Martyn's Law for Markets: A 2026 Compliance Guide

Last updated: 17 October 2026

Martyn's Law for markets applies where a market — whether a Christmas market, farmers' market or permanent indoor trading hall — can hold 200 or more people at once. Standard Tier covers 200-799 people; Enhanced Tier covers 800 or more. An estimated 250,000 premises fall within scope UK-wide, per Linklaters (2025).

Key Takeaways

• Martyn's Law is the common name for the Terrorism (Protection of Premises) Act 2025, which received Royal Assent on 3 April 2025 and carries at least a 24-month implementation period before enforcement begins, per GOV.UK (2025).
• Standard Tier applies to premises or events with 200-799 people present; Enhanced Tier applies to 800 or more, per ProtectUK (2026).
• Standard duty breaches carry a maximum penalty of £10,000, with a daily penalty of up to £500, per Policy Pros (2026).
• Enhanced duty breaches carry a maximum penalty of £18 million or 5% of qualifying worldwide revenue, whichever is greater, with a daily penalty of up to £50,000, per Policy Pros (2026).
• Martyn Hett, after whom the law is named, was one of 22 people killed in the Manchester Arena attack, per GOV.UK (2026).

What is Martyn's Law?

Martyn's Law is the common name for the Terrorism (Protection of Premises) Act 2026, a piece of UK legislation that places legal duties on the people responsible for certain public premises and events to prepare for the possibility of a terrorist attack. The Act is named after Martyn Hett, one of 22 people killed in the Manchester Arena attack of May 2017, per GOV.UK (2026). His mother, Figen Murray, led the campaign that put the law on the statute book. As she put it: "I realised to my horror that security at venues is literally only a recommendation and I thought I need to change it."

The Act received Royal Assent on 3 April 2025, with an implementation period of at least 24 months before it takes effect, per GOV.UK (2025). For markets — Christmas markets in city centres, weekly farmers' markets, indoor trading halls — the question is not whether the law exists, but whether a particular market falls within its scope, and if so, which tier.

Pulse Operations has published a full readiness guide, Martyn's Law: a readiness guide for security & FM teams, covering the two tiers, core duties and a practical checklist for security and FM teams preparing sites now, ahead of enforcement.

Does Martyn's Law apply to markets?

Martyn's Law applies to a market if the premises could hold 200 or more people, public and staff combined, at any one time. Capacity is judged on maximum occupancy, not average daily footfall, per Pulse Operations's guide, Martyn's Law: a readiness guide for security & FM teams. A quiet Tuesday farmers' market with 40 stallholders and a trickle of shoppers may sit well below threshold. A Saturday Christmas market in a city square, with queues for mulled wine and a stage for carol singers, can easily exceed 200 people at peak — and therefore fall into scope.

This distinction matters enormously for seasonal and outdoor markets. The law does not ask what a market averages across a season; it asks what the premises or event could hold when full. A market operator who only counts footfall on a slow weekday risks miscalculating their own duty.

Standard Tier and Enhanced Tier for markets

Standard Tier applies to premises or events with a capacity of 200-799 people, per ProtectUK (2026). This is the tier most local markets, town-centre Christmas markets and mid-sized indoor trading halls will sit in. Duties here are proportionate and low-cost: simple, common-sense procedures rather than a documented risk assessment.

Enhanced Tier applies to premises or events with 800 or more people, per the same ProtectUK (2026) guidance. A major regional Christmas market — think Manchester's, Birmingham's Frankfurt Market, or Winchester Cathedral's grounds during peak weekends — could reach this tier, particularly if the site includes fairground rides, a beer festival marquee or a ticketed ice rink drawing large sustained crowds. Enhanced-tier sites must maintain a documented risk assessment that stays current, not a one-off document filed and forgotten, per Pulse Operations's guide.

Who is the responsible person for a market?

The responsible person is the individual or organisation legally accountable for meeting Martyn's Law duties at a given premises or event, per Pulse Operations's guide, Martyn's Law: a readiness guide for security & FM teams. For a permanent indoor market hall, this is usually the market operator or landlord. For a temporary Christmas market on council land, it is typically the local authority or the event organiser named on the licence — but this can shift depending on the contractual arrangement with stallholders and security providers.

Markets present a genuinely messier picture than a single-tenant office building or a cinema. A council may own the land, an events company may run the market, individual traders operate their own stalls, and a security contractor patrols the perimeter. Martyn's Law does not eliminate that complexity — it forces clarity onto it. Someone must be named. The NALC guidance on Martyn's Law specifically addresses how parish and town councils, who frequently license markets and outdoor events, need to establish this responsibility before an event goes ahead, not during it.

Shared responsibility with stallholders and contractors

Individual stallholders are not typically the responsible person under the Act — that duty sits with whoever controls the premises or event overall. But stallholder staff still count towards occupancy figures, and their presence affects evacuation and communication planning. A market with 60 stallholders each with one or two staff can add 100-150 people to the headcount before a single member of the public arrives.

"Don't wait for the final guidance to start. Classify your sites by capacity, name a responsible person for each, and write procedures your night team can actually carry out. The operators who treat Martyn's Law as an extension of good practice will find enforcement a non-event." — Mo Hassan, Founder, Pulse

What public protection procedures do markets need?

Public protection procedures are the practical steps a responsible person puts in place to reduce harm and improve responses if a terrorist attack occurs — evacuation, invacuation, lockdown and communication with those on site, per Pulse Operations's guide, Martyn's Law: a readiness guide for security & FM teams. For an open-air market, these procedures look different from a single-building venue with defined exits.

A Christmas market spread across a cobbled square, with stalls forming narrow lanes and multiple access points from surrounding streets, needs an evacuation plan that accounts for pinch points, stall obstruction and the fact that not every stallholder will hear a single announcement over a crowd. Lockdown — keeping people in place rather than moving them — may be more appropriate in some scenarios than evacuation, and market staff need to know which response applies when.

Practical procedures for a market operator typically include:

• A clear chain of command naming who calls an evacuation, lockdown or invacuation
• Rehearsed communication methods that reach stallholders as well as the public — tannoy, radio, marshal relay
• Mapped assembly points that don't funnel crowds through the same choke points used for entry
• A record of who briefed staff, when, and on what — because Martyn's Law expects operators to train and inform staff, not just write a policy
• Liaison arrangements with the local authority, police and any appointed security contractor before the market opens, not on the day

In our own experience running security across mixed-use developments, the sites that struggle most under scrutiny are the ones where the plan exists on paper but nobody on the ground can describe it. That is as true of a market square as it is of a residential block.

What happens if a market fails to comply?

Penalties for non-compliance scale sharply with tier. Standard duty breaches carry a maximum penalty of £10,000, with a daily penalty of up to £500, per Policy Pros (2026). Enhanced duty breaches and qualifying events carry a maximum penalty of £18 million or 5% of qualifying worldwide revenue, whichever is greater, with a daily penalty of up to £50,000, per the same Policy Pros (2026) source.

This scale was confirmed early in the legislative process. During debate on the Protect Duty Bill, UK Parliament Hansard (2022) recorded that "a maximum penalty of up to £18 million or 5% of worldwide turnover will be available for enhanced sites, while standard locations will be subject to a maximum £10,000 penalty." For a local authority running a town-centre Christmas market on a modest budget, even the standard-tier daily penalty of £500 accumulates fast if a breach runs uncorrected across a six-week festive trading period.

The Security Industry Authority (SIA) will regulate and enforce the Act. The SIA has already launched a consultation on section 12 guidance, the detail that will shape how enforcement decisions are made in practice, per GOV.UK (2026). Market operators bidding for council contracts should expect Martyn's Law readiness to appear on tender scoring sheets well before the Act is fully in force — Pulse Operations's own tender guide, How to win your next security tender, notes that buyers of publicly accessible venue contracts are already asking about Martyn's Law readiness under the Terrorism (Protection of Premises) Act 2026 as part of pass/fail selection gates.

Are freely accessible markets and public squares excluded?

This is one of the most common points of confusion for market organisers. The general principle under Martyn's Law is that premises must be assessed on capacity and use, and access controls such as ticketing or gated entry can affect how a site is categorised — but a market held in an otherwise freely accessible public square does not automatically escape scope simply because there's no ticket booth. If the market operator has taken on responsibility for the space, erected stalls, and organised the event, the occupancy threshold is still the test that matters.

Where genuine ambiguity remains — a farmers' market held once a month in a public car park with no barriers, no stage and modest footfall, for example — organisers should err towards a documented decision rather than an assumption. Recording why a site was assessed as out of scope is good practice even where the law does not yet demand it, because it demonstrates the kind of proactive governance the SIA is expected to look for once enforcement begins.

How Pulse Operations supports market security compliance

Markets rarely have the luxury of a single security team dedicated to one building. A security contractor covering a Christmas market might also be running mobile patrol and keyholding rounds across a dozen other sites the same week. That's precisely where a fragmented paper trail becomes a liability under Martyn's Law — if a council or event organiser asks for evidence that a briefing happened, that a patrol covered the perimeter, or that a stallholder induction took place, "it's in someone's head" is not an answer that survives an SIA enquiry.

Pulse Operations's compliance runway brings SIA licensing, BS 7858 screening records, DBS checks, right-to-work documentation, training records and Martyn's Law readiness onto one expiries runway, so a market's responsible person can see at a glance what's covered and what's about to lapse. This mirrors the challenge Pulse's founding team solved on their own contracts before offering the platform to other operators: on one prestige central-London residential estate covering 16 buildings on a single nightly round, the client's original problem was simple — they could not see whether every building actually got its patrols without ringing the office. Since going live on Pulse in March 2026, that estate has logged over 4,100 patrols with 100% of checkpoint completions photo-verified, visible per building in a client portal rather than buried in a paper log.

The same logic applies to a market square. Every checkpoint on a perimeter patrol is completed only by a mandatory watermarked photograph — officer, site, GPS, time — with no QR or NFC tag scanning involved by design. If a market's security contractor is asked to prove a briefing happened or a patrol was walked, the record already exists, timestamped and tamper-evident.

Your Martyn's Law for markets checklist

• Calculate maximum capacity, public and staff combined, for peak trading days — not average footfall
• Classify each market or event as out of scope, Standard Tier (200-799) or Enhanced Tier (800+)
• Name a responsible person for each market or site, in writing
• Draft evacuation, invacuation and lockdown procedures suited to an open-air, multi-stall layout
• Brief and train stallholder-facing staff and security personnel, and log who was briefed and when
• Build a documented, kept-current risk assessment if any market reaches Enhanced Tier
• Confirm liaison arrangements with the local authority, police and security contractor before the market opens
• Keep records ready to demonstrate compliance to the SIA on request

FAQ

Does Martyn's Law apply to outdoor and Christmas markets?

Yes, if the market's maximum capacity reaches 200 or more people, public and staff combined. Standard Tier covers 200-799 people and Enhanced Tier covers 800 or more, per ProtectUK (2026). A small Christmas market may sit below threshold; a city-centre event with fairground attractions may reach Enhanced Tier at peak.

What capacity threshold triggers Martyn's Law for a market or fair?

The threshold is 200 people for Standard Tier and 800 people for Enhanced Tier, based on maximum possible occupancy rather than typical daily footfall, per ProtectUK (2026). Organisers must assess peak capacity, including staff and stallholders, not an average across the season.

Are farmers' markets and seasonal markets covered by Martyn's Law?

Farmers' markets are covered only if they reach the 200-person threshold at any point. Many small, monthly farmers' markets will sit below scope, while larger seasonal markets with entertainment, food halls or festival elements are more likely to reach Standard or Enhanced Tier.

Who is the responsible person for a market under Martyn's Law?

The responsible person is the individual or organisation accountable for meeting the Act's duties, typically the market operator, events company or local authority controlling the premises, per Pulse Operations's guide, Martyn's Law: a readiness guide for security & FM teams. Councils licensing markets should confirm this in writing before the event, as detailed in NALC's guidance for parish and town councils.

What is the difference between Standard Tier and Enhanced Tier for markets?

Standard Tier (200-799 people) requires low-cost, common-sense procedures. Enhanced Tier (800 or more people) requires those procedures plus a documented, regularly updated risk assessment, per ProtectUK (2026) and Pulse Operations's guide.

What penalties apply if a market fails to comply with Martyn's Law?

Standard duty breaches carry a maximum penalty of £10,000 plus up to £500 per day; Enhanced duty breaches carry a maximum penalty of £18 million or 5% of qualifying worldwide revenue, plus up to £50,000 per day, per Policy Pros (2026).

When does Martyn's Law come into force for markets and events?

The Terrorism (Protection of Premises) Act 2025 received Royal Assent on 3 April 2025, with an implementation period of at least 24 months before enforcement begins, per GOV.UK (2025). Market operators should use this period to prepare rather than wait for final commencement.

Securing your market's compliance with Pulse Operations

Markets sit across councils, event organisers, stallholders and security contractors, which is exactly the kind of fragmented responsibility that makes Martyn's Law compliance hard to evidence when it matters. Pulse Operations's compliance runway keeps SIA licensing, BS 7858 records, training and Martyn's Law readiness on one expiries dashboard, while photo-verified patrols give a market operator proof — not a promise — that perimeter checks and stallholder briefings actually happened.

Pulse was built inside the founding team's own London security and FM operation, Priority First, before being opened to other operators — including the 16-building residential estate now logging over 4,100 photo-verified patrols since March 2026. If your organisation runs security for markets, town-centre events or seasonal trading sites, get in touch with Pulse Operations for a demo, or see current published pricing to compare against your existing setup.

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