The Security Industry Authority (SIA) has closed its consultation on draft statutory guidance for the Terrorism (Protection of Premises) Act 2025, known as Martyn’s Law. The consultation received wide engagement from various stakeholders, including venues, local authorities and security professionals across the UK, with approximately 200 written representations being submitted.

The consultation sought feedback on the draft guidance, which sets out how compliance with Martyn’s Law will be overseen by the SIA once the Act is in force.

The Institute of Licensing (IoL), in addition to producing its own non-statutory interim guidance, submitted a response to the consultation, highlighting pressure points for the SIA to address in the final version of its guidance.

What did the IoL raise?

Firstly, the draft guidance failed to recognise the existing regulatory framework placed on venues under the Licensing Act 2003 and the Gambling Act 2005. Clearer integration would mitigate the risk of confusion for operators and avoid the perception that they are being pulled in different directions by parallel regulators. From our experience, when multiple regulators operate in the same space, such as the gambling sector, conflicting regulation and guidance can cause uncertainty and frustration for operators, resulting in significant time and expense in managing competing regulatory expectations.

Secondly, licensing authorities and police already inspect venues and hold valuable local intelligence, which the IoL submitted should be used as a foundation for joint inspections, shared intelligence and coordinated enforcement.

Thirdly, Martyn’s Law permits “suitably qualified” individuals to carry out certain functions; however, the draft guidance suggests that decisions will sit only with SIA staff. The IoL queried whether licensing officers would be empowered to make similar compliance decisions to improve efficiency and reduce burdens on businesses. It also sought clarity on how the SIA will decide when processes “differ materially” from what is reasonably expected, as well as further clarity on appeals, notice suspensions and enforcement timelines.

When will the guidance be finalised and when will Martyn’s Law come into force?

Martyn’s Law is expected to come into force in spring 2027 and, during this lead-in time, operators are encouraged to prepare for its implementation. The SIA intends to regulate in a supportive, proportionate and risk-based way, and will publish final statutory guidance and a full consultation report in autumn 2026.

Statutory guidance has a more significant legal effect than standard guidance. Operators may be held accountable if the guidance is not followed, so understanding and complying with the requirements will be essential.

What can operators do in the meantime?

We recommend that operators take stock of their current processes, review and, where appropriate, update current risk assessments and policies, or design new ones.

Furthermore, operators are also encouraged to assign an individual or team to manage Martyn’s Law compliance, record-keeping and responses to any inspections or notices.

If you need guidance on Martyn’s Law, ensuring readiness for the introduction of the statutory guidance, alcohol licensing compliance, navigating enforcement action with authorities, or managing other licensing-related disputes, we’re here to help. Please get in touch with Leigh at leighschelvis@schofieldsweeney.co.uk.