Martyn’s Law for Gyms and Fitness Studios: What to Do
TL;DR
Gyms with 200 to 799 people in the building at once, counting members, class attendees, and everyone working, including self-employed trainers, are standard tier under Martyn’s Law. Above 800 it’s enhanced tier instead. Membership numbers are not capacity, in either direction, and a gym is one of the hardest buildings in the country to make an announcement in, because everyone has headphones in and the studios run their own music. Below: how to count, the hours nobody is on shift, and a worked example for a 245-person peak.
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Most gyms already have a fire risk assessment, some kind of opening and closing check, and a way of inducting the trainers who work the floor, whether or not they’re on the payroll. Martyn’s Law adds what those don’t usually cover: sheltering people inside when the danger is outside (invacuation), securing the entrance (lockdown), and a way of telling a floor full of people something when most of them can’t hear you. None of it needs new kit or building work. But it does need writing down, and if you run unstaffed hours it needs to work at 6am with nobody on reception as well as at 6pm with a full floor.
The arithmetic trips people up first. Gym operators think in members, and Martyn’s Law thinks in bodies through the door at one moment, which are wildly different numbers. A site with 3,000 members might never have 200 of them in at once. A site with 900 might peak at 260 on a Monday in January. Only the second number matters, so that’s where this guide starts. If your site also has a pool or a sports hall, the leisure centres guide covers those.
Does Martyn's Law Apply to Gyms?
Yes. Gyms 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, are regularly expected on site at the same time. If your gym 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 Gym Capacity
Membership numbers are not capacity, and the mistake runs in both directions. A big roll with a quiet building can leave you well under the threshold. But plenty of gyms assume they’re nowhere near 200 because the gym floor holds 120, and then find that the floor, two full studios, the changing rooms, reception, and everyone working add up to well over it. Count the building, not the room you picture first.
At your busiest realistic moment, count members on every floor, everyone in a class, anyone in the changing rooms, sauna, or steam room, people in reception or the café, and everyone working: employed staff and volunteers, duty managers, cleaners, self-employed personal trainers, freelance class instructors, and any contractor on site. Trainers and instructors are easy to forget precisely because they aren’t on the payroll.
If you have turnstiles or fob entry, you already hold better attendance data than most venue types get, and historic entry records are one of the approved ways to evidence your figure. Two cautions. Fob logs count entries rather than people in the building, so you need a sense of how long a visit lasts before that becomes an occupancy number. And they miss everyone who doesn’t badge in, which is usually staff, trainers, and contractors. Your fire safety occupancy figure is the other quick starting point, and often the easiest one to defend.
Your peak isn’t a normal week. January, and to a lesser extent September, is when gyms fill up, and a site that runs at 150 in October can sit above 250 every weekday evening for six weeks after New Year. The threshold asks what you can reasonably expect from time to time, which means a busy period that comes round every year counts. So does a launch week, a class timetable change, or the week a competitor down the road closes.
If your gym sits inside something bigger, a hotel, an office block, a university, or a shopping centre, work out whose premises are whose before you count anything. The responsible person is whoever controls the premises for their everyday use, not whoever owns the freehold. Where control is genuinely shared, each party is a responsible person in their own right and the Act expects them to coordinate rather than assume the other one has it in hand.
Not sure where you fall? Use our free capacity calculator to work it out.
Key Challenges for Gyms
Most Gyms 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:
Everybody is wearing headphones
This is the one that makes gyms different. A pub can shout. A theatre can stop the show. On a gym floor, most of your members have earbuds in and music up, and a tannoy announcement will reach almost nobody. The most reliable signal you have is cutting the music, because the room noticing the silence is the fastest way to get faces looking up. Brief your team that killing the sound is step one, then have someone walk the floor with a clear instruction rather than relying on a speaker. Studios need their own person: the instructor has a microphone, the room’s attention, and no chance of hearing anything from outside.
The hours when nobody is on shift
Plenty of gyms run unstaffed early mornings, late evenings, or around the clock, with fob entry and no member of staff in the building. The duty doesn’t switch off with the lights, but the test is what’s appropriate and reasonably practicable, and that’s a different bar for an empty reception than for a Monday evening with twelve people on shift. Practical answers exist: clear signage at the entrance and by every fire exit saying what to do and where to go, an emergency call point that reaches whoever monitors the site, and checking that fire exits open without a fob. Write down what happens in those hours rather than leaving a gap, because a procedure that only works between nine and five isn’t a procedure for a 24-hour gym.
Getting people off the machines
Evacuating a gym floor isn’t like clearing a room of seated people. Someone on a treadmill at speed needs a few seconds to stop safely, and someone mid-set under a loaded bar needs to rack it before they move. That gap is short but real, and a procedure that assumes instant movement will look wrong the first time you walk it through. The related problem is the floor itself: dumbbells left in walkways, mats and kit parked in corridors, and a bench pulled across a fire route. A clear walkway belongs in the evacuation plan, so fold the check into the round your team already walks.
Changing rooms, lockers and the sauna
Your changing rooms hold people who are undressed, mid-shower, and out of earshot behind running water and hairdryers. Someone has to physically sweep them, and it should be someone your safeguarding arrangements already clear for that space. The sauna and steam room are worse, because they’re sealed, hot, and often out of sight of everything else, so name who checks them. Then there’s the locker problem: the instinct to grab your phone, keys, and wallet before leaving is strong, and it’s the single thing most likely to slow an evacuation down. Make the rule absolute and say it out loud: nobody goes back to their locker.
Trainers and instructors who don’t work for you
The person standing in front of twenty people in your spin studio may well be self-employed, renting the room or paying you a cut. Same for the personal trainers on your floor. They’re the ones who would actually move a group in an incident, and they’re not on your payroll or in your induction. The Act expects procedures to be communicated to whoever would carry them out, employed or not. Put a one-page summary in the trainer licence or hire agreement, brief them properly when they start, and keep a note of who was briefed and when. That record is the kind of evidence an SIA inspector would ask to see.
One way in, and it’s a turnstile
Fob gates and turnstiles are excellent for lockdown and awkward for everything else. They give you a front door you can genuinely secure, often from reception, which is more than most venues have. But they’re a pinch point if people head for the entrance out of habit instead of the nearest fire exit, so your evacuation routes need to be the ones members don’t normally use, and they need signing that way. Many gyms also sit behind a full-height glass shopfront in a retail park or high street unit, which matters for invacuation: the front of the building is the worst place to shelter, and your safer space is almost always an interior room without external glazing.
Worked Example: Gym Procedures
An independent gym over two floors of a converted retail unit. Ground floor: fob turnstile entry, reception and a small café, changing rooms with lockers and a sauna, and a spin studio. First floor: cardio and resistance machines, a free weights area, and a second studio. Staffed from 6am to 10pm, fob access for members from 5am to midnight. Monday evening peak in January.
| Procedure | Implementation |
|---|---|
| Capacity | 245 at the Monday evening peak (165 members across the two gym floors, 24 in spin, 28 in the upstairs studio class, 12 in reception, the café, and the changing rooms, plus 9 staff and 7 self-employed trainers and instructors) |
| Evacuation | First floor down both staircases, not the lift, to the rear fire exit onto the service yard and the front exit onto the street. Ground floor out through the fire door beside the spin studio, which bypasses the turnstiles entirely. Muster in the far corner of the car park, away from the glass frontage. The duty manager picks the direction, reception stops anyone else badging in, and the studio instructors walk their classes out as a group. Named sweeps for the changing rooms and the sauna, reported back to the duty manager at the muster point. |
| Invacuation | The two studios are the designated safer spaces: interior rooms on both floors, solid doors, no external windows. The ground-floor café and reception sit behind full-height glass and are the worst place in the building to be, so people there move back into the spin studio rather than staying put. Members on the first-floor gym floor go into the upstairs studio. Anyone in the changing rooms stays put with the doors closed, since there’s no glazing and no reason to move them through the building. |
| Lockdown | Reception drops the entrance shutter and stops the turnstiles releasing (the control is behind the desk and every duty manager knows where it is). The floor supervisor secures the rear fire exit and the service yard door from inside. Studio doors closed, lights down, instructors keeping their groups in place. Music off across the building, which is also the signal. All of it releasable from inside if a fire starts. |
| Communication | Music off first, throughout the building, because it’s the one thing every member notices. Duty manager and floor staff carry radios, and a code word over the radio starts the response without alarming anyone. Floor staff then walk their zone giving the same short instruction out loud, since headphones make the tannoy useless on its own. The studio instructors get told by radio and repeat agreed wording over their own microphones. Reception calls 999 and meets the emergency services at the front. |
| Training | Employed staff and volunteers at induction, then a fifteen-minute walkthrough at the start of January and again in September, the two points in the year when the building is busiest and the newest people are on shift. Self-employed trainers and instructors get the one-page summary with their licence agreement and a proper briefing in their first week. Procedure cards at reception, in the first-floor supervisor’s station, and inside both studios. The unstaffed hours at either end of the day are written down and signed off separately, because nobody is there to carry them out. |
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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The people who make this work are whoever is on the floor at the time, and in most gyms that’s a small, young, high-turnover team plus whichever trainers happen to be in. Keep the briefing short and specific to the building: which exit, which safer room, what you say, and who kills the music. A five-minute walkthrough on someone’s first shift is worth more than an hour of theory they’ll have forgotten by March.
Class instructors deserve their own briefing, because they’re the only person a room of thirty people is looking at. They need to know how they’ll be told, what to say, and that their studio is likely to be the safer space other people are being sent into. If they’re self-employed, that conversation belongs in the agreement rather than in the corridor.
The Act expects procedures to be communicated to everyone who would carry them out, whether they’re employed, volunteering, or self-employed. Keep a simple record of who has been briefed and when. It takes a spreadsheet, it costs nothing, and it’s the difference between telling an SIA inspector that you’ve trained your team and being able to show it.
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
- Work out your peak headcount across the whole building, not just the gym floor, and include self-employed trainers, instructors, cleaners, and contractors
- Check your January and September numbers, because a busy period that comes round every year is a peak you can reasonably expect
- Decide how you reach a floor full of headphones: who cuts the music, who walks the floor, and what they say
- Give each studio its own named person and a way of being told, since instructors can’t hear anything from outside the room
- Write down what happens during unstaffed hours, including signage, how someone raises an alarm, and whether the fire exits open without a fob
- Name who sweeps the changing rooms and the sauna, and check that squares with your safeguarding arrangements
- Make the no-going-back-for-your-locker rule explicit, and say it in the announcement
- Pick a safer interior space away from the shopfront glass, and check it holds the numbers from the zone you’d send there
- Route evacuation away from the turnstiles, and sign the fire exits members never normally use
- Put a procedure summary in every trainer licence and studio hire agreement, brief them once, and keep a note of when
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 gym.
- 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 gyms yet?
We have thousands of members. Does that make us enhanced tier?
We’re members-only. Doesn’t that put us outside the law?
Our gym is unstaffed overnight. What are we supposed to do?
Our personal trainers are self-employed. Do we have to brief them?
Our gym is inside a hotel. Whose duty is it?
Do we need CCTV, bag searches, or security staff on the door?
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Standard Tier (2026). Martyn’s Law for Gyms and Fitness Studios: What to Do. Available at: https://www.standardtier.co.uk/guide/martyns-law-for-gyms
Last reviewed: 22 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.