Martyn’s Law for Cinemas: What You Need to Do
TL;DR
Cinemas with 200 to 799 people on site at the same time across all screens (audience plus staff and volunteers) fall under Martyn’s Law standard tier. Above 800, you’re into enhanced tier instead. The standard band mostly catches independent 1 to 4 screen sites. Most multiplexes run hot enough at Friday peaks to cross into enhanced. If you have a modern TMS, it gives you a single point to halt every screen and bring house lights up at once, which most venue types would kill for. The hard parts are staggered showings, the dark auditorium during trailers when latecomers are still arriving, and the self-service kiosks that have thinned out front-of-house presence. Below: capacity counting, key challenges, and a worked example for a 3-screen independent.
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If your cinema regularly has between 200 and 799 people on site at the same time across all screens (audience plus staff, volunteers, and anyone in the foyer), it falls under the standard tier of Martyn’s Law. Above 800 you’re into enhanced tier, which carries a heavier set of duties beyond the scope of this guide. Standard tier means no equipment to buy and no physical changes. You need documented procedures for evacuation, invacuation, lockdown, and communication, and a team who actually know what they say.
Cinemas have an unusual capacity question. You aren’t counting one auditorium, you’re counting the busiest concurrent total across every screen running at the same time, plus the foyer queue, plus your staff and volunteers. That number is what decides whether you’re standard tier (200 to 799) or enhanced tier (800 and above). Most independent cinemas with one to four screens sit in the standard band. Most six-screen-plus multiplexes will pass 800 at Friday and Saturday peaks, putting them in scope for the enhanced duties instead. Worth doing the maths properly before you assume which side of the line you’re on.
Does Martyn's Law Apply to Cinemas?
Cinemas fall under Entertainment and leisure (Schedule 1, paragraph 3) of the Terrorism (Protection of Premises) Act 2025. If your cinema regularly has between 200 and 799 people present at the same time, 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 Cinema Capacity
Add up the seats across all screens running concurrently, plus everyone on shift, plus anyone in the foyer at peak. A 3-screen independent with 150, 120, and 80 seats has 350 audience capacity. Add 12 staff and a foyer with 30 people queueing for the next showing and you’re at 392, comfortably standard tier.
A 6-screen multiplex averaging 150 seats per screen has 900 audience capacity at full concurrent occupancy. Even at 70% of that on a Friday night, it’s 630 audience plus around 25 staff and a busy lobby, which sits close to the 800 enhanced threshold. Run the numbers against your busiest realistic Friday slot, not a quiet Tuesday.
The official test is the greatest number reasonably expected at the same time, where ‘reasonably expected’ means with some regularity. A one-off premiere doesn’t count. A pattern of weekend sellouts does.
Not sure where you fall? Use our free capacity calculator to work it out.
Key Challenges for Cinemas
Every cinema is different, but these are the issues that come up most often:
Multi-screen lockdown and the TMS
Modern digital cinemas run on a TMS (theatre management system) that can halt every screen, freeze projection, and bring up house lights from a single workstation, usually in the booth or back office. Christie, GDC, Sony, and Unique X all sell systems that do this. If you have one, your duty manager and projectionist need to know the emergency cue and be able to trigger it without thinking about it. If you’re running an older setup that can’t centrally halt projection, that’s worth flagging to your team and planning around manually instead.
Staggered showings
Different screens are at different points in their film when an incident hits. One auditorium is in opening trailers with people still trickling in, another is at the climax with the audience locked in, a third is rolling credits and people are already heading for the door. The TMS gives you the all-screens halt, but the human response per auditorium will be different. Brief your floor staff to expect different reactions in different rooms and to give the same calm direction in each one.
Dark auditorium and late arrivals
Cinemas dim earlier than theatres and stay dim through 15 to 20 minutes of trailers. Latecomers arrive into a dark room and find their seats by the tread lighting, often with nobody at the door checking who’s coming in. There’s no curtain-up moment when the doors close. Decide who watches the auditorium entrance once the lights go down, and how you’d reach the audience in the dark if you need to. The TMS bringing the lights back up is your first move.
Self-service kiosks have thinned out the floor
Most chains and a growing number of independents now run self-service ticket scanners and kiosks. Less queueing, but also fewer staff at the entry, fewer eyes scanning the foyer, and fewer people who’d notice someone behaving oddly near a screen door. If you’ve moved to kiosks, make sure the team you do have are walking the floor rather than parked behind a till. SCaN for All Staff (free, 30 minutes) covers what to look for.
Concessions, bag policies, and premium seating
Cinemas are far more relaxed about bags than theatres. People bring in coats, rucksacks, and shopping. That isn’t a problem in itself, but it does mean an unattended bag on a foyer chair is harder to call as ‘unusual’. The HOT protocol (Hidden, Obviously suspicious, Typical for the environment) is the right filter, and a bag at a foyer table is typical. A bag wedged behind a fire exit or left in an empty screen is not. Premium recliners deserve a separate thought: they take longer to right and they obstruct the row, so factor that into your evacuation timing.
Worked Example: Cinema Procedures
An independent 3-screen cinema in a converted high-street building. Screens of 150, 120, and 80 seats. Foyer with concessions and a small bar, two self-service kiosks, a back-office TMS workstation, two upstairs offices, and a loading door for film deliveries. 14 staff at peak.
| Procedure | Implementation |
|---|---|
| Capacity | 404 (350 audience across all three screens at concurrent capacity + 14 staff + 40 in the foyer at changeover) |
| Evacuation | Foyer doors to the high street (2 sets); Screen 1 fire exit to the side alley; Screen 2 fire exit to the rear yard; Screen 3 shares the rear corridor and exits via the loading door if needed. TMS halts projection on every screen and brings up house lights. PA announcement to all auditoria and the foyer at the same time. Floor staff direct audiences away from the threat, not automatically to the nearest door. Assembly point: the public square opposite the high-street entrance. |
| Invacuation | Auditoria themselves are reasonable shelter (interior walls, no external windows on the screen wall, fixed seats give cover). Move foyer customers into the largest auditorium. Back office and projection rooms for staff if needed. Loading door bolted from inside. |
| Lockdown | Foyer doors locked by the duty manager (keys held at the box office desk); kiosks left as-is (no entry from them); fire exits secured from inside (push bars already prevent entry); loading door bolted by the projectionist; back-office and upstairs office doors locked from inside. House lights brought up via the TMS, then dimmed once the audience is settled. |
| Communication | Duty manager initiates the response. PA system reaches all three screens and the foyer (verify the link if you’ve never tested it, plenty of cinemas haven’t). TMS plays a pre-loaded slide on each screen if you have it set up: a single calm message asking the audience to stay seated and follow staff direction. Floor staff on radios. Duty manager calls 999. Code word agreed in advance so a staff member at a kiosk can trigger the response without alarming the queue. |
| Training | All staff briefed at induction: TMS emergency cue, exits in each screen, the foyer plan, the code word. Duty managers walked through the TMS halt and house lights up at least once a quarter so it stays automatic. Floor staff briefed on SCaN basics and the HOT protocol. Printed procedure cards at the box office, in the projection room, and in the back office. All staff and volunteers encouraged to complete ACT Awareness e-learning (free, 45 minutes). |
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.
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Your duty manager and projectionist are the ones who actually trigger the response. If you have a TMS, they need to know the emergency cue cold and be able to bring lights up across every screen without hesitating. If you don’t, they need a fast manual fallback that does the same thing. Walk it through every quarter so it stays muscle memory.
Floor staff are your eyes once the lights go down. With self-service kiosks taking the till work, the team you do have should be walking the foyer and the auditorium entrances rather than parked behind a counter. SCaN for All Staff (30 minutes, free) covers what to look for.
Don’t forget the part-time and casual team who only work weekend matinees or late shows. They’re the ones likely to be on the floor at the busiest moments. Brief them properly at induction, and keep a printed summary at every workstation so anyone can find it under pressure.
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
- Add up the maximum concurrent capacity across every screen plus staff and the foyer queue
- Confirm whether your TMS can halt all screens and bring up house lights from a single point, and who knows how to use it
- Map the exit routes for every screen, including the loading door and any rear corridors
- Decide who watches the auditorium entrances once the lights go down
- Plan how you’d reach an audience in the dark (TMS slide, PA, ushers with torches)
- Brief floor staff on SCaN basics and the HOT protocol so kiosk-led operations don’t lose situational awareness
- Walk duty managers through the TMS emergency cue at least quarterly
- Plan separately for IMAX, 4DX, and recliner screens where evacuation timing or audio mix is different
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.
- Write procedures for evacuation, invacuation, lockdown, and communication tailored to your cinema.
- Make sure your staff and volunteers know the procedures. Brief them, put up posters, hand out one-page summaries.
- Keep records of what you have done and who has been briefed.
- 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.
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Frequently Asked Questions
Does Martyn’s Law apply to my cinema right now?
We’re a 6-screen multiplex. Are we standard tier or enhanced tier?
Should we use the fire alarm for a security incident?
Our TMS is older and can’t centrally halt projection. What do we do?
Do we need to check bags at the door?
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Standard Tier (2026). Martyn’s Law for Cinemas: What You Need to Do. Available at: https://www.standardtier.co.uk/guide/martyns-law-for-cinemas
Last reviewed: 8 June 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.