Martyn's Law for Volunteers and Volunteer-Run Venues
TL;DR
Being run by volunteers or a charity doesn't take a venue out of Martyn's Law. Volunteers count towards your capacity figure, and the ones who'd act in an emergency need to know your procedures. The responsible person is whoever controls the premises, which for a hall or place of worship is usually the committee or trustees as a body. Nothing is in force yet, so there's time to set up a short briefing that reaches everyone on the rota.
Not sure your hall, church or club reaches 200? Start here.
Martyn's Law (the Terrorism (Protection of Premises) Act 2025) was mostly talked about in terms of pubs, theatres and shops. But a lot of the buildings it covers have no payroll at all. Village and community halls. Churches, mosques, gurdwaras and synagogues. Volunteer-run arts centres and music venues. Sports clubs with a clubhouse and a committee.
If that's you, the questions are slightly different. Who counts towards the 200? Who is legally responsible when nobody is in charge full time? And how do you make sure the person on the door this Saturday knows what to do, when they last volunteered in March? This guide answers those, using the Act and the Home Office statutory guidance.
In this article
Does Martyn's Law Apply to Volunteer-Run Venues?
Yes, on the same terms as everyone else. A venue is in scope if it's a building used for one of the purposes listed in Schedule 1 of the Act (halls for hire, places of worship, entertainment venues, sports grounds and so on) and at least 200 people are reasonably expected to be there at the same time, from time to time. Who runs it, and whether anyone gets paid, doesn't come into it.
The exclusions in Schedule 2 cover Parliament and the devolved governments, open-access parks and recreation grounds, and transport premises already covered by their own security law. There's nothing in there for charities, voluntary groups or community organisations.
The band is 200 to 799 for standard tier. Above that, a venue is enhanced tier, which brings heavier duties. Places of worship are the exception that matters most here: they stay standard tier at 200 or more, however big they get, as do childcare settings, schools and further education colleges.
Sports clubs need one extra check. An open ground with no access controls and no stands is excluded, and the statutory guidance gives the example of a volunteer-run junior football club playing on a public pitch: not in scope, even on tournament days with 200 people there. A ground with stands, or with a gate where people pay or show a ticket, needs a closer look. Our sports grounds guide goes through it.
Do Volunteers Count Towards Capacity?
Yes. The capacity figure is the greatest number of people reasonably expected on the premises at the same time, and the Home Office statutory guidance (para. 4.23) says it must include staff. It defines staff as everyone working there, ‘whether as employees, contractors, volunteers or otherwise’.
So on your busiest regular occasion, count the stewards, the kitchen and tea rota, whoever's on the door, the sound person, the band, and any committee members who are working the event as well as the audience. At a hall or church that sits just under 200 on a normal day, that can be the difference.
A genuine one-off doesn't pull you in. The guidance's example is a village hall that never sees more than 150, until a local band with a hit hires it for a 250-person gig. That unexpected event leaves the hall out of scope. If the gigs become a regular thing, it's in. Our capacity calculator walks you through the approved ways of working the number out.
Who Is the Responsible Person When a Committee or Trustees Run the Venue?
The responsible person is whoever has control of the premises for their main use. For a volunteer-run hall or place of worship that's normally the organisation in charge of the building (the management committee, the trustees, the church council) rather than any one volunteer.
That comes from section 4 of the Act. The statutory guidance (paras. 6.1 to 6.3) adds that the responsible person can be ‘the individual, company or organisation’ in control, that it ‘may not be a named individual or single person’, and that it's ‘most likely to be a company or an organisation’. Control ordinarily means having possession of the premises and the right to decide how they're run and who can stay on site. You don't have to own the building.
The guidance names volunteer bodies directly in its examples. A village hall's ‘management committee’ is the responsible person for the hall (para. 6.5). A synagogue's ‘primary governing body’ is the responsible person for the synagogue (para. 5.29). Our responsible person guide covers landlords, leases and shared buildings in more detail.
Incorporated charities and unincorporated committees
If your venue is run by a body with its own legal identity, like a charitable company or a charitable incorporated organisation, and that body controls the premises, it's the obvious candidate for responsible person.
Plenty of halls, clubs and congregations are unincorporated associations instead: a group of people with a constitution but no separate legal identity. The Act's wording allows for these. Under the Interpretation Act 1978, ‘person’ in an Act includes an unincorporated body, and section 29 lets the SIA serve a notice on an unincorporated association by giving it to anyone ‘concerned in the management or control’ of it.
What neither the Act nor the guidance spells out is how a financial penalty would land on an unincorporated committee, or what that means for individual members. We're not going to guess. If your structure is unusual, or the building is owned by one body and run by another, read chapter 6 of the statutory guidance and get advice, from a solicitor or your umbrella body, before you notify the SIA.
Two things are clear for standard tier. You don't need to designate a senior individual, which is only for enhanced tier and qualifying events. And failing to meet the standard tier duties isn't a criminal offence in itself. The SIA has said it plans to advise first, and under the Act its powers run to compliance notices and fines of up to £10,000, plus up to £500 a day if a breach continues. But giving the SIA false or misleading information is a criminal offence, so whoever fills in the notification should be sure of the facts. More in our penalties guide.
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The volunteers who'd carry out your procedures need to know what those procedures are and what their own part is. They don't need a qualification, and there's no set course.
Standard tier has two duties: notify the Security Industry Authority (SIA), and have public protection procedures in place for evacuation, invacuation (moving people to a safer part of the building), lockdown, and communication. Section 5 describes these as procedures followed by ‘individuals working on the premises’, and the guidance counts volunteers as working there.
The statutory guidance (paras. 7.51 to 7.53) says there's no statutory training requirement, but the people who'd carry out the procedures must be made aware of them and of their specific role. If they haven't been told, it'll be hard to show the procedures are really in place. Briefings, inductions, shadowing and annual refreshers all count.
The guidance even uses a volunteer-run example (para. 7.55). A village hall's new volunteers are briefed on the lockdown procedure by a senior volunteer when they start, and the procedure is written up on the wall. The hall then turns down an expensive course that claims to make people compliant, because the volunteers already understand what to do.
So a briefing from someone who knows the building can be enough. Our ACT training guide lists the free government courses if you want to add some general awareness on top.
How Do You Brief a Rota of Volunteers Who Come In Irregularly?
Keep it short, repeat it often, and make sure one named person at every session knows it properly. A volunteer who does two Saturdays a year won't remember a training evening from last spring, but they will remember a two-minute briefing given at the start of the shift.
The law doesn't prescribe any of this. These are the approaches we'd suggest, built on what the guidance accepts:
- A named lead for every session. Whoever unlocks, or whoever's running the event, is the person who'd start an evacuation or a lockdown. Brief them properly and put their name on the rota. The guidance's worked examples include a village hall where a senior volunteer acting as duty manager makes the call.
- A two-minute briefing at the start. Exits, the safer room, which doors lock and who locks them, and how you'll tell everyone. Same four points every time.
- A card or a poster. The guidance suggests a quick reference guide or a credit-card-sized prompt card (para. 7.58). Put one by the main door and one in the kitchen.
- Brief new volunteers before their first shift. Not after three months of helping out.
- Refreshers. Once or twice a year, maybe at the AGM or a volunteers' meeting, and whenever the procedures change.
- Keep a simple record. Who's been briefed and when. If the SIA ever asks how your volunteers know the procedures, a list in the minutes or a signed sheet is the easiest way to show it.
Committees turn over, so write it down rather than leaving it in one keyholder's head. Our guides for community halls and places of worship have worked examples built around exactly this kind of rota.
Hirers and Visiting Groups
Hiring the building out doesn't hand the duty over. The statutory guidance (paras. 6.13 to 6.15) says the responsible person stays the same when premises are hired out. You can ask a hirer to carry out parts of your procedures, but you should explain what's expected, and the hire agreement is the natural place for it. The guidance adds that if the SIA asks, you must be able to show you told the hirer what was required and took reasonable steps to check they did it.
The one exception is a qualifying event: 800 or more people with checks on entry, like tickets. Whoever controls the premises for that event becomes responsible for it. That can never happen at a place of worship, a school or a nursery, where an event of any size leaves the premises standard tier. Our events guide explains the rules.
When Does It Start, and What Is the SIA Doing?
The duties aren't in force yet. No venue has to comply today, and you can't notify the SIA yet because its online system isn't open. Commencement is expected in Spring 2027 at the earliest. Once the duty starts, a standard tier venue has three months to notify, and the Home Office myth buster says notifying is free.
The SIA wants to hear from volunteer-run venues before then. In an update on 8 July 2026, it invited venues to help test its notification platform, comment on its guidance, or host a pilot inspection ahead of commencement, and said it was ‘particularly interested in those from places of worship, volunteer-run community centres, festivals and one-off events’. The update asks people to sign up to the SIA mailing list, and gives MLR@sia.gov.uk as the contact for questions.
Get Your Procedures Written and Your Rota Briefed
Standard Tier was built for venues like yours. Answer questions about your building and it drafts your procedures document in 10 minutes. Volunteers scan a QR code and go through a short training on their phones, whenever they're next in, and you can see who has done it without collecting signatures. One price per venue, with unlimited staff and volunteers, so a long rota costs nothing extra.
30-day free trial · No card required · £18/month (usually £38), unlimited staff and volunteers
Frequently Asked Questions
Are charities exempt from Martyn's Law?
Do volunteers count towards our capacity figure?
Our hall is run by a committee. Is the chair personally the responsible person?
Does someone have to be trained on a course before they volunteer?
If we hire the hall out, does the hirer take over the duty?
Does Martyn's Law apply to volunteer-run venues yet?
Official Sources
- Section 4: Persons responsible for qualifying premises or events
- Section 5: Public protection procedures
- Section 29: Means of giving notices
- Schedule 2: Excluded premises and events
- Interpretation Act 1978, Schedule 1 (definition of ‘person’)
- Home Office statutory guidance (chapters 4, 6 and 7)
- Home Office responsible person factsheet
- Home Office guidance on the notification requirement
- SIA: Martyn's Law, a collective effort (8 July 2026)
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Standard Tier (2026). Martyn's Law for Volunteers and Volunteer-Run Venues. Available at: https://www.standardtier.co.uk/guide/martyns-law-volunteers
Last reviewed: 3 October 2026. Based on the Act, the Home Office statutory guidance and factsheets, and SIA updates available at the time of writing.
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.