Who is the Responsible Person Under Martyn’s Law?

The Terrorism (Protection of Premises) Act 2025, commonly known as Martyn’s Law, establishes clear legal duties to bolster public safety across UK venues and events. At the heart of compliance lies a single core concept: identifying the Responsible Person.

With enforcement expected to begin in spring 2027, building owners, operators, educational institutions, and event planners must clarify who holds legal accountability well in advance.

Control Dictates Legal Duty

Under the Act, the Responsible Person is not necessarily the property owner. Instead, it is the individual or entity that exercises operational control over the premises for the activity bringing it into scope, or over a site during a qualifying event.

• Corporate Accountability - The role typically belongs to a company, institution, or organization rather than a specific individual.
• Non-Delegable Duty - While day-to-day security tasks (like guard patrols or stewarding) can be outsourced to third-party contractors, legal liability cannot be transferred. The controlling entity remains fully accountable regardless of contract terms.

Determining Responsibility in Complex Settings

1. Multi-Use Buildings and The Principal Use Test

When a single property hosts multiple activities, the Act relies on the Principal Use of Premises Regulations 2026 (in effect since 15 October 2026) to determine the dominant function.

Assessing principal use involves evaluating two stages:

1. Building Character - Examines original design intent, current function, layout/scale, and official classifications (such as planning permissions or licensing).
2. Contextual Circumstances - If the first stage is inconclusive, equal weight is given to factors such as operating hours, floor space allocated to each activity, and whether one service merely supports another (for instance, an event space with an auxiliary café).

Note: Fully self-contained units with defined boundaries (such as a retail shop within a mall) are evaluated as standalone premises rather than part of the broader building's principal use.

2. Temporary and Qualifying Events

For qualifying public events, duty sits with the party controlling the location for the duration of the event.

• Rented Land - If an event planner leases farmland under an agreement conferring full operational control, the planner becomes the Responsible Person.
• Retained Control - If the landowner retains site management and simply hires contractors to handle access points, liability remains with the landowner.
• Tier Rules - All qualifying events are automatically classified under the Enhanced Tier (there is no Standard Tier for events).

3. Education Settings and Student Housing

Guidance from the Department for Education clarifies designated duty-holders across academic environments:

• Schools and Colleges - The governing body holds the role, or the proprietor where no board exists. For academies, duty falls to the Academy Trust.
• Universities - The primary governing body of the institution carries responsibility for higher education premises.
• Institution-Run Student Accommodation - Housing managed directly by or for a higher education institution counts as part of higher education use, placing duty on the university governing body.
• Private Student Housing - Commercial accommodation let directly to students must be assessed independently under Schedule 1 criteria on its own merits.

Navigating 5 Common Scenarios

1. Standalone Tenant (Shop or Café) - The tenant holding operating control over the specific unit assumes the legal duty.

2. Shopping Centre Complex - Venue management covers shared concourses and public entry points, while individual tenants cover their respective bounded units.

3. Multi-Site Business Network - A single parent corporation can act as the designated duty-holder across all of its locations.

4. Shared Control Venues - Where multiple operators share control, more than one Responsible Person exists, and they must actively co-ordinate.

5. Fully Demised Lease - The tenant holds the main duty for the unit. The landlord is not the Responsible Person, though they must co-operate where enhanced tier duties apply.

Office spaces alone are not listed premises. Responsibility only arises if a distinct sub-area (such as a ground-floor retail unit or public eatery) meets qualifying thresholds.

Tiers, Tasks, and Senior Leadership

Duties by Tier

• Standard Tier - Duty-holders must notify the Security Industry Authority (SIA) and maintain proportionate public protection routines covering evacuation, invacuation, lockdown, and emergency communication.
• Enhanced Tier - In addition to standard requirements, duty-holders must implement advanced physical security measures, submit documented plans to the SIA, and formally designate a Senior Individual.

The Role of the Senior Individual

Organizations managing Enhanced Tier properties or qualifying events must nominate a Senior Individual. This must be a manager or director with real authority over operational budgets and strategy who takes oversight for statutory compliance.

Co-ordination vs. Co-operation

Where multiple stakeholders overlap, the law mandates two distinct duties:

1. Co-ordination - Required when multiple Responsible Persons share a site or operate a qualifying venue inside a larger venue (such as a multiplex cinema within a commercial shopping center). Parties must align emergency exits, alarm protocols, and lockdown procedures.
2. Co-operation - Required from third parties who exercise partial control without being the primary duty-holder (such as commercial landlords). Landlords must reasonably assist tenants with necessary physical upgrades (such as turnstiles or access gates) mandated by security assessments.

SIA Notification Timelines

Responsible Persons must register their venue or event details through the SIA online portal according to specific windows:

• Existing Premises - Within 3 months from the legal commencement date.
• Change of Responsible Person - Within 28 days of taking on or relinquishing operational control.
• Qualifying Events - Within 14 days from when the event date is first made public.

5 Steps to Martyn’s Law Compliance

1. Audit Properties - Catalog all spaces, venues, and planned events against the Act’s listed uses.
2. Review Control Structures - Examine operational leases, venue hire terms, and management agreements to establish true control.
3. Document Principal Use - Record formal assessments for multi-use properties, updating records whenever layouts or licenses change.
4. Designate Leadership and Delegations - Formally appoint Senior Individuals where required and log all internal delegations.
5. Establish Shared Frameworks - Agree on joint emergency communication channels, shared assembly points, and notification procedures with neighbouring tenants and landlords.

Execution at the Front Desk

Front-of-house staff, security teams, and mailroom operators often execute the day-to-day safety workflows established by the Responsible Person. Clear visitor control, uncluttered entryways, and prompt internal communication are critical during emergency lockdowns or evacuations.

Digital log tools (such as Parcel Tracker mailroom software) help high-footfall environments like student accommodation and university campuses maintain clean reception areas and instant recipient notifications. While software does not replace legal compliance, streamlined front-desk workflows support the operational readiness required under Martyn's Law.

Disclaimer: This article provides general educational information regarding the Terrorism (Protection of Premises) Act 2025 and should not be taken as formal legal advice. Refer to official guidance from the UK Home Office and Security Industry Authority (SIA) for binding statutory details.

FAQs Answered

What defines a Responsible Person under Martyn’s Law?

The entity or individual exercising actual control over a venue's qualifying activity, or over a site during a qualifying event.

Can compliance responsibilities be outsourced to a security vendor?

No. Security contractors can carry out designated tasks, but legal accountability remains strictly with the Responsible Person.

What triggers the requirement for a Senior Individual?

Organisations operating Enhanced Tier premises or running qualifying public events must formally name a Senior Individual to oversee compliance.

What are the registration deadlines for the SIA portal?

Existing premises have 3 months from the law's commencement to register, structural or management changes must be reported within 28 days, and qualifying events must be registered within 14 days of public announcement.