Martyn’s Law for Museums: What You Need to Do
TL;DR
Museums with 200 to 799 people in the building at once, counting visitors, school groups, and everyone working including volunteer stewards, are standard tier under Martyn’s Law. Above 800 it’s enhanced tier instead. Two things make museums harder than most venues: free entry means you have no ticket data to count from, and the people who’d actually carry the procedures out are volunteers who might do one shift a month. Below: how to count without tickets, briefing a volunteer rota, and a worked example for a 242-person day.
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Most museums already run a fire evacuation, and many have invigilation and collection security routines that shape how people move through the building. Martyn’s Law adds the bits those don’t cover: invacuation (keeping people inside and away from the street), lockdown (securing the doors, including a café or shop entrance if you have one), and a way of telling every floor the same thing at once when the fire alarm is the wrong signal. It asks for nothing physical, and since that comes up in every conversation about listed buildings, here it is early: no cameras, no barriers, no alterations.
The counting is where museums struggle. Most don’t charge, don’t count, and genuinely don’t know how many people were in the building at four o’clock on the busiest Wednesday of half term, so you have to work it out another way, and there are approved ways of doing it. Then there’s who does the work. In a lot of independent museums the whole of front of house is volunteers, and the plan has to be one a steward on an occasional shift can carry out on a floor full of strangers. If your gallery spaces are more art than object, the galleries guide covers the same category from that angle. The rest of this guide starts with the number, because everything else hangs off it.
In this article
Does Martyn's Law Apply to Museums?
Yes. Museums 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 museum 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 Museum Capacity
Free entry means no ticket data, which rules out the easiest counting method and leaves you five others. Your fire safety occupancy figure is usually the fastest and the easiest to defend, because someone has already worked it out and written it down. After that: a manual count on a genuinely busy day, a door counter if you have one, visitor figures you already report to a funder, or an estimate built from your own floor areas. None of this needs a consultant, and the Government has said plainly that complying shouldn’t need consultants or third-party products.
Count everyone working, not just the people on the payroll. Volunteer stewards, the café staff, the shop volunteer, the learning officer, the curator who is in that day, cleaners, and any contractor installing or de-installing an exhibition. A small museum with eight paid staff can easily have fifteen volunteers in on a Saturday. And that’s twenty-three people before a single visitor walks in.
Your peak is not a wet Tuesday in November. It’s half term, a free family day, a late opening, the first fortnight of a touring exhibition, or the weekend of a local festival. The test is the greatest number you could reasonably expect from time to time, which means something that happens with some regularity counts even if it’s six days a year. A one-off that will never happen again is a different question, and if that one-off tops 800 with tickets or registration, it may be a qualifying event in its own right.
If your site spreads across more than one building, or has grounds, work out what’s in and what isn’t. Open-access parks, gardens and recreation grounds are excluded where there’s no ticket, membership or payment to get in, so a walled garden anyone can wander into generally sits outside. The buildings are what qualify. If the whole site is ticketed, or the grounds are only reachable through a paid entrance, the picture changes and you should count the lot.
Museums inside something bigger need a conversation before anyone counts anything. A museum in a council building, on a university campus, or inside a larger heritage trust site has a responsible person defined by control, not by who owns the freehold. Whoever controls the premises for their use as a museum carries the duty. Where control is genuinely shared, each party is responsible in their own right and the Act expects them to coordinate rather than assume someone else has it covered. A café or shop inside the museum is a different question. Where one premises has two Schedule 1 uses, regulations in force from 15 October 2026 point you to the principal use, and for a museum that’s the museum. A franchise running the café doesn’t pick up a duty of its own unless the café is genuinely separate premises with its own qualifying capacity.
Not sure where you fall? Use our free capacity calculator to work it out.
Key Challenges for Museums
Most Museums 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:
Front of house is volunteers, and they’re not in every week
This is the one that shapes everything else. A volunteer steward who does one Saturday a month sees your procedures twelve times a year at best, and a training day they have to travel in for on a Tuesday is not going to happen. So the briefing has to be short, spoken, and repeated. One page, delivered in ten minutes at the start of a shift, with a card at every steward station saying which exit, which safer room, and what to say. The Act expects procedures to be communicated to whoever would carry them out, and it counts volunteers explicitly. Keep a list of who has been briefed and when, because that list is the evidence.
Telling people something in a building with no tannoy
Plenty of museums have no public address system at all, and in a listed building you may not be able to fit one even if you wanted to. That’s fine, because the Act asks for a process rather than equipment. What it means in practice is people: a steward in each gallery who walks the room and says the same short line out loud. Two complications worth planning for. Visitors on audio guides can’t hear you, so brief stewards to step in front of someone rather than call across the room. And if you get international visitors, a printed line at each desk in the languages you actually see is a five-minute job that could save you two minutes on the day.
The instinct to save the objects
Everyone who works in a museum has been trained to protect the collection, and in an emergency that training fires before anything else. Someone will want to close the cases, someone will remember the loan conditions on the temporary show, and someone will go back for a document. So say the rule out loud in the briefing, and put it on the card: people first, objects second, nobody goes back. If a loan agreement or an insurance condition asks for something to be secured, check now whether it can be done in seconds on the way out or not at all, and write it down accordingly. What you cannot have is a case-locking routine sitting in the middle of your evacuation.
Rooms that nobody can see into
Museums are full of spaces that are out of sight and out of earshot. Period rooms off a main gallery, the AV room with the film running and the door closed, the stores, the archive, the lift, the accessible toilet, the learning room when a session is on. A general shout clears the main galleries and leaves people in all of them. Name who sweeps what, keep the list short enough that it works with the staffing you actually have on a Tuesday, and have each sweeper report back to one person at the muster point rather than drifting off home.
School groups and organised visits
A class of thirty and two teachers behaves differently from thirty individual visitors, and mostly that helps: they arrive as a group, they have adults who know their names, and they can be moved as a unit. The bits that catch people out are coats and bags in a store room (which nobody goes back for), lunch in a room that isn’t a gallery, and who does the headcount. Teachers stay in charge of their pupils. You direct the movement. Agree that split when the visit is booked rather than on the day, and it’s worth putting a line about it in your booking confirmation.
A historic building you’re not allowed to change
Narrow stairs, one main entrance that everyone came in through and will head back to, a fire route through a room that used to be a scullery, and listed fabric you can’t touch. It feels like an impossible starting point. But it isn’t, because standard tier doesn’t ask you to install or alter anything. Nothing to buy, nothing to bolt on, no consent to apply for. What you do instead is route around the building you’ve got: pick the exits people don’t normally use and sign them, put a person at the pinch point, and pick a safer interior space away from street-facing glass for invacuation. Some museums find their best safer space is a basement store or a windowless learning room.
Worked Example: Museum Procedures
An independent local history museum in a Grade II listed former town house with a modern rear extension. Ground floor: entrance and welcome desk, shop, café, two galleries. First floor: three galleries and a learning room in the extension. Second floor: archive, stores and offices. A small walled garden open to the street. Nine paid staff, a rota of about forty volunteers, free entry. A term-time Wednesday with two school visits booked.
| Procedure | Implementation |
|---|---|
| Capacity | 242 at the Wednesday peak (118 visitors across the galleries, 34 in the café and shop, 60 pupils in two school groups with 6 teachers and helpers, 9 paid staff, 12 volunteer stewards, and 3 contractors installing the next temporary exhibition) |
| Evacuation | Upper floors down both staircases, the period main stair and the extension stair, never the lift. Ground floor out through the rear fire exit into the car park and the café’s secondary door onto the side street, which keeps everyone off the narrow front pavement. Muster at the far end of the car park. School groups leave as a group with a steward leading and their teachers doing the headcount at the muster point. Named sweeps for the second-floor stores, the AV room, the toilets and the walled garden, each reporting to the duty manager by name. |
| Invacuation | The learning room is the designated safer space: interior, solid door, no external windows. The ground-floor store behind the shop is the second. The café has full-height glazing onto the street and is the worst room in the building to shelter in, so anyone there moves back into the store. First-floor galleries have sash windows onto the road, so visitors there move into the learning room rather than staying put. |
| Lockdown | Front door bolted from the inside, and every duty person knows where the bolt is because it’s stiff and it’s been shown to them. The extension supervisor secures the rear fire exit and the car park door from inside. Shop shutter down, café side door closed, garden gate locked. Gallery doors closed, groups kept in place with their stewards. All of it releasable from inside if a fire starts. |
| Communication | There’s no PA in the listed part of the building, so the process is people. The duty manager decides and calls it over the radios the stewards carry. Each steward then walks their gallery and says the same agreed line out loud, stepping in front of anyone wearing an audio guide rather than calling to them. A printed version of the line in the three languages the museum sees most sits at the welcome desk and the first-floor station. The welcome desk calls 999, stops anyone else coming in through the front door, and meets the emergency services on the street. |
| Training | Volunteers get ten minutes on their first shift, walking the actual route rather than reading it, then a refresher each spring before the busy season starts. Paid staff at induction and once a year. Cards at the welcome desk, the first-floor station and in the learning room. Exhibition contractors are told on the first morning of an install, along with where the fire exits are. The date of every briefing goes in one spreadsheet. |
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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Your volunteers are the plan. Whatever you write down, the thing that decides how a real incident goes is whether the person on the desk on a Saturday knows which door to send people to and what to say. Ten minutes walking the route with them is worth more than a policy document they’ll skim once. Keep it to one page and make the page match the building they’re standing in.
Build the refresher into something that already happens. Most museums have a seasonal opening, a volunteer social, or a start-of-year briefing. Attaching five minutes to one of those is far more realistic than calling everyone in for training, and it means the newest volunteers hear it before the busiest months rather than after.
The Act expects procedures to be communicated to everyone who would carry them out, whether they’re employed, volunteering, or working for someone else on your site. Keep a simple record of names and dates. It costs nothing, and it’s the difference between telling an inspector you’ve briefed your volunteers 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 without ticket data, starting from your fire safety occupancy figure, and write down which method you used
- Count everyone working: volunteer stewards, café and shop staff, learning staff, cleaners, and exhibition contractors
- Check your half-term, free family day and late opening numbers rather than an average day
- Decide how you tell people anything in a building with no PA, and who walks which gallery
- Brief stewards to step in front of visitors wearing audio guides instead of calling across the room
- Say the collection rule out loud: people first, objects second, nobody goes back
- Name who sweeps the stores, the AV room, period rooms, the toilets and any outdoor space
- Pick a safer interior space away from street-facing glass, and check it holds the number of people you’d send there
- Agree with schools at the booking stage who does the headcount and where groups go
- Get every volunteer briefed in ten minutes on shift, put a card at each station, and keep a note of who and 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 museum.
- 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 museums yet?
We’re free to enter and we don’t count visitors. How do we work out our capacity?
Most of our front of house is volunteers. Do they count towards the 200?
We’re in a listed building. Do we have to install anything?
Our grounds are open to the public. Are they in scope?
We hold one big event a year with more than 800 people. Does that make us enhanced tier?
Are we a museum or a visitor attraction under the Act?
Official Sources
From the Sector
What's changed recently
- New regulations set who's responsible when a building has more than one use (8 September 2026)
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Standard Tier (2026). Martyn’s Law for Museums: What You Need to Do. Available at: https://www.standardtier.co.uk/guide/martyns-law-for-museums
Last reviewed: 14 September 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.