Martyn's Law for Leisure Centres: What You Need to Do
TL;DR
Leisure centres with 200 to 799 people in the building at once (visitors across every zone plus staff and volunteers) fall under the standard tier of Martyn’s Law and need procedures for evacuation, invacuation, lockdown, and communication. The hard parts are specific to you: swimmers who are wet and barefoot, changing rooms someone has to sweep, children whose parents are in a different zone, and halls run by hirers. Your lifeguards’ emergency training is a head start. Below: a worked example for a trust-run centre with a 375-person peak.
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If your leisure centre regularly has between 200 and 799 people in the building at once (swimmers, gym members, class attendees, spectators, and everyone working, from lifeguards to café staff), 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. Leisure centres sit under Schedule 1’s entertainment and leisure use, alongside cinemas and bowling alleys. Standard tier means public protection procedures for four things: evacuation, invacuation, lockdown, and communication.
Leisure centres are awkward for one reason above all: nobody is in the same place. A pub crowd is one room. Your building on a Saturday morning is a dozen separate groups: lanes of swimmers, a gym floor, two exercise classes, junior football in the sports hall, parents in the café, toddlers in the crèche. Some of those people are in the water. Some are undressed. Some are four years old and nowhere near their parents. There’s good news too. If you run a lifeguarded pool, part of your team already trains for emergencies as a condition of the job, and that’s a better starting point than most venues get.
Does Martyn's Law Apply to Leisure Centres?
Leisure Centres fall under Entertainment and leisure (Schedule 1, paragraph 3) of the Terrorism (Protection of Premises) Act 2025. If your leisure centre 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 Leisure centre Capacity
Count the busiest occasion, not the average Tuesday afternoon. For many centres that’s Saturday morning: every swim lesson full, the gym busy, both studios running, junior sport in the hall, plus the parents watching all of it. Add staff and volunteers to the visitor number, because the threshold counts everyone present at once, and a peak that happens every weekend counts as happening ‘from time to time’.
Membership numbers are irrelevant. A centre with 4,000 members might never have more than 300 people through the door at the same time, and it’s the 300 that matters. If your entry system logs admissions, that data is one of the approved ways to evidence your figure. Your fire safety occupancy number is another, and often the quickest place to start.
Watch event days. A swimming gala or a regional competition can put more people on your spectator balcony than the rest of the building holds on a normal day. If events like that happen with any regularity and push the whole building past 799, you’re looking at enhanced tier rather than standard, so count those days before you count anything else.
Not sure where you fall? Use our free capacity calculator to work it out.
Key Challenges for Leisure Centres
Every leisure centre is different, but these are the issues that come up most often:
Evacuating people who are in the water
An evacuation that works for the gym fails at the pool. Swimmers are wet, barefoot, and dressed for heated water, and you might be sending them into a February car park. If your pool is lifeguarded, your emergency action plan almost certainly covers clearing the water quickly. Martyn’s Law adds the question of where those swimmers go next. Pick routes that work in bare feet, keep foil blankets or a stock of towels near the poolside exits if you can, and make one rule absolute: nobody goes back through the changing rooms for their clothes.
Clearing the changing rooms
Someone has to sweep them, and it’s the one space where an announcement can disappear under showers and hairdryers. Decide who checks each changing area, in pairs where staffing allows, and agree the exact words they’ll use. There’s a safeguarding edge here too: children may be changing unaccompanied after lessons, so whoever sweeps should be someone your safeguarding policy already clears for that space.
The crèche, the swim lesson, and the parent in the gym
Plenty of your visitors are children whose parents are elsewhere in the building: in the gym during a swim lesson, in the café during football practice. In an incident those groups move separately, so the answer is registers and a reunification point, not parents pushing against the flow to reach their kids. Crèche workers and swim teachers take their registers and keep their groups together, the assembly point has a marked spot where classes wait, and parents hear how this works at booking, not mid-incident.
Hired halls and clubs who aren’t your people
Tuesday night badminton, a martial arts club, five-a-side leagues: your sports hall may spend half its week under someone else’s control. Those coaches and organisers are the ones who’d actually move their group, and they don’t work for you. Put a one-page procedure summary in the hire agreement, brief regular hirers once when they start, and make sure reception can say which groups are in the building on any given evening.
Two people on shift at 6am
Your Saturday plan might have thirty people to call on. Your early shift might be a duty officer and one lifeguard. Write the procedures for the smallest crew that ever runs the building, then scale up. A plan that needs six radios fails at dawn. Quiet hours are also the honest test of lockdown: with two people in the building, who secures the front doors, and can they do it from reception?
Worked Example: Leisure centre Procedures
A trust-run leisure centre on two floors: 25-metre pool and learner pool with a wet changing village, 60-station gym, two studios, a four-court sports hall, a café, and a crèche. Saturday-morning peak: full swim lessons, junior football in the hall, both studios running. 26 staff and volunteers on shift, including four lifeguards.
| Procedure | Implementation |
|---|---|
| Capacity | About 375 at the Saturday peak (roughly 350 visitors across the pool, gym, studios, hall, café, and crèche, plus 26 staff and volunteers) |
| Evacuation | Main entrance to the front car park; poolside fire exit to the side path, with foil blankets stored in the poolside first aid room; sports hall fire doors direct to the rear field; first-floor gym and studios down the main stairs. Lifeguards clear both pools under their emergency action plan, then take swimmers straight out through the poolside exit, never back through the changing village. The duty officer picks the direction of travel and reception turns arriving visitors away at the door. |
| Invacuation | The dry-side changing rooms and the first-floor studios are the designated safer spaces: interior rooms, solid doors, no street-facing glass. The pool hall, with its full-height windows, gets cleared inwards rather than used as shelter. Crèche children move as one group with their register. Café customers come behind the servery into the kitchen corridor. |
| Lockdown | Reception switches the automatic entrance doors to manual and locks them (the override is behind the desk and every duty officer knows it); the hall attendant secures the sports hall fire doors from inside; the senior lifeguard secures the poolside exit; café shutter down. Front-of-house lights off, everyone moved away from the glazed entrance atrium. All of it reversible from inside if a fire starts. |
| Communication | The duty officer and lifeguards are already on radios, and a code word over the radio starts the response without alarming visitors. The tannoy carries a short scripted announcement to the gym, studios, and café, repeated twice, while the sweep team covers the changing rooms where the tannoy is hard to hear. Reception calls 999; the duty officer meets police at the front and briefs them. |
| Training | Lifeguards fold the Martyn’s Law scenarios into the in-service training they already do. Dry-side, café, and crèche workers get a walkthrough at induction and a refresher each quarter. Regular hirers get the one-page summary with their hire agreement and a five-minute briefing in their first week. Procedure cards live at reception, in the poolside office, and in the crèche. |
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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If your pool is lifeguarded, you already employ the most emergency-drilled people in the building. Lifeguard qualifications are built around emergency action, and most pools run regular in-service training, so add the Martyn’s Law scenarios to sessions that already happen rather than inventing new ones. What pool training doesn’t cover is the counter-terrorism difference: sometimes the right move is away from the nearest exit, or staying inside altogether.
The rest of the team is more varied: duty officers, casual swim teachers, café staff, cleaners, volunteers helping run junior sessions. The Act expects procedures to be communicated to everyone who would carry them out, employed or not. A short induction briefing, procedure cards where people actually stand (reception, the poolside office, the crèche), and a recap at team meetings cover most of it.
Clubs and coaches who hire your spaces count too. They’re the ones standing in front of thirty kids when something happens, so the hire agreement should carry your procedure summary, and regular hirers deserve a proper briefing on their first visit. Keep a note of who’s been briefed and when. That record is exactly the evidence an SIA inspector would ask to see.
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 busiest-occasion numbers across every zone: pool, gym, studios, hall, café, crèche, and spectators, plus staff and volunteers
- Check gala and competition days: if regular events would push the building past 799 people, you may be enhanced tier, not standard
- Plan the end of a pool evacuation: barefoot-friendly routes, warmth at the assembly point, and a firm no-return rule for the changing rooms
- Name who sweeps each changing room, and check it squares with your safeguarding policy
- Set up child reunification: registers travel with groups, a marked waiting spot at assembly, parents told the drill at booking
- Map a safer interior space for each zone, and don’t assume a glass-walled pool hall can shelter anyone
- Work out lockdown for your doors, including switching automatic entrance doors to manual, and name who secures each one
- Put a procedure summary in every hire agreement, brief regular clubs and coaches 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 leisure centre.
- 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 leisure centres yet?
The council owns our building but a trust runs it. Who’s the responsible person?
We have thousands of members. Does that make us enhanced tier?
Our pool already has an emergency action plan. Doesn’t that cover us?
Do we need bag checks, CCTV, or security staff?
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Standard Tier (2026). Martyn's Law for Leisure Centres: What You Need to Do. Available at: https://www.standardtier.co.uk/guide/martyns-law-for-leisure-centres
Last reviewed: 3 July 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.