Martyn’s Law: what the new statutory guidance means for schools

An overview of the Terrorism (Protection of Premises) Act 2025 and the practical steps schools and academy trusts should take to prepare for compliance

Martyn’s Law (the Terrorism (Protection of Premises) Act 2025), which applies to education settings, is UK legislation designed to improve protective security and preparedness at public premises in the event of a terrorist attack. It was passed following the 2017 Manchester Arena attack and is named in memory of Martyn Hett, one of the victims.

The Act requires those responsible for certain premises to take proportionate, risk‑based actions to help keep people safe and reduce harm if a terrorist incident were to occur. For most academy trusts, it will mean formalising and evidencing what many schools already do, rather than introducing radical new controls.

The Act received Royal Assent on 3 April 2025. The Government has confirmed an implementation period of at least 24 months, meaning the law is not expected to be enforced until around April 2027. Statutory guidance was published in April 2026, giving clarity on scope and expectations so organisations can begin preparing. There is no requirement to be compliant yet, but academy trusts are strongly encouraged to plan and embed arrangements during the implementation period.

This blog outlines the relevant legal framework, identifies the affected parties, and details the practical steps required of academy trusts.

Does Martyn’s Law apply to academy trusts?

The guidance explicitly confirms that education settings are in scope of Martyn’s Law, as they are publicly accessible premises where large numbers of people gather.

Martyn’s Law applies to education settings where it is reasonable to expect 200 or more people (staff, pupils, visitors) to be present at the same time. This includes early years, primary schools, secondary schools, special schools and further education colleges.

Settings with fewer than 200 people are out of scope, but the Government still encourages proportionate preparedness planning as good practice.

Which tier will academy trusts fall into?

The Act introduces two tiers; standard tier and enhanced tier.

For schools, the key clarifications are:

Schools with fewer than 200 people present at the same time are out of scope, but encouraged to plan voluntarily.
Schools with 200 or more people (pupils, staff and visitors combined) are in scope.
Early years, primary, secondary and FE settings are always treated as Standard Tier, even if numbers exceed 800. Schools do not move into the Enhanced Tier, unlike other large public venues. This applies regardless of whether more than 800 people are regularly present (including pupils, staff and visitors).

What will academy trusts be required to do?

Identify the “Responsible Person”

The guidance clarifies that each qualifying school must have a responsible person.

For academy trusts, this will usually mean:

The trust board as the legal duty holder
Responsibilities delegated operationally to the CEO, Headteacher or senior leader

The Responsible Person is accountable for ensuring the Act’s requirements are met across all sites in scope.

Notify the regulator

Schools in scope will need to notify the Security Industry Authority (SIA) that they are a qualifying premises. The SIA is the appointed regulator for the Act.

The guidance stresses that, at least initially, the SIA’s role will be education, support and proportionate oversight.

Put “reasonably practicable” public protection procedures in place

This is the core requirement for schools, and the guidance is intentionally clear that it is about procedures, not physical security. This means having documented, understood procedures covering:

Lockdown (to secure premises against attackers)
Evacuation (to get people out of the premises)
Invacuation (to move people to a safe place)
Communication during an incident (communication (to alert people on premises to the danger)

These procedures should be proportionate to the school, aligned with existing safeguarding and emergency arrangements and reviewed periodically.

There is no requirement to install physical security (e.g. scanners, barriers, CCTV upgrades).

Embed training and awareness

The guidance expects schools to ensure:

Staff know the procedures, what to do and who to contact
Staff understand indicators and escalation routes
Training is proportionate and realistic

The intention is to build confidence and preparedness, not fear.

It does not mandate a specific training product or external provider, and explicitly discourages unnecessary spending.

What does Martyn's Law not require?

No mandatory physical building works
No routine armed security
No requirement to hire external consultants
No requirement to follow Protect Duty guidance verbatim

Staff‑led measures are sufficient and expected.

Governance implications for academy trusts

From a trust governance and assurance perspective, boards should expect to:

Assign clear responsibility (and evidencing it)
Receive assurance that:
- Procedures exist and are approved
- Staff are briefed and awareness activity
- Arrangements are kept under review
Ensure compliance is documented and defensible

This is likely to become a future area of internal scrutiny, audit and regulatory review, particularly once enforcement begins in 2027.

Key takeaway for academy trusts

For academy trusts it will mean:

Understanding whether each site is in scope
Formalising and evidencing existing emergency arrangements (around lockdown, evacuation, invacuation and communication)
Making sure staff know what to do if the unthinkable happens

Used well, it should strengthen safeguarding, risk management and governance assurance, rather than create disproportionate burden.

Closing remarks

All current external and internal audit clients are welcome to contact the Price Bailey Academy Helpdesk with any queries arising from Martyn’s Law.

Price Bailey works with academy trusts to provide independent internal scrutiny reviews covering business recovery and disaster review which can include Martyn’s Law/Terrorism Act readiness. Please get in touch with our team for an informal conversation using the form below.

We always recommend that you seek advice from a suitably qualified adviser before taking any action. The information in this article only serves as a guide and no responsibility for loss occasioned by any person acting or refraining from action as a result of this material can be accepted by the authors or the firm.

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