Martyn’s Law for Art Galleries: What You Need to Do
TL;DR
Galleries with 200 to 799 people in the building at once, counting visitors, artists, and everyone working including volunteers and freelance invigilators, are standard tier under Martyn’s Law. Above 800 it’s enhanced tier instead. The number that decides your tier is almost never a normal opening day. It’s the private view, when a space that holds forty browsers holds three hundred people with a drink in one hand, in the evening, with fewer people working than on a Tuesday afternoon. The other hard part is invacuation, because a white-cube gallery with a glazed frontage often has no interior room to move people into. Below: counting the opening rather than the average, finding a safer space back of house, and a worked example for a 290-person private view.
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Most galleries already handle what any public building needs: a fire evacuation, someone invigilating, a plan for the evening the whole mailing list turns up at once. Martyn’s Law adds what those don’t cover: invacuation (keeping people inside when the street is the danger), lockdown (securing a frontage that may be mostly glass and a door that’s open all evening), and telling a room full of people holding drinks what to do without the fire alarm doing it for you.
Most gallery managers make the same mistake: reading the threshold against a normal Wednesday. The Act asks what you can reasonably expect from time to time, and an opening every six or eight weeks counts, so the private view is your number even if the rest of the month never gets close. Sheltering people is the other thing that catches galleries out. One open volume with a glass wall onto the street is a hard place to keep anyone safe. Back of house usually is. The rest of this guide takes those in turn, starting with the count.
Does Martyn's Law Apply to Art Galleries?
Yes. Art Galleries fall under Libraries, museums, galleries (Schedule 1, paragraph 5) of the Terrorism (Protection of Premises) Act 2025, which applies once 200 or more people, including staff, volunteers, and contractors, are regularly expected on site at the same time. If your gallery 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 Gallery Capacity
Count the private view, not the average day. Openings recur, they’re advertised, and they draw a crowd into a space that spends the rest of the week nearly empty. The same goes for a launch, a late, a fair preview, an artist’s talk, or the last weekend of a show that got a good review. A gallery whose ordinary footfall is thirty people can be a standard tier premises on the strength of an evening that happens eight times a year.
There are no tickets to count, so use one of the other accepted methods. Fire safety occupancy is the quickest starting point and the easiest to stand behind. Beyond that: the guest list and the door clicker from your last three openings, a count of the invitations you send and the rate at which people actually turn up, or a figure built from your floor area. Historic records from previous openings are the most convincing evidence you can have, so if nobody has ever counted, count the next one.
Include everyone working, which at an opening is more people than usual. Invigilators, gallery staff, the artist and their guests, technicians still finishing something, hired bar staff, a photographer, and anyone from a PR or events company. Freelancers and contractors count towards the threshold in exactly the same way as employees.
If you occupy part of a bigger building, work out whose premises are whose before counting. A gallery on the ground floor of an office block, in a shared arts building, or inside a warehouse converted into studios has a responsible person defined by who controls the premises for their use as a gallery. Where control is shared, each party is a responsible person in their own right and the Act expects them to coordinate. Where a landlord isn’t the responsible person but still has control of something, they have to cooperate with whoever is.
Being free to enter and open to the street doesn’t take you out of scope, and neither does being a commercial gallery rather than a public one. Charging, ticketing and membership make no difference to whether premises qualify. What matters is the use and the numbers.
Not sure where you fall? Use our free capacity calculator to work it out.
Key Challenges for Art Galleries
Most Art Galleries 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:
The opening is a different venue from the gallery
Everything about a private view changes the risk picture at once. There are five to ten times as many people in, they’re standing in a crowd rather than moving through a space, most of them have a drink, the light is low, it’s dark outside, and the front door is usually propped open. And you’re often running with fewer people who know the building than on a normal weekday, because the extra bodies are hired bar staff who arrived an hour ago. Write your procedures for that evening first. A plan that works at an opening works comfortably on a Tuesday, and it doesn’t work the other way round.
Nowhere to shelter in a room with a glass wall
Invacuation means bringing people into the building or into a safer part of it, and a white-cube gallery is close to the worst-designed space in the country for it. One open volume, a full-height glazed frontage onto the street, no interior rooms, and nothing to get behind. So the answer is almost always back of house: the office, the store, the packing room, the corridor by the loading door, a basement. Go and stand in each one now and ask whether forty people would fit, whether the door closes, and whether anyone would think to go there. Then tell your team, because nobody works this out under pressure.
Invigilators who started last week
In a lot of galleries the entire floor team is one or two invigilators, often freelance, often paid by the hour, frequently artists or students, and rotating fast enough that the person on shift today may never have met you. They’re also the only person in the room. The training answer has to fit that reality: one page, a five-minute walk of the exits and the safer room at the start of a first shift, and a card at the desk. The Act expects procedures to be communicated to whoever would carry them out, employed or not, so put a line in the freelance agreement and keep a note of who was briefed and when.
The instinct to stay with the work
Invigilation training says never leave the room unattended, and insurance and loan conditions can say something similar in writing. But in an emergency that instinct is dangerous, because it keeps the one person who knows the building standing next to a painting while everyone else works out what to do on their own. Say it explicitly in the briefing and put it on the card: the work is insured, people aren’t. If a condition of a loan requires something to be secured, check now whether it can be done in seconds on the way past. If it can’t, it doesn’t belong in the evacuation.
The floor plan changes with every show
Galleries build and demolish walls between exhibitions. A route that was clear in March can be blocked by a temporary partition in May, and an exit that was signed can end up behind a plinth. Occasionally a work itself sits in a doorway. So a gallery procedure can’t be written once and filed. Fold a walk of the exits and the safer room into the end of every install, alongside the snagging you already do. It takes five minutes and it’s the single most useful habit in this guide for a space that keeps changing shape.
The door is open and anyone can walk in
Free entry, no ticket, no barrier, and a door onto the pavement is what a gallery is for, and it also means you have no idea who is in the room. That isn’t something to fix by putting a lock on it. It’s a reason to be clear about lockdown: what actually secures your front door, who has the key or the button, and how long it takes. Many galleries find the honest answer is a shutter that takes two people and a couple of minutes, which is worth knowing in advance rather than discovering on the night. Check it works from the inside, and check it can be released from the inside too.
Worked Example: Gallery Procedures
A contemporary gallery on two floors of a converted warehouse in a city centre. Ground floor: full-height glazed frontage onto the street, one main space, a desk by the door. First floor: a smaller project space reached by a single staircase. Basement: office, packing room, and store, with a goods door onto a service lane. Two employed staff, a rota of six freelance invigilators, free entry, openings every seven weeks. A Thursday-evening private view for a well-reviewed show.
| Procedure | Implementation |
|---|---|
| Capacity | 290 at the private view (215 in the main space and on the street side of the door, 44 in the first-floor project space, 12 artists and guests of the artist, 2 gallery staff, 4 invigilators on for the evening, 8 hired bar staff and a technician, plus 4 people from the artist’s gallery in another city) |
| Evacuation | Main space out through the front door onto the street, and out through the goods door into the service lane, which doubles the exit capacity and matters when 200 people are standing between the front door and the work. First floor down the single staircase and out through the goods door, never towards the front, because the stair lands in the busiest part of the ground floor. Muster fifty metres up the service lane away from the glass. The gallery director calls it, the desk stops anyone else coming in, and a named invigilator sweeps the first floor, the toilets and the basement before reporting back. |
| Invacuation | The basement packing room is the designated safer space: no external glazing, a solid door, and enough room for the first-floor crowd and the desk team. The store next to it is the overflow. The ground-floor main space is the worst place in the building because of the glazed frontage, so people there move down to the basement rather than staying put, and the first floor comes down the stairs to join them. If the stairs can’t be used, the first-floor project space has no external windows and holds its own. |
| Lockdown | The front shutter is the one that counts, it needs two people, and it takes about ninety seconds, which is why both gallery staff know how to do it and one invigilator has been shown as well. The technician secures the goods door from inside. Lights in the front space down, everyone moved back from the glazed frontage, and the first-floor door closed. All of it releasable from inside if a fire starts. |
| Communication | At an opening the room is loud and there’s no PA, so the process is people and it starts with the music. Killing the sound is step one, because a room that suddenly goes quiet looks up. The director then gives one short instruction from the middle of the space, and the invigilators repeat it at the front door, at the foot of the stairs, and in the first-floor project space. Bar staff stop serving and move to the exits rather than trying to relay anything, since they don’t know the building. The desk calls 999 and meets the emergency services on the street. |
| Training | Freelance invigilators get five minutes on their first shift, walking to the goods door and the packing room rather than being shown a plan, and a copy of the one-page summary attached to their agreement. Both employed staff know the shutter. Before every opening, a two-minute reminder to whoever is working that evening, including the hired bar staff, covering the two exits and where people go if the answer isn’t outside. The exits and the safer room get walked again at the end of each install, because the walls move. |
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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Brief the opening, every time. Whatever your standing procedures say, the evening with three hundred people in is the one that needs a two-minute huddle before doors: which exits, who calls it, where people go if outside is wrong, and who kills the music. Include the hired bar staff, because they’ll be nearest the door and they have never been in the building before.
Freelance invigilators need the same information as employed staff, delivered in a way that survives a fast rota. Five minutes of walking the route on a first shift, a card at the desk, and a one-page summary attached to the agreement will do it. The Act expects procedures to be communicated to everyone who would carry them out, and it doesn’t care who employs them.
Keep a note of who has been briefed and when. In a gallery with a rotating freelance team, that list is the only way anyone can tell whether the person on the desk this afternoon has ever been told anything, and it’s the kind of evidence you’d want to be able to show.
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 a private view, not an average day, and use your last few openings as the evidence
- Include everyone working on the night: invigilators, technicians, hired bar staff, PR, and the artist’s guests
- Find a safer space back of house with no external glazing, and check it holds the number you’d send there
- Work out how the front is actually secured, how long it takes, and who has been shown
- Use the goods or service door as a second exit, and make sure it isn’t blocked by crates during an install
- Give freelance invigilators five minutes on their first shift and a one-page summary with their agreement
- Say the rule out loud: the work is insured, people aren’t, and nobody stays with a piece
- Walk the exits and the safer room again at the end of every install, because the walls move
- Agree who kills the music and who gives the instruction at an opening
- Keep a list of who has been briefed and when, including freelancers and anyone hired for the night
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 gallery.
- 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 galleries yet?
We get forty people on a normal day and three hundred at an opening. Are we in scope?
We’re a commercial gallery with free entry and no tickets. Does the law still apply?
Our invigilators are freelance. Do we have to brief them?
The whole front of our gallery is glass. Where are we supposed to shelter people?
Does the Act say anything about protecting the artwork?
We rent one floor of a shared arts building. Whose duty is it?
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Standard Tier (2026). Martyn’s Law for Art Galleries: What You Need to Do. Available at: https://www.standardtier.co.uk/guide/martyns-law-for-galleries
Last reviewed: 23 August 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.