Martyn’s Law, officially the Terrorism (Protection of Premises) Act 2025 received Royal Assent on 3 April 2025. It has been introduced to strengthen protective security and preparedness against terrorist attacks. However, it does not come into force immediately. The government has set an implementation period of at least 24 months, meaning enforcement is expected to begin around early 2027.
This time allows for:
- Establishing the new regulator function within the Security Industry Authority (SIA)
- Publishing detailed guidance
- Giving organisations time to prepare and comply.
What does the Act do?
It places a legal duty on those responsible for certain premises and events to assess the risk of terrorism and plan how to respond in the event of an attack.
The act applies to healthcare premises, including hospitals, GP surgeries, and other NHS buildings.
The act uses a tiered approach based on expected occupancy:
- Standard duty premises with capacity of 200–799 people. Premises that fall into this category must have basic emergency preparedness measures:
- Evacuation
- Invacuation
- Lockdown
- Communication
- Staff training on safe routes and use of security equipment.
- Enhanced duty premises with capacity of 800+ people. Premises that fall into this category have additional requirements over and above those requirements set out above:
- Risk assessments
- Physical security measures (e.g., CCTV)
- Possibly hiring security staff.
What does this mean for primary care?
Most GP surgeries, dentists’ community pharmacists, opticians and small primary care centres will not meet the 200-person threshold, so they are likely out of scope for mandatory duties.
Larger health centres or hubs (with multiple practices or services) may fall under standard duty if they can reasonably expect 200+ people at the same time (including staff and patients).
Following an assessment, and if in scope the premises must:
- Appoint a designated senior individual (DSI) responsible for compliance
- Implement basic protective measures and staff training
- Prepare response plans for terrorist incidents
Even if below the threshold, the Home Office and NHS guidance encourages voluntary adoption. This includes:
- Basic preparedness measures, for example evacuation and lockdown plans
- Staff awareness training such as action counters terrorism (ACT) awareness e-learning
- Clear communication protocols for emergencies
The rationale is that terrorist attacks are unpredictable, and smaller premises can still be affected directly or indirectly.
Key actions for primary care providers
- Check occupancy levels to determine if your premises meets the threshold.
- If in scope:
- Identify the responsible person (DSI)
- Develop emergency procedures (evacuation, lockdown, communication)
- Train staff on terrorism awareness and response
- If out of scope, consider voluntary adoption
- Keep an eye on Home Office guidance and NHS Estates updates for detailed compliance requirements
Author Helen Simmonds, PCC adviser
PCC provides advice and support on primary care premises matters, including drafting estate strategies, utilisation reviews, assessment of available estate across neighbourhoods and provide project management for premises developments. Contact enquiries@pcc-cic.org.uk for more information or visit www.pcc-cic.org.uk/premises-practices.
