Martyn's Law for pubs and bars with function rooms

The Terrorism (Protection of Premises) Act 2025 is not in force yet. The SIA expects it to come into force in spring 2027 and will confirm the date. Here is how it applies to a pub: how to count your capacity, which tier you fall into, and what has to be in place.

Counting capacity

The figure that decides the tier is the greatest number of people it is reasonable to expect to be present at the same time, from time to time, including staff. For a pub that means the number you can reasonably expect at the busiest times across the whole premises, including the function room and garden, with staff counted. The licensed capacity is a starting point, not automatically the answer. Figures vary a lot between pubs and bars with function rooms, so work out your own. Below 200 the Act does not apply. 200 to 799 is standard tier. 800 and over is enhanced tier.

Which tier

A pub where 200 or more people can reasonably be expected at once, across all areas and counting staff, is standard tier. A pub that is busy at weekends or before Christmas can be in scope even if weekday numbers are lower. If you lease the pub, you as the tenant are usually the responsible person, even where the brewery or pub company holds the licence.

What a standard tier pub must have

Once the Act is in force, notify the SIA of the premises and the responsible person through the SIA's online portal. Anyone already responsible on the start date has three months. Have public protection procedures in place, so far as reasonably practicable, for four situations: evacuation (getting people out), invacuation (bringing people in and keeping them inside), lockdown (securing the premises) and communication (telling people what to do). Staff who have a role in them need to know what it is. No equipment, no searches and no security staff are required at this tier. The SIA can impose a penalty of up to £10,000, and up to £500 a day if a compliance notice is not met.

What that looks like in a pub

Pubs run with a small team and a manager who may not be on shift. The pack's procedures name roles by job title, such as duty manager, rather than a person, and the staff briefing can be given to a new bar team member on day one.

The capacity assessment is the important document for a pub near the line: if the honest answer is under 200 the pub has nothing further to do, and the pack records that so it can be shown.

A function room hired out needs the hirer briefed. The pack's co-ordination section covers it.