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

TL;DR

Shops with 200 to 799 people on site (customers and staff combined) fall under Martyn’s Law standard tier. Above 800 you’re into enhanced tier instead. Supermarkets, department stores, and large high-street shops are all in scope. If you have a stock room or warehouse, it’s likely your best shelter space. If you’re inside a shopping centre, both you and the centre operator are responsible. Below: capacity calculation, key challenges, and a worked example for a medium supermarket.

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If your shop regularly has between 200 and 799 people on site at the same time (customers and staff 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. This applies to supermarkets, department stores, large high-street shops, garden centres, DIY stores, and any other retail premises that hits the threshold.

Most shops already have fire evacuation plans and trained fire marshals. Martyn’s Law adds three things your fire plan doesn’t cover: invacuation (moving customers to safer parts of the building), lockdown (securing all entry points), and a communication plan for security incidents that doesn’t rely on the fire alarm. If you have a stock room or warehouse area, you’ve probably never thought of it as a safety asset, but it may turn out to be your best shelter space.

Does Martyn's Law Apply to Shops?

Shops fall under Shops etc. (Schedule 1, paragraph 1) of the Terrorism (Protection of Premises) Act 2025. If your shop 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 Shop Capacity

Count everyone on site at peak times: customers on the shop floor, staff on tills, shelf stackers, warehouse workers, cleaners, security, and anyone in the stock room or offices. Saturday afternoons and the run-up to Christmas are what matter, not a quiet Tuesday morning.

If you have footfall counters (many shops installed them during COVID), use that data. Otherwise, use your fire safety occupancy figure. For standard retail, the floor space factor is 2.0 square metres per person. For bulky goods (DIY, furniture, garden centres), it’s 7.0 square metres per person. Divide your sales floor area by the right factor, then add maximum staff on shift.

A shop with 400 square metres of sales floor could hold 200 customers under the standard factor. Add 25 staff on a busy Saturday and you’re at 225. If you have a cafe or restaurant within the store, that area uses a denser factor and pushes numbers up further.

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

Key Challenges for Shops

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

Glass frontage

Most shops have large windows or full glass frontages. Glass is a fragmentation hazard if there’s an explosion outside. During invacuation, move customers away from the front of the store and towards interior spaces. Stock rooms, warehouse areas, and staff rooms behind solid walls are your best options. If you have roller shutters, closing them adds a layer of protection.

Customers moving freely

Unlike a theatre where everyone is seated, your customers are spread across aisles, fitting rooms, toilets, and multiple floors. During an incident, staff need to sweep the entire store. Someone trying on clothes in a fitting room or using the customer toilets won’t hear a PA announcement. Assign specific staff to check these areas.

Trolleys and aisle obstacles

In supermarkets, abandoned trolleys block aisles during an evacuation. Customers may instinctively try to take their trolley with them. Your procedures should address this: tell customers to leave trolleys where they are and move to the nearest exit. Staff should focus on directing people, not clearing trolleys.

Part of a shopping centre

If your shop is inside a shopping centre, both you and the centre operator are responsible persons under the Act. You must coordinate your procedures. The centre covers common areas (concourses, car parks, food courts) and you cover your unit. Agree how you’ll communicate during an incident, and make sure your procedures don’t conflict with the centre’s.

Peak trading and temporary staff

Christmas, Black Friday, and school holidays bring your highest footfall and your least experienced staff. Agency workers and seasonal temps may never have been in the store before. They still need to know the exits, the shelter areas, and what the code word means. Build a two-minute security briefing into every temp’s first shift.

Worked Example: Shop Procedures

A medium supermarket with a sales floor of 600 square metres, stock room and warehouse at the rear, staff room upstairs, loading bay, and customer car park. Capacity 400 including 30 staff at peak.

ProcedureImplementation
Capacity400 (370 customers + 30 staff)
EvacuationMain entrance (automatic doors with manual override) to car park; fire exits at the ends of aisles to side paths; staff door through stock room to loading bay. Customers directed to leave trolleys and move to nearest exit. Duty manager coordinates from the shop floor. Staff sweep fitting rooms, toilets, and stock room.
InvacuationStock room and warehouse (no windows, fire doors, solid walls). Staff room upstairs. Customers moved away from glass frontage to the rear of the store as a minimum. If time allows, into the stock room. Staff close roller shutters on the shop front if fitted.
LockdownMain entrance automatic doors switched to manual and locked (duty manager); loading bay roller shutter closed (warehouse team); fire exits secure from inside (push bars prevent entry); staff entrance locked (stock room supervisor). Lights dimmed on shop floor near windows.
CommunicationStore PA system for customer announcements. Staff radios with a code word for security incidents. Self-checkout attendant and till operators are the primary customer-facing communicators in their areas. Duty manager calls 999. Tills and self-checkout screens can display short messages if the system supports it.
TrainingNew starters briefed during induction: exits, stock room shelter area, lockdown points, code word. Printed procedure summary in staff room and behind the customer service desk. Monthly reminder during team briefing. Agency and seasonal staff get a two-minute walkthrough on their first shift. 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 Shops

Retail staff turnover is high. Don’t rely on a single annual training session. Build security awareness into the induction process so every new starter hears it on day one. A five-minute walkthrough of exits, shelter areas, and lockdown points during their first shift is enough to start.

If you have self-checkout areas, they’re a blind spot. One attendant monitoring twelve machines is focused on the screens, not the store entrance. Make sure self-checkout staff know what to do and who takes over if they need to help direct customers during an incident.

If your shop is part of a larger building (shopping centre, retail park), coordinate with the landlord or centre management. They’ll have their own procedures, and your staff need to know how the two sets of procedures work together.

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 (customers + all staff at your busiest trading period)
  • Map all exit routes (front entrance, stock room fire exit, any rear or side doors)
  • List every entry point and how each locks: front door or shutter, delivery entrance, staff entrance
  • Identify your safest interior area for invacuation (stock room, office, or any interior room that locks)
  • Set up a staff communication method (earpieces, code words, or a simple PA)
  • Brief all staff, including part-time and seasonal workers, on procedures
  • Plan for incidents during peak trading (Saturday afternoons, sale days, the Christmas rush)
  • If your shop is part of a shopping centre, coordinate with centre management on their procedures

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 shop.
  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 shop right now?
Not yet. The Act was passed in April 2025 but won’t be enforced until at least Spring 2027. Getting procedures in place now means you’re ready and your staff are trained before the deadline.
We’re a DIY store with a huge floor but not many customers at once. Are we in scope?
Possibly not. Bulky goods retailers use a floor space factor of 7.0 square metres per person, so you need a much larger floor area to reach 200 customers. But add staff, any cafe area (which uses a denser factor), and peak-period footfall. If the total regularly hits 200, you’re in scope.
Do we need bag searches or security guards?
No. Standard tier is procedures only. No bag searches, no security equipment, no guards required. If you already have loss prevention or security staff, they’re an asset for implementing your procedures, but the Act doesn’t require them.
We’re inside a shopping centre. Who is responsible?
Both you and the centre operator. The Act says where premises form part of other premises, both responsible persons must coordinate. In practice, the centre covers common areas and you cover your unit. Work with your centre management to align procedures.
How do we handle Christmas and Black Friday when we have agency staff?
Every temporary worker needs a minimum briefing: where are the exits, where is the shelter area, what does the code word mean. Two minutes on their first shift. A printed procedure card in the staff room backs this up. The briefing doesn’t need to be long, but it does need to happen.

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

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.