With the threat of terrorism likely to be at an all time high in light of continuing hostilities across the world, it is timely that the Home Office has just released guidance to those with control of certain premises and events on how they can comply with their forthcoming responsibilities under the Terrorism (Protection of Premises) Act 2025. By way of reminder, the purpose of the Act is to reduce the risk of physical harm to individuals and the vulnerability of larger premises and events arising from acts of terrorism.
Home Office guidance under s27
On 15 April 2026, the Home Office laid before Parliament its statutory guidance under s27 of the Act, explaining core concepts and how those responsible for premises and events within scope can comply with their legal duties.
The Minister of State for Security (Dan Jarvis) confirmed in his accompanying written statement that:
"The government strongly advises against using third party providers who claim they can make premises or events compliant with the Act at this time. No third-party product is endorsed by the Home Office, or by the Security Industry Authority, which will act as the regulator for Martyn’s Law."
The guidance is also accompanied by three non-statutory documents which provide some non-exhaustive:
A: methods for assessing numbers of individuals who can be reasonably expected to be present at premises/events at the same time;
B: examples of premises and events falling within scope of the Act, demonstrating key concepts; and
C: further resources, including training and awareness products from the National Counter Terrorism Security Office and the National Protective Security Authority.
SIA guidance under s12
At the same time, the Security Industry Authority (SIA) also published a consultation on its draft statutory operational guidance under s12 of the Act, explaining how it will carry out its role as regulator and oversee and support compliance. The call to action is for those responsible for premises and events to engage directly and respond to the consultation by Friday 12 June. Thereafter, a final version of the guidance will be prepared for approval by the SIA Board and the Secretary of State. The SIA will separately publish practical information on operational processes, including how and when responsible persons should make notifications that they are within scope of the Act.
Details of the Home Office guidance
The s27 guidance builds on the factsheets that have already been published on specific issues within the Act and almost provides a workbook, together with flowcharts, for those already familiar with the legislation.
Chapter 3 provides a glossary of terms which will be helpful in understanding provisions of the Act. For example, the Act applies to premises where it is reasonable to expect that 200 or more individuals may be present 'from time to time' and to events where it is reasonable to expect 800 or more people may be present 'at the same time'. The guidance explains how businesses should interpret phrases such as 'from time to time' and 'at the same time', as well as the all-important concept of ensuring so far as 'reasonably practicable' that appropriate public protection procedures and measures are put in place.
Chapter 4 looks at qualifying premises and provides more examples of the uses specified in Schedule 1. For example, entertainment and leisure activities include "nightclubs, theatres, cinemas, concert halls, arenas, theme parks, zoos, aquariums, amusement arcades, casinos, gyms, leisure centres, swimming pools and bowling alleys" and visitor attractions "could include heritage railway lines". Chapter 5 looks similarly at qualifying events.
Chapter 6 looks at the responsible person and Chapter 7 the legal requirements under the Act. In here you can find more detailed general guidance on developing public protection procedures as well as specific suggestions. One example is a "grab bag/incident response kit [which] could include up-to-date emergency contact details, staff lists, floor plans or other critical documents….The responsible person should consider where such a bag or kit could be safely stored and who would have access to it." Another example proposes a credit-card-sized aide memoire of relevant procedures and how to follow them.
Reference is also made to templates that will be developed which will be "optional and indicative, but they will be designed to assist with the documentation of public protection procedures".
Chapter 8 deals with public protection measures for enhanced tier premises and qualifying events.
Next steps
With the Act receiving Royal Assent on 3 April 2025 and an implementation period of at least 24 months, this guidance comes roughly at the half way point. The guidance is clear that "while there is no legal requirement to comply until the legislation comes into force, those in scope of the Act will wish to begin considering the requirements. This guidance has been published in advance of commencement to enable those responsible to prepare." Now is the time to embed a good security culture with shared values from the top down.
