Who Is the Responsible Person Under Martyn's Law?

How Does the Act Define the Responsible Person?

Under Section 4 of the Act, the responsible person is ‘the person who has control of the premises in connection with their relevant Schedule 1 use’. That is the legal definition, and every word matters.

‘Control’ means operational control: who decides how the premises are run day-to-day. ‘In connection with their Schedule 1 use’ means in connection with whatever activity makes the premises qualify (serving food, entertainment, retail, worship, education, and so on).

Operational Control, Not Ownership

This is the single most important point. It's based on who runs the place, not who owns the building.

A freeholder who owns a high street building but has leased it to a restaurant operator has no involvement in running the restaurant. They are not the responsible person. The restaurant operator is. The Home Office factsheet is explicit about this: ‘the freehold owner is NOT the responsible person if they have no involvement in running the premises.’

For most independent venues, the answer is straightforward. If you manage the venue, make the operational decisions, and employ the staff, you are almost certainly the responsible person.

Who Is Responsible: Common Scenarios

Can There Be More Than One Responsible Person?

Yes, and it is more common than you might think. Section 8 of the Act covers situations where more than one person has control. Each person is individually a responsible person with their own duties.

Common examples:

• A shopping centre landlord (controls common areas) and individual tenants (control their units)
• A building with a ground-floor restaurant and upper-floor offices run by different operators
• A community hall where the trustees manage the building but hire it out to different groups
• Co-working spaces where the operator controls the shared areas and individual companies control their private offices

Where premises form part of other premises (say, a shop inside a shopping centre), Section 8 requires the responsible persons to coordinate. The shop operator and the centre management must work together on things like evacuation routes that pass through common areas.

Shopping Centres and Shared Buildings

Shopping centres are one of the trickier scenarios. The commercial real estate sector has flagged this as an area needing clarity.

The likely split: the landlord or management company is the responsible person for common areas (food courts, corridors, car parks). Each tenant is the responsible person for their own unit. Both need to coordinate on shared evacuation routes, lockdown procedures, and communication systems.

An individual shop unit inside a centre may fall below the 200 capacity threshold on its own. But the centre as a whole almost certainly qualifies. The landlord's responsibility covers the common areas regardless of whether individual tenants are in scope for their units.

What About Venue Hire?

If you hire out your venue for events, the question is: who retains control? There are three scenarios:

1. You hand over full control. The hirer runs the event, manages the building, and controls access. They become the responsible person for the duration.
2. You retain full control. Your staff manage the building, you control access and operations. You remain the responsible person.
3. Control is shared. Most common. You manage the building and some operations; the hirer runs the event content. Both are responsible persons and must coordinate.

Whichever scenario applies, the key question is always the same: who has operational control of the premises? The hire agreement should make this clear. If it does not, sort it out now rather than arguing about it when an SIA inspector comes calling.

What Must the Responsible Person Do?

For standard tier venues (200 to 799 capacity), the responsible person has two duties:

1. Notify the SIA that the premises are qualifying premises (free, via an online system that the SIA is building)
2. Put public protection procedures in place covering evacuation, invacuation, lockdown, and communication, and make sure staff and volunteers know them

That is it for standard tier. No written plan submitted to the SIA, no designated senior individual, no physical security measures. Just procedures and awareness. The government's impact assessment puts the cost at about £330 a year, mostly in staff time.

If the SIA inspects your venue, it has said it will check that procedures exist, that they make sense for your specific building, and that your staff and volunteers can explain them. See our penalties guide for the full enforcement framework.

The Duty to Cooperate

Section 8 creates a duty to cooperate. Even if you aren't the responsible person yourself, if you have some control of the premises you must cooperate with whoever is.

In practice, this means:

• Sharing relevant information about the building (fire exits, alarm systems, structural features)
• Not obstructing the responsible person from implementing procedures
• Coordinating on shared elements (evacuation routes that cross boundaries, shared communication systems)

This is ‘so far as is reasonably practicable’. No one expects perfection. But a landlord who refuses to share building plans with a tenant trying to write their evacuation procedures would be failing to cooperate.

Get Your Procedures Sorted

If you are the responsible person for a standard tier venue (200 to 799 capacity), compliance is straightforward. Answer our questions about your venue, and we will generate tailored public protection procedures, set up staff training, and give you an audit trail. The whole thing takes about 10 minutes.

Frequently Asked Questions

Official Sources

• Section 4: Responsible person (premises)
• Section 8: Multiple responsible persons and coordination
• Home Office responsible person factsheet
• Home Office overarching factsheet
• ProtectUK Martyn's Law hub

Related Guides

• Find out if your event is a qualifying event under Martyn's Law
• Read the complete guide to Martyn's Law compliance
• See what happens if you don't comply: penalties and enforcement