybody who could be there at once: the public, your volunteers, the performers, the person on the door, the ones washing up. Not tickets sold, and not the figure on your fire certificate.
Work down your asset list and ask the same question of each building: on its busiest realistic day, how many people are inside at once, counting your staff and volunteers? For a sports pavilion the honest answer is often forty. For a cemetery chapel it is often twenty. Those are out, and no further action follows.
Who is the “responsible person”?
This is where councils get stuck, and it is worth being precise. The duty falls on whoever has control of the premises — not on whoever owns the freehold.
- If the village hall is run by an independent charitable trust with its own committee, the duty is generally the trust’s, even where the council owns the building.
- If the council is the sole managing trustee, or runs the hall directly through a committee of the council, the duty sits with the council.
- If you let the building to a hirer for their event, control is a matter of what your hire agreement says. Most standard hire agreements leave day-to-day control with the hall, not the hirer.
If the answer is genuinely unclear, that ambiguity is itself worth resolving — not because the Act demands it today, but because “we each assumed the other one had it” is the worst place to be later.
What about our events on the recreation ground?
Events are dealt with separately from premises in the Act, and the bar is considerably higher: the events limb is aimed at large events with controlled access — ticketing, passes, or checks on the way in — at a scale well above the 200-person premises threshold. A free village fête on open ground that anybody can wander into is very unlikely to meet it.
If you run something genuinely large and ticketed — a town festival with fencing and wristbands — read the statutory guidance on qualifying events properly rather than relying on a summary, including this one.
Minute the decision
This is the specifically council part, and the most useful thing on this page. Councils get audited, councillors change, and clerks move on. A decision that lives in someone’s memory is a decision that will be taken again from scratch in two years.
A resolution you can adapt
“Council considered the application of the Terrorism (Protection of Premises) Act 2025 to its premises. Council noted that the duties are not yet in force. Having assessed the maximum number of people reasonably expected at each premises at any one time, including staff and volunteers, Council RESOLVED that [Pavilion, 40] and [Cemetery Chapel, 20] fall below the 200-person threshold and are out of scope, and that [Village Hall, 240] falls within the standard tier. Council further RESOLVED to review this assessment annually and on any material change to a building or its use.”
Adapt the numbers and names. The value is in recording the figure you used and the date you used it — that is what makes the decision defensible when somebody asks in 2028.
If one of your premises is in scope
Then it is standard tier, and standard tier is deliberately light: have the four public protection procedures in place, and notify the regulator when notification opens. There is no documented risk assessment duty at this tier and no requirement to buy equipment or hire anybody.
In practice the work is one meeting: agree what you would do to get people out, to bring them in away from the windows, to secure the building, and to tell everybody — then write down what you agreed and who agreed it.
Not sure which side of the line you are on?
The checker walks you through the same rules in about two minutes. It is free, there is no account, and your answers never leave your browser.
Working with your hall committee
Where the hall is run by a separate trust, the most useful thing a council can do is not to take the duty over but to make sure somebody has consciously accepted it. A line in the minutes of both bodies — the council recording that the trust has control, the trust recording that it accepts it — costs nothing and closes the gap that would otherwise sit between you.
Common questions
Does Martyn’s Law apply to parish councils?
It applies to premises, not to councils as organisations. Each building the council controls is assessed on its own: 200 or more people reasonably expected at once brings it into scope, fewer than 200 leaves it out. Most parish assets — pavilions, small halls, cemetery chapels — sit comfortably below the threshold.
The council owns the village hall but a trust runs it. Who has the duty?
Generally whoever has control of the premises, which is usually the trust and its committee rather than the freeholder. Where the council is sole managing trustee, or runs the hall through a committee of the council, the duty sits with the council. Where it is unclear, record in both sets of minutes who is accepting it.
Is our village fête a qualifying event?
Very unlikely. The events limb of the Act is aimed at large events with controlled access — ticketing, passes or checks on entry — at a scale well above the 200-person premises threshold. An open, free-to-enter fête on a recreation ground does not normally meet it. If your event is large and ticketed, read the statutory guidance on qualifying events directly.
What should we minute?
The figure you used for each premises, the conclusion you drew, the date, and a commitment to review annually or on material change. Recording the number matters more than the prose: it shows the assessment was actually made rather than assumed.
Do we need to do anything before the duties come into force?
No. Nothing is required of you today and no penalty exists yet. Many councils do the assessment now anyway because it is a single agenda item, and because it is easier to do calmly than in the window when notification opens.
Where this comes from
Everything above is our plain-English reading of the following. Where we quote a paragraph number, it is from the Home Office statutory guidance. If you want the law itself rather than our summary of it, start with the first link.
- Terrorism (Protection of Premises) Act 2025 (c. 10) legislation.gov.uk The Act itself. Royal Assent 3 April 2025.
- Terrorism (Protection of Premises) Act 2025: statutory guidance GOV.UK (Home Office) Published April 2026, last updated 18 May 2026. The paragraph numbers quoted in these guides are from this document.
- Terrorism (Protection of Premises) Act 2025: overarching factsheet GOV.UK (Home Office) The short version, in the government’s own words.
- Security Industry Authority GOV.UK The regulator for Martyn’s Law. Watch here for the notification process opening.
Last reviewed . Martyn’s Law is not yet in force and the guidance is still developing — if you are reading this long after that date, check the sources above for anything newer.
This is guidance, not a legal determination. Standfast helps you think clearly and get ready. It does not decide your legal position, and nothing on this page is legal advice. If your circumstances are unusual, or a great deal turns on the answer, take advice.