Update from Michelle Russell on Martyn's Law
Source: gov.uk (2025-11-27)

An update from Michelle Russell, Chief Executive of the SIA, on the recent work of the SIA on Martyn’s Law.

Once Martyn’s Law received Royal Assent on 3 April 2025, and the SIA was confirmed as the new regulator, we wasted no time starting the work required to prepare for go-live.

Go-live will be when Parliament, through its statutory instruments, will commence Martyn’s Law and our role as regulator. This is Parliament’s decision, but we are getting ourselves ready for Spring 2027.

What is the SIA’s role as regulator?

I am often asked what our role as regulator is. It is to regulate against Martyn’s Law, and the legal requirements and framework Parliament has set out in the Terrorism (Protection of Premises) Act 2025. These requirements will be clarified by the Home Office’s statutory section 27 guidance about the requirements. This guidance is important as if there are concerns a requirement under the Act has not been complied with, a person affected can seek to evidence and show they acted in accordance with the guidance and so are not in non-compliance.

Parliament has given the SIA the responsibility of determining whether a premises or event is in compliance with those requirements as well as the responsibility to provide advice and guidance to them. At the SIA, we need to be operationally independent from the Home Office, law enforcement and other partners in our case working and decisions about whether an event or premises is complying or not and when we use our powers.

What has the SIA been doing since April 2025?

I am asked why we are we not hearing more from the SIA. In fact, some of you have been hearing a lot from us – at events and conferences across the country – since April, with those premises and events in scope of Martyn’s Law. And you will hear more from us next year once the Home Office guidance is published.

In the meantime, we have been working at pace, building capability and capacity and exploring and testing with depth the things we need to do in advance of go-live. Much of this is the behind-the-scenes work, building blocks we need to do internally first.

Here is some of what we have done over the last six months.

Securing funding

We have been agreeing new, separate grant funding to be provided direct by the Home Office to the SIA to fund the SIA’s new Martyn’s Law work. This is important as this new work is not being funded by SIA licence holders’ fees. We hope to hear final confirmation of the funding available for 2026 and 2027 soon.

Recruiting a new director

We have recruited an excellent new lead executive director who will start in early January. For such an important role it has been a rigorous recruitment exercise. I am particularly grateful to Figen Murray for taking part in the recruitment process.

Designing a new organisational structure

We have created a blueprint design for new functions and teams for each of the different areas we need.

There will be over 100 new operational posts created in the SIA’s Martyn’s Law team, working on:
- guidance and other educational and outreach work
- the formal notifications that premises and events in scope of Martyn’s Law will make
- desk-based casework on compliance issues, as well as scrutiny and assessment of compliance documents and plans submitted by enhanced tier premises
- inspections and formal investigations into concerns about non-compliance and follow up enforcement work
Mirroring the approach we have with our SIA security inspections teams, we will be basing our inspectors and inspection teams regionally and locally across the UK. Other office-based roles will be mostly in a new SIA location in Manchester.

What are our next steps?

The SIA teams are actively working on:
- our draft section 12 guidance about how we propose to exercise our functions particularly the investigatory powers – we will be publicly consulting on this once the Home Office guidance is made available in 2026
- joint engagements and events with the Home Office to raise awareness of the new law and our role
- developing a new risk framework for our work to ensure we have clear priorities and apply a consistent approach to decisions we make
- a new regulatory model, business plan, internal business processes and procedures and, critically, building, setting up, and testing the supporting digital and case working systems for our casework – this involves a significant amount of planning and design work and a robust procurement exercise which will take time to carry out
It is important we get these steps right and this work continues at pace to ensure that we have the right people, tools and systems in place. As we progress further, and as the Home Office guidance becomes available, you will hear more from us and our teams in the build up to commencement.

How will the SIA approach its role as regulator?

Our role as the Martyn’s Law regulator will be primarily advisory from the start to give venues and events in scope – predicted to be around 155,000 standard tier premises and 25,000 enhanced tier premises – the opportunity to get compliance right first. We expect to find and highlight positive good practice. As well as identifying and advising those who are not doing enough to comply, we intend to carry out deep dives into specific issues relating to compliance, to inform our evolving guidance.

If we find non-compliance issues, you can expect us as regulator to be robust but fair and proportionate in our approach including on enforcement where we need to take further steps to ensure compliance. Where we need to, we will deal swiftly and effectively with non-compliance using the powers we have been given.

Many premises and events will already have some of the procedures and measures in place and have already acted to ensure premises are safe and secure to visitors and protected against obvious threats. Martyn’s Law is about considering these from the perspective of reducing the risk of physical harm to individuals arising from acts of terrorism and for those larger premises and events in scope, reducing the vulnerability of those premises and events to acts of terrorism in the first place.

As the new regulator I expect us to be guiding, testing and making sure that premises and events in scope are doing enough to meet the requirements, and this is the case consistently across the UK. The SIA inspectors and teams will be checking that, where there are appropriate plans, procedures and measures in place, they are being put into practice, are known about, and are working effectively.

In terms of outcomes, we want to ensure through our work and awareness of the new law, ultimately premises and events are and feel a safe place to be where everyone plays their part in preparing for and protecting them from terrorist attacks.

Parliament gave us the role to keep under review the effectiveness of the new law’s requirements in reducing the risk of physical harm to individuals arising from acts of terrorism and the vulnerability of enhanced duty premises and qualifying events to acts of terrorism. As our regulatory work starts, of advising, supporting, and inspecting premises and events, we will be able to do so.

What is the role of private security?

This is a question that comes up a lot at events attended by security professionals keen to hear and know about Martyn’s Law. Private security businesses, security operatives and professional advisors are not in scope of the law. However, they clearly are interested parties and stakeholders as Martyn’s Law is about strengthening and improving protective security and security standards across the UK. Visible, alert, proactive, professional security can be a deterrent, need to know the premises arrangements for lock downs, evacuations, and invacuations. They may be the first response in the event of an incident.

How will we be held to account?

The SIA’s role going forward will be collectively regulating and improving standards in private security and protective security at premises and events across the UK.

I, and my team, very much have the aim of Martyn’s Law at the centre of our thinking as we prepare for the Martyn’s Law responsibility we have been trusted with. We hold the memory of the 22 people who died, and all those who were injured and affected by the horrendous events on 22 May 2017 in the Manchester Arena inquiry, clearly in the forefront of our minds as we do.

There are quite rightly high expectations for both the positive impact and success of Martyn’s Law and of the SIA as regulator; we absolutely want and expect to be held to account for effectively delivering on our role, not just by Parliament and ministers, but by those premises and events in scope, the public and of course Figen Murray, whose son, Martyn Hett, the new law is named after, and the campaign team, who fought so hard to make Martyn’s Law a reality – we know and expect you to keep scrutinising our progress and timely delivery.

Further information

For those seeking further information in the meantime, the Home Office has published a Martyn's Law myth buster (https://assets.publishing.service.gov.uk/media/69281f35b3b9afff34e960f0/martyns-law-mythbuster.pdf) (PDF, 294 KB, 4 pages). This is a valuable resource for those seeking to deepen their understanding of, and help others understand, Martyn’s Law.