Martyn’s Law for Arts Centres: What You Need to Do
TL;DR
Arts centres with 200 to 799 people in the building at once are standard tier under Martyn’s Law. That figure counts every audience, class, café customer and gallery visitor, plus everyone working, volunteers included. At 800 or more it’s enhanced tier instead. What sets an arts centre apart is that it’s several venues behind one front door. A show, a film, a busy café-bar and a children’s class can all be running at the same moment, each with different people looking after it. Below: counting the overlap, working out which use the law treats as yours, dealing with hirers and volunteers, and a worked example for a 513-person Saturday night.
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Most arts centres already have a fire plan, a premises licence and someone in charge on show nights. Martyn’s Law adds procedures for a terrorist attack in four areas: evacuation, invacuation (bringing people inside, or into a safer part of the building), lockdown, and communication. At standard tier it doesn’t ask for equipment, building work, bag searches or a training course. It asks that appropriate procedures are in place, so far as is reasonably practicable. The Home Office’s statutory guidance adds that the people who’d carry them out need to know them.
The awkward part for an arts centre is that one building has very different days. At eleven on a Tuesday morning you might have a toddler music group, a pottery class, a handful of people in the gallery and a queue at the café, looked after by three people. At half seven on a Saturday there’s a full house, a film, a packed bar and a dozen volunteers on. Same building. Same law. Two quite different plans, and the busiest overlap is what decides your tier, so that’s where this guide starts.
Does Martyn's Law Apply to Arts Centres?
Yes. Arts Centres fall under Entertainment and leisure (Schedule 1, paragraph 3) of the Terrorism (Protection of Premises) Act 2025, which applies once 200 or more people, including staff, volunteers, and contractors, can be expected on site at the same time, even if only occasionally. If your arts centre expects between 200 and 799 people at once, it qualifies as a standard tier premises. At 800 or more, you're into enhanced tier instead, which carries a heavier set of duties.
Standard tier means two duties: notify the SIA that you are a qualifying premises, and put public protection procedures in place covering evacuation, invacuation, lockdown, and communication.
No physical alterations. No equipment to buy. No consultants to hire.
How to Work Out Your Arts centre Capacity
Count the building, not the biggest room. The Act looks at how many people may be present at the same time in connection with one or more of the uses it lists, so the theatre, the screen, the gallery, the café-bar and any class all count together. Find the busiest realistic overlap, which for many arts centres is a weekend evening with a show, a film and the bar all going, and use that. Don’t add up every room’s maximum unless they genuinely fill at the same time.
Different spaces need different counting methods, and the Home Office’s supplementary guidance on counting allows for that. Fixed seats give you an exact figure for an auditorium or a cinema. Walk-in spaces don’t, so for the café-bar, foyer and gallery use door counts or till data from your busiest nights, or the occupancy figure from your fire risk assessment. Count the peak. The guidance is clear that an average across the day or the week isn’t the number.
Add everyone working: paid staff, volunteers on front of house, the bar and the gallery, technicians, tutors running classes, a visiting company in the dressing rooms, and the café team if the café is part of your building. Volunteers and contractors count in exactly the same way as employees.
Studios or workspaces you let to artists or small businesses are worth separating out. If the public don’t visit them, they aren’t used for one of the listed uses, and the statutory guidance says to count only the people attending or working in the parts of the premises that are. An open studios weekend, when the public walk round them, is another matter.
The test is what you can reasonably expect from time to time, which the Home Office reads as occasionally. A panto run or a few sold-out nights a year can be enough, even if most days are far quieter. If your figure lands between 200 and 799, you’re standard tier. If 800 or more is a realistic expectation even once a year, the premises are enhanced tier, which carries much heavier duties than this guide covers.
Not sure where you fall? Use our free capacity calculator to work it out.
Key Challenges for Arts Centres
Most Arts Centres hit the same handful of problems with Martyn's Law, and they come from how the building works rather than from the Act itself. These are the ones that come up most often:
Working out which use is yours
Schedule 1 of the Act lists the uses that bring premises into scope, and an arts centre can touch four of them: entertainment and leisure (theatre, cinema, live music), galleries, food and drink (the café-bar) and halls for hire. Since 15 October 2026, regulations (S.I. 2026/1005) set a two-step test for which one is your principal use. Step one asks which use relates most closely to the purpose and nature of the building. That means what it was built or converted for, whether it’s still used that way, its physical layout, and how the council treats it, through planning or the premises licence for instance. Only if that doesn’t settle it do you go to step two, which also weighs floor area, opening hours, whether a use takes the whole building or part of it, and whether one use mainly supports another. In our reading, a performance-led arts centre is likely to land on entertainment. A gallery-led centre with a small studio theatre, or one that mostly hires rooms out, could land elsewhere. The answer identifies the responsible person and the use you’ll give the regulator when you notify. It doesn’t change the duties, and the Home Office guidance says procedures need to cover all the activities in the building, café and classes included. Write down your reasoning, and look at it again after a refurbishment, a licence change or a change in how you use the place.
A daytime building and a show-night building
The statutory guidance accepts that where numbers differ a lot from one time to another, procedures can vary with them. For most arts centres that means a daytime version and a show-night version. In the day it’s the café, the gallery and a couple of classes, run by whoever is on duty with a small team and no ushers. In the evening it’s a full auditorium with front of house in place. Your scope and tier come from the busiest overlap, so the daytime version still needs to exist on a Tuesday with 150 people in. Write it for whoever is actually there: who calls it, who locks the café door, who goes up to the studios.
Several spaces, several people in charge
During a show, the audience can’t hear the foyer, the cinema can’t hear anything over the film, and a class upstairs has its door shut. If you have a PA, check where it actually reaches. The dependable answer is a named lead for every space in use, whether that’s a duty manager, a head usher, whoever runs the film, the bar lead or the class tutor, and a set way of telling each of them: a radio, a phone call, or someone sent up the stairs. Agree the words they’ll say, and make them different from your fire announcement, because a fire alarm sends everyone to the assembly point and that may be exactly where you don’t want them.
The café-bar that’s open to anyone all day
Many arts centres have a café-bar with its own street door, sometimes a terrace, open from morning to late to anyone walking past. That makes it the busiest way in and the hardest to secure, and it’s often the part of the building with the most glass. So lockdown in an arts centre usually starts at the café door: who locks it, how long it takes, and where the café customers go next. If someone else runs the café under a concession and it has no separate boundary from the rest of the building, it’s likely to be part of your premises, and your procedures should cover it as far as it’s within your control. You can hand the tasks to the café team. You can’t hand over the legal responsibility. Put who does what in the concession agreement, and brief the café team the way you’d brief your own volunteers.
Children’s classes and older people’s groups
Daytime programmes bring in groups that don’t move like an evening audience: under-fives with their parents, a youth theatre, a chair-based dance class for older people. Make the tutor the key person for their room, and remember that in many arts centres the tutor is a freelancer who has never seen your procedures. Think through where a children’s group would shelter and who stays with them, how you’d reunite them with parents waiting in the café, and how long it takes to move people who use walking frames or wheelchairs to a safer room or out of the building. Keep the class register in the room, so the tutor can account for everyone.
Hirers and community groups
When a choir, a dance school or a community group hires a studio, the Home Office statutory guidance says the responsible person stays the same. That’s you. You can ask the hirer to carry out parts of your procedures, and the guidance suggests setting that out in the hire agreement, but overall responsibility stays with you. If the regulator asks, you’d need to show that you made clear what you expected and took reasonable steps to check it happened. In practice that’s a one-page summary with every booking confirmation, a clause in your hire terms, and five minutes with the group’s organiser when they arrive.
Worked Example: Arts centre Procedures
A charity-run arts centre in a market town, in a converted Victorian chapel and its old Sunday school, leased from the county council and run day to day by the charity. A 280-seat theatre in the chapel, a 90-seat cinema, a ground-floor café-bar with its own street door and a small terrace, a first-floor gallery, two studios used for classes and community hire, and four top-floor studios let to local makers. Eight paid staff and about forty volunteers on a rota. A Saturday evening in December: a sold-out touring show, a film, a community choir rehearsing in Studio 1 under a hire agreement, and a busy bar full of people who aren’t going to either.
| Procedure | Implementation |
|---|---|
| Capacity | 513 at the Saturday evening peak (280 theatre audience + 90 cinema audience + 55 in the café-bar and on the terrace + 20 in the gallery + 40 at the choir hire in Studio 1 + 8 cast and crew from the visiting company + 6 paid staff on shift + 12 volunteers on front of house, bar and gallery + 2 technicians). The makers’ studios are let to tenants and closed to the public, so the two tenants working late are left out. A weekday daytime peak is about 160, but it’s the evening figure that puts the centre in the 200 to 799 band. |
| Evacuation | Theatre out through the foyer doors to the square and through the side exit to the lane. Cinema through its own exit to the lane. Café-bar and terrace through the street door. Gallery and both studios down the rear stair to the car park. The duty manager calls it and decides which way is safe, because the foyer and the café door both open onto the same square. Ushers and the bar lead hold each exit and send people away from the threat rather than automatically to the fire assembly point. The gallery volunteer brings the choir down with the gallery visitors. Muster at the far end of the car park, with a street two blocks away as the fallback. |
| Invacuation | The theatre is the main safer space: thick chapel walls, no windows onto the square, and room at the back of the stalls for the café-bar crowd as well as the audience. The cinema holds its own audience where they sit. The café-bar is the worst place in the building, all glass onto the square, so the bar team moves those customers through the foyer into the theatre. The gallery and the choir go into Studio 2, which has no external windows and is empty on a Saturday evening. The visiting company stays in the dressing rooms. |
| Lockdown | The café-bar street door and terrace gate go first, because anyone can walk through them. The bar lead locks the door and drops the café shutter. The duty manager locks the foyer doors from the box office. The technicians secure the stage door and the rear stair door to the car park. The cinema and studio doors are closed, with people kept inside. Every door can still be opened from inside if a fire starts. |
| Communication | The PA covers the foyer and café-bar but can’t be heard in the theatre during the show or in the cinema with the film running, so each space has a named lead on a radio: the duty manager, the head usher, the cinema volunteer, the bar lead and the gallery volunteer. The show technician stops the performance and brings up the house lights. The cinema volunteer stops the film. Everyone uses the same agreed words, which sound nothing like the fire announcement. The duty manager calls 999, then phones the choir’s organiser, who doesn’t carry a radio. |
| Training | Volunteers are briefed at sign-in by the duty manager for the role they’re doing that night, with a card at each position. Paid staff go through the procedures at induction and again once a year. The visiting company gets a page in the get-in pack and a word with their stage manager at the technical handover. Hirers get the same page with their booking confirmation and five minutes on arrival. Class tutors get it at the start of each term. Everyone is pointed to the free ACT Awareness e-learning, but nobody has to do it. |
This is one example. Your procedures should reflect your specific building, layout, and circumstances. Read our full guide to public protection procedures for a detailed breakdown of what to include. To see how procedures like these come together on paper, read our complete example document for a 300-capacity pub.
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Many arts centres run on volunteers who switch roles: usher on Friday, gallery steward on Saturday afternoon, behind the bar on Sunday. Brief them for the job they’re doing today rather than everything at once. A card at each position and two minutes at sign-in does more than an evening session once a year that nobody quite remembers. The Home Office statutory guidance expects anyone given a part in the procedures to know what it is, and it counts volunteers and contractors alongside employees.
The people most likely to be missed are the ones who don’t think of themselves as working for you. Freelance tutors. The café team, if the café is contracted out. A visiting company. A hirer’s organiser. The statutory guidance also expects you to explain to hirers what you need from them. Give each of them the same one page, and tell them who will alert them and how.
Keep a simple log of who was briefed, on what, and when. With forty volunteers on a rota and tutors and hirers coming and going, it’s the only way to know whether tonight’s bar lead has ever heard the plan, and it’s the kind of evidence you’d want to have if the regulator asked.
The free ACT Awareness e-learning (45 minutes) is a good baseline for anyone who wants to go further. It covers recognising threats, suspicious items, and what to do during an attack.
Quick Checklist
- Count the busiest realistic overlap across every space in use, not each room’s maximum
- Use fixed seats for the auditorium and screens, and past door counts, till data or fire occupancy for the café-bar, foyer and gallery
- Include everyone working: paid staff, volunteers, technicians, tutors, visiting companies and the café team
- Leave out studios or workspaces let to tenants that the public don’t visit, and note why
- Work through the principal use test, write down your reasoning, and review it if the building or its use changes
- Write a daytime version and a show-night version of your procedures
- Name a lead for every space in use and decide how each one gets told
- Make the café-bar street door part of lockdown, and agree who locks it
- Plan where a children’s class shelters, who stays with them, and how they’re reunited with parents
- Add a one-page summary and a clause to your hire terms, and keep a log of who has been briefed
Getting Started
Compliance is not complicated. Here is what to do:
- Work out your capacity (try our free calculator). Under 200? You are not in scope.
- Check who the responsible person is. It's usually whoever runs the arts centre, which isn't always the owner, and both duties fall to them.
- Write procedures for evacuation, invacuation, lockdown, and communication tailored to your arts centre.
- Make sure your staff and volunteers know the procedures. Brief them, put up posters, hand out one-page summaries. If volunteers help out, read how Martyn's Law treats volunteers.
- Keep records of what you have done and who has been briefed.
- Notify the SIA once the duty starts. You can't yet: our guide to notifying the SIA explains how it'll work, and the Martyn's Law timeline tracks when the duties are expected to begin.
- Review at least once a year.
You can do this yourself, or use Standard Tier to document your procedures in 10 minutes, set up a training portal your staff and volunteers can access on their phones whenever it suits them, and keep a digital audit trail without chasing signatures or filing paperwork.
30-day free trial · No card required · £18/month (usually £38), unlimited staff and volunteers after that
Frequently Asked Questions
Does Martyn’s Law apply to arts centres yet?
We have a theatre, a cinema, a gallery and a café. Which category are we?
Most days we have fewer than 200 people in. Are we in scope?
The council owns our building and we run it as a charity. Whose duty is it?
Someone else runs our café. Is that their responsibility or ours?
When we hire a studio out, does the hirer become responsible?
We run a ticketed festival weekend that brings in over 1,000 people. What happens then?
Official Sources
From the Sector
What's changed recently
- Martyn's Law: new rules for buildings with more than one use (8 September 2026)
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Standard Tier (2026). Martyn’s Law for Arts Centres: What You Need to Do. Available at: https://www.standardtier.co.uk/guide/martyns-law-for-arts-centres
Last reviewed: 30 October 2026. Based on the Act, the Home Office statutory guidance published on 15 April 2026, and the Home Office factsheets. Requirements may be refined as the SIA finalises its guidance.
This guide is general information about the Terrorism (Protection of Premises) Act 2025, not legal advice. Duties under the Act rest on the responsible person for each venue and cannot be transferred. If you're unsure how a specific requirement applies to your premises, take advice from a solicitor or qualified security adviser before acting on anything you read here.
Standard Tier is an independent platform and is not affiliated with the UK Home Office, the SIA, or any government body.