Martyn’s Law for Hotels: What You Need to Do

TL;DR

Hotels with 200 to 799 people on site (guests in rooms, staff, restaurant diners, event attendees) fall under Martyn’s Law standard tier. Above 800 you’re into enhanced tier instead. The hardest challenge is sleeping guests at 3am: you can’t use the fire alarm for a security incident because it sends people towards exits that might be near the threat. Guests in rooms are already sheltered, though. Below: capacity counting, key challenges, and a worked example for a 100-room independent hotel.

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If your hotel regularly has between 200 and 799 people present at the same time (guests, staff, event attendees, restaurant and bar patrons combined), it falls under the standard tier of Martyn’s Law. Above 800 you’re into enhanced tier instead, which carries a heavier set of duties beyond the scope of this guide. Standard tier needs public protection procedures for evacuation, invacuation, lockdown, and communication.

Hotels have a challenge that most other venues don’t: people sleeping. At 3am, your building might have 180 guests asleep in their rooms and a night porter or two on duty. Waking and directing people who don’t know the building, may not speak English, and weren’t expecting to be disturbed is fundamentally different from managing a crowd in a pub or a theatre. Hotels do have one universal advantage: guests in their rooms are already sheltered. Beyond that, what you have to work with depends on the building. If you run an electronic key card system, you can restrict floor and back-of-house access. If your fire alarm has voice messaging built in, the wiring gives you a communication backbone most venues would envy. Bell-only fire alarms can’t be repurposed this way, so you’ll need a separate alert method.

Does Martyn's Law Apply to Hotels?

Hotels fall under Hotels etc. (Schedule 1, paragraph 8) of the Terrorism (Protection of Premises) Act 2025. If your hotel 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 Hotel Capacity

Count everyone who could be on site at the same time: guests in rooms (rooms multiplied by average occupancy), restaurant diners, bar patrons, event or conference attendees, spa users, and all staff on shift. The number that matters is your busiest realistic scenario, not your quietest midweek night.

A 100-room hotel at 1.8 guests per room averages 180 guests. Add 25 staff on the day shift, 60 diners in the restaurant, and 100 wedding guests in the function room, and you could hit 350 to 400. Even if you only hold a few large events per year, those peaks bring you into scope.

Be careful with function rooms and conference spaces. A wedding or conference can temporarily push your total well above your normal occupancy. If events regularly add enough people to cross from standard tier into enhanced tier territory (800 or more), you may need to plan for that.

Not sure where you fall? Use our free capacity calculator to work it out.

Key Challenges for Hotels

Every hotel is different, but these are the issues that come up most often:

Sleeping guests at 3am

This is the hardest communication problem in any venue type. Fire alarms wake everyone, but the official guidance says you should avoid using fire alarms for security incidents because guests will automatically evacuate, possibly towards the threat. You need a way to tell sleeping guests to stay in their rooms and lock their doors. Options include PA announcements (if your system reaches bedrooms), in-room phone calls, text messages via your booking system, or staff knocking on doors. None of these is perfect, but having a plan is what matters.

Guests who don’t know the building

Your guests checked in a few hours ago. They know where their room is, where the restaurant is, and probably nothing else. They haven’t read the fire safety notice behind the door. During an incident, they’ll need clear, simple directions from staff. Consider adding a line about emergency procedures to your check-in process, even if it’s just pointing out the fire escape map.

24/7 operation with skeleton night staff

If you have a night porter working alone overnight, that’s your most vulnerable staffing scenario. That one person needs to know all four procedures and be able to initiate them without help. They need direct access to a phone for 999, a radio or PA system, and the ability to lock the main entrance. Lone worker procedures should integrate with your counter-terrorism plan. If your hotel has no overnight cover at all (some smaller B&Bs and budget hotels), make sure check-in guests are briefed on what to do and who to call if something happens between lockup and breakfast.

Function rooms and conferences

Event attendees are often completely unfamiliar with the building. A wedding with 120 guests or a conference with 200 delegates can more than double your normal occupancy. Your event coordinator needs to know your procedures and brief the event organiser. For large events, consider a short verbal safety announcement at the start.

International guests and language barriers

Hotels regularly host guests who don’t speak English. Written instructions behind the room door should include pictograms or multilingual summaries for the most common languages among your guests. During an incident, clear hand gestures and calm, simple words are more effective than detailed verbal instructions.

Worked Example: Hotel Procedures

A 100-room independent hotel with a restaurant (60 covers), bar, function room (capacity 120), small spa, and car park. Three floors of guest rooms. Maximum capacity 400 including 25 staff on day shift.

ProcedureImplementation
Capacity400 (180 guests in rooms + 60 restaurant diners + 30 bar patrons + 100 function room attendees + 5 spa users + 25 staff)
EvacuationMain entrance to car park; restaurant fire exit to garden; function room fire exit to side road; fire escape stairwells at each end of guest corridors to ground floor and out. Duty manager coordinates. Reception staff direct people in the lobby. Floor staff (housekeeping or designated fire marshals) check corridors. Guests in rooms follow fire escape route on bedroom door. Assembly point: far end of car park.
InvacuationGuest rooms on upper floors (solid walls, lockable doors; guests already sheltered). Ground-floor public areas are more exposed. Restaurant and bar guests moved to interior corridors or upstairs. Function room guests directed to interior areas away from external walls and windows. Spa users moved to ground-floor corridor behind reception.
LockdownMain entrance doors locked by receptionist (electronic lock override); restaurant external doors locked (restaurant manager); function room fire exit secured from inside; car park entrance barrier lowered; loading bay door locked (kitchen porter); spa external door locked. Lifts recalled and held. Key card system used to restrict ground-floor access if available.
CommunicationReception initiates response. PA system reaches all public areas and corridors (check if it reaches bedrooms). In-room phones used to call occupied rooms with pre-scripted message. Staff radios connect reception, restaurant, housekeeping, and management. Duty manager calls 999. For function room events, event coordinator acts as the link between venue staff and event attendees.
TrainingAll staff briefed during induction: exits, shelter areas, lockdown points, PA system, code word. Night porters receive additional training on lone-worker procedures and all four response types. Shift handover includes a security status update. Printed procedure summary at reception, in the staff room, and in the kitchen. Housekeeping briefed on what to report (suspicious items in rooms, unusual guest behaviour). All staff 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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Staff Training for Hotels

If you have night porters, they need the most thorough training of any role. They’re alone, they’re responsible for the entire building, and they’re the only person between a threat and a building full of sleeping guests. Walk them through every scenario. Make sure they know how to lock the front door, use whatever communication method you’ve chosen, and call 999 without hesitation.

Housekeeping staff enter every room every day. They’re the people most likely to notice something unusual: an unattended bag in a corridor, a room being used in an unexpected way, or a guest asking detailed questions about the building layout. Brief them on what to report and make it easy for them to do so.

Shift handover is your best recurring training opportunity. A 30-second counter-terrorism update during each handover keeps awareness consistent across all shifts without requiring separate training sessions.

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 maximum capacity (guests in rooms + restaurant/bar/function room + all staff at peak occupancy)
  • Map all exit routes on every floor, including stairwells, service corridors, and function room exits
  • List every entry point and how each locks: main entrance, car park access, service entrance, fire exits on each floor
  • Plan how you’ll alert guests in their rooms (PA system, internal phone, door-to-door)
  • Plan for 24-hour operation, including reduced night staffing (who does what at 3am with two people on duty?)
  • Set up communication between departments (radios, internal phones, duty manager system)
  • Brief all staff across all departments: reception, housekeeping, kitchen, maintenance, night team
  • Plan how you’d account for guests during an evacuation (room occupancy data, guest lists)

Getting Started

Compliance is not complicated. Here is what to do:

  1. Work out your capacity (try our free calculator). Under 200? You are not in scope.
  2. Write procedures for evacuation, invacuation, lockdown, and communication tailored to your hotel.
  3. Make sure your staff and volunteers know the procedures. Brief them, put up posters, hand out one-page summaries.
  4. Keep records of what you have done and who has been briefed.
  5. 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 hotel right now?
Not yet. The Act was passed in April 2025 but won’t be enforced until at least Spring 2027. Starting early means your night team and day team both know the procedures before the deadline.
How do I count capacity when guests are sleeping?
Count everyone present at the same time. At night that’s guests in rooms (rooms multiplied by average occupancy) plus night staff. During the day, add restaurant diners, bar patrons, event attendees, spa users, and all day staff. The peak scenario is what counts.
Should I use the fire alarm for a security incident?
No. Fire alarms trigger automatic evacuation, which could send guests towards the threat. You need a separate communication method for security incidents. A PA announcement, in-room phone calls, or staff going door to door are better options for telling guests to stay in their rooms.
Guests in their rooms are already sheltered. Is that invacuation?
Effectively, yes. Upper-floor rooms with solid walls and lockable doors are good protected spaces. The invacuation challenge for hotels is getting people in public areas (lobby, restaurant, bar, car park) to move to interior corridors or upper floors, and telling guests already in rooms to stay put and lock their doors.
What about conference or wedding guests who don’t know the building?
Your event coordinator should brief the event organiser on your procedures before the event. For large events, a short safety announcement at the start (exits, what to do if they hear a PA announcement) takes 30 seconds and covers the basics.

Official Sources

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Standard Tier (2026). Martyn’s Law for Hotels: What You Need to Do. Available at: https://www.standardtier.co.uk/guide/martyns-law-for-hotels

Last reviewed: 21 March 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.