Martyn's Law Penalties: Fines, Enforcement, and What Happens if You Don't Comply

Overview

The Terrorism (Protection of Premises) Act 2025 creates a graduated enforcement framework. For standard tier venues (200–799 capacity), this means advice first, formal notices second, and financial penalties as a last resort.

No one is going to prison for not having public protection procedures. Standard tier non-compliance is handled through fines, not criminal charges. (The one exception: giving false or misleading information to the SIA is a criminal offence under Section 25, for all tiers.) The system is designed to get venues compliant, not to punish them.

Who Enforces Martyn's Law?

The Security Industry Authority (SIA) is the regulator. The SIA already regulates private security and door supervisors. Martyn's Law gives it a new function: overseeing venue compliance with public protection requirements.

The SIA is recruiting over 100 new staff across guidance, notifications, compliance casework, inspections, and enforcement. A new Manchester hub is being established specifically for this work.

Local authorities, police, and fire services have no enforcement role under the Act. The SIA is the sole regulator.

The “Support First” Approach

The SIA has publicly committed to a “support first” enforcement approach. In their own words, they will:

1. Give venues the opportunity to get compliance right
2. Highlight good practice
3. Advise those not doing enough
4. Reserve formal enforcement for serious or persistent non-compliance

This mirrors how health and safety regulation works in the UK. The HSE does not typically fine businesses on a first visit. It advises, issues improvement notices, and escalates only when those are ignored. The SIA is taking the same approach.

The Enforcement Ladder

The SIA has said it expects to work through these steps in order, escalating only where the previous step did not resolve the issue. One caveat: the Act does not require it to. In a serious case, nothing stops the regulator moving straight to a formal notice or penalty.

The SIA wants compliance, not revenue from fines.

What Is a Compliance Notice?

A compliance notice is a formal written direction from the SIA telling you to take specific steps to become compliant. It must state what you need to do and give you a reasonable timeframe to do it.

A compliance notice is not a penalty. It is a formal instruction. If you follow it within the timeframe, that is the end of it.

Before issuing a compliance notice, the SIA must give you the opportunity to make representations. You can explain your circumstances, challenge the SIA's findings, or propose alternative steps.

What Is a Restriction Notice? (Enhanced Tier Only)

A restriction notice is the SIA's power to restrict or prohibit the use of premises where non-compliance creates a serious risk to public safety. It can effectively shut a venue down. But it is not part of the standard tier enforcement ladder: under the Act, restriction notices can only be issued against enhanced duty premises and qualifying events.

If your venue is standard tier (200–799), the SIA cannot restrict or close it under Martyn's Law. The enforcement tools that apply to you are the ones above: advice, compliance notices, and financial penalties.

How Much Are the Fines?

For standard tier venues, the maximum monetary penalty is £10,000. This is a civil penalty, not a criminal fine. It does not result in a criminal record.

Before imposing a monetary penalty, the SIA must issue a notice of intent, give you the opportunity to make representations, and then issue a final notice if it still considers the penalty appropriate.

The SIA will consider the circumstances when setting the amount. Factors likely to be relevant include:

• The seriousness of the failure (no procedures at all vs. incomplete procedures)
• Whether the venue cooperated with the SIA
• Whether the venue took steps to comply after being advised
• The size and resources of the venue
• Any history of non-compliance

A venue that has some procedures but missed one area is in a very different position to a venue that has done nothing at all.

What Are Daily Default Penalties?

If a venue continues to fail to comply after receiving a monetary penalty, the SIA can impose a daily default penalty of up to £500 per day. This continues until the venue becomes compliant.

Daily penalties are the final escalation for standard tier. They exist to deal with venues that refuse to engage with the process entirely. A venue that is genuinely trying to comply and engaging with the SIA is extremely unlikely to reach this stage.

What Do Inspectors Actually Look For?

The final rulebook for inspections is not out yet: the SIA plans to publish its final Section 12 guidance in autumn 2026. But based on the SIA's stated approach and its draft guidance, expect an inspector at a standard tier venue to check six things:

1. Has the SIA been properly notified that this is a qualifying premises?
2. Do procedures exist for all four areas (evacuation, invacuation, lockdown, communication)?
3. Do the procedures make sense for this specific building?
4. Can staff and volunteers explain the procedures?
5. Has the responsible person thought about the likely scenarios for their premises?
6. Is there evidence? Training records, copies of procedures, review dates

What Inspectors Will NOT Look For

• Physical security measures (CCTV, barriers, bollards)
• Formal written risk assessments
• Security consultancy reports
• Specific qualifications or certificates
• Purchased products or services

If a random staff member or volunteer can explain what they would do in an incident, and you can show the inspector your procedures, you are in good shape.

How Do Enhanced Tier Penalties Compare?

Enhanced tier penalties are in a different league. This section is included for context. If your venue has fewer than 800 people, you are standard tier and these do not apply to you.

Can You Appeal?

Yes. All enforcement decisions can be appealed to the First-tier Tribunal. For standard tier, that means compliance notices and monetary penalties. (Restriction notices, which only apply to enhanced duty premises and qualifying events, can be appealed too.)

Before most penalties are imposed, the SIA must also give you the opportunity to make representations. This is your chance to explain your circumstances, provide additional evidence, or challenge the SIA's findings before a formal decision is made.

When Does Enforcement Start?

No venue is required to comply yet. Here is the timeline:

The government committed to a minimum 24-month preparation period from Royal Assent before enforcement begins. Starting early means you avoid the rush when everyone tries to comply at once.

How to Avoid Penalties

Compliance is straightforward. You need public protection procedures covering evacuation, invacuation, lockdown, and communication. Your staff and volunteers need to know those procedures. That is it.

1. Work out your capacity (try our free calculator). Under 200? You are not in scope.
2. Put procedures in place for all four areas. Write them down in your public protection procedures.
3. Make sure your staff and volunteers know the procedures. Brief them, train them, put up posters.
4. Keep records of what you have done and who has been briefed.
5. Review at least annually.

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.

Frequently Asked Questions

Official Sources

• Full text of the Act
• Home Office overarching factsheet
• The SIA's new regulatory role
• Standard duty requirements factsheet
• ProtectUK Martyn's Law hub

Related Guides

• Read our full guide to writing public protection procedures
• Use our compliance checklist to track what you still need to do
• Go back to basics with our plain-English explainer of the Act