Pool Re, Great Britain’s government-backed terrorism reinsurer, welcomes the Royal Assent given to the Terrorism (Protection of Premises) Act, on the 3rd April 2025, meaning that the legislation is now officially an Act of Parliament under law.
In the face of an ever evolving and less predictable threat landscape, noting that since 2017 the Security Services and Police have interdicted 43 late-stage foiled, the Terrorism (Protection of Premises) Act will improve public safety, through increased preparedness and protection of in-scope public venues and events.
The Terrorism (Protection of Premises) Act, or Martyn’s Law, addresses part of 169 recommendations made by the Manchester Arena attack inquiry, one of which was that of a duty to afford better protection to people within Publicly Accessible Locations.
Pool Re wishes to recognise and pay thanks to the extraordinary efforts of the campaign team in promoting the legislation, spearheaded by Figen Murray, mother of Martyn Hett who lost his life alongside 21 other victims of the Manchester Arena attack in 2017. Her tireless campaign efforts have been instrumental to the passing of Martyn’s Law.
The Home Office team, and supporting partners, should also be commended for their determination and engagement across industries, businesses and sectors, to ensure a proportionate and robust bill was introduced for parliamentary scrutiny.
As we now enter a implementation phase, expected to last at least 24 months, Pool Re awaits publication of further details, guidance and supporting tools, to be provided by the Home Office and supporting partners, to ensure that businesses can begin their preparations for implementing the legislative requirements.
Pool Re welcomes the move of the Martyn’s Law regulator, the Security Industry Authority, as an Arms-Length Government body under the portfolio of the Homeland Security Group (HSG) and Dan Jarvis MP, the Minister of State of State for Security, to ensure that the regulator function is aligned with the policy and guidance functions of the Act.
Pool Re is also pleased by the recent announcement that the Register of Security Engineering Specialists (RSES) will be responsible for administering the list of qualified individuals under a Counter Terrorism Security Specialists Register. This will provide a centralised register of competent individuals, assessed against a competency standard, whom business can consult for appropriate advice on the implementation of protection procedures or measures within Martyn’s Law. Pool Re awaits further details on the Competent Person in the Workplace (CPIW) scheme.
Updates to the Legislation
Marking the end of a six month legislative process since the bill was introduced for legislative scrutiny (14th October 2024), the Act is passed with cross-party support across the House of Commons and House of Lords.
Only a small number of minor of technical amendments are made, which are intended to improve the clarity of the legislation:
| Amendment | Description |
| Qualifying premises and events (Amendments 1, 2, 10, 11, 12, 13) | Attendance of a premise or event for personal attendance reasons will not be in scope, as it is not a Publicly Accessible Locations. Qualifying events must be a ticketed event, rather than attendance by invitation, e.g. wedding, private office party. |
| Clarity of guidance provided (Amendment 5) | Ensuring that guidance and support provided to those in scope of the legislation, is timely, correct and supportive, based upon consultation with necessary persons, to enable implementation and compliance with the legislation. |
| Changes to powers given to Secretary of State (Amendments 7, 8, 9) | Ensuring a correct balance to ensure the bill can be kept up to date, (i.e. changes in protection measures, procedures, or capacity thresholds), whilst maintaining safeguards for powers to be used appropriately and proportionately. |
In sum, qualifying criteria(s) of the legislation are:
| Qualification | |
| Publicly Accessible Location | Where the public has access to the premises or part of the premises, with an expected capacity of 200 persons (Standard Tier) or 800 persons (Enhanced Tier). |
| Qualifying Activity | Premises which are used for a qualifying activity such as shops, nightclubs, entertainment venues, sports grounds, education establishments, and healthcare facilities. |
| Events (above a maximum expected capacity of 800) where there are express permission for entry (e.g. ticketing, payment). | Events (above a maximum expected capacity of 800) where there are express permission for entry (e.g. ticketing, payment). |
Based upon the established tiered approach, the following requirements are expected:
| Tier | Requirements |
|
Standard Tier (200-799 expected maximum capacity venues) |
|
|
Enhanced Tier (800+ expected maximum capacity venues, and events) |
|
Pool Re provides a full summary of the legislative requirements on the Pool Re Martyn’s Law Hub, and will continue to provide support to our Members and policyholders in navigation of the Act.