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Martyn's Law and your restaurant: the 200-person test and the four procedures

Martyn's Law is not in force, and nobody has to comply with it until it is. But it will reach more restaurants than most owners expect: the line is 200 people on the premises at the same time, staff included, at the busiest moments of the year. A big Saturday, a terrace in July or a December of office parties can be enough.

Published · For restaurants in England, Wales, Scotland and Northern Ireland, from the Act and the Home Office and SIA guidance. Not legal advice.

What the law is, and when it starts

"Martyn's Law" is the Terrorism (Protection of Premises) Act 2025, which received Royal Assent on 3 April 2025. Its duties apply across the whole United Kingdom: section 36 extends Part 1 to England and Wales, Scotland and Northern Ireland. The regulator is the Security Industry Authority (SIA).

The duties themselves had not come into force when this guide was checked on 4 November 2026. On legislation.gov.uk the sections that define qualifying premises and the procedures are marked as not in force at Royal Assent. The only part switched on so far is section 27, on guidance, from 10 April 2026. The Home Office promised an implementation period of at least 24 months from Royal Assent and says there is no legal requirement to comply until the Act comes into force; the SIA's page says that is expected in spring 2027, with the exact date to be confirmed. That is the window for getting ready without a deadline breathing down your neck.

Is your restaurant in scope?

Section 2 makes premises "qualifying" when three things are true, and a fourth is not:

  • The premises are a building, part of a building or a group of buildings, with or without land around them.
  • They are wholly or mainly used for a use in Schedule 1. Paragraph 2 is the one for us: the sale of food or drink principally for consumption on the premises. The Act never says "restaurant", "pub" or "café"; this paragraph is how they come in.
  • It is reasonable to expect that, from time to time, 200 or more people may be there at the same time in connection with that use.
  • The premises are not on the Act's list of excluded premises (Schedule 2).

Between 200 and 799 people, the premises are in the standard tier. At 800 or more they are enhanced duty premises, with heavier obligations. The Home Office's own scope examples put a pub that regularly passes 200 at weekends, and a restaurant that rises to 250 in the two months before Christmas, in the standard tier, with the operator as the person responsible. A hotel with a restaurant and a spa that expects 800 or more is enhanced, and there the hotel operator is responsible for the whole.

Who is "responsible"? Section 4 says it is whoever has control of the premises in connection with that use. For a restaurant that is normally the operator, not the landlord. Where more than one person has control, each of them is responsible.

Counting to 200: what the Home Office says to count

The number is people, not covers. The Home Office's document on counting says it includes everyone on the premises, and that staff means employees, contractors and volunteers, full time or part time. Your kitchen brigade, the floor team and the person on the door all count.

"At the same time" means together. "From time to time" means occasionally: not an average over a day or a week, and not a one-off you could not reasonably expect to happen again. So the question is not how busy a normal Tuesday is, but what your peak looks like when it happens: the last Saturday before Christmas, Mother's Day, a match on the screens, a summer evening with the terrace open.

The document lists six methods and says they are not exhaustive. For a restaurant, three tend to matter: the safe occupancy figure in your fire risk assessment; your own history of actual usage at peak times; and fixed seating, counted seat by seat and with the staff added. A capacity attached to a licence can settle it too. If you use another method, you write down why. Two of the Home Office's illustrations are close to home: a café with an indoor figure of 180 and 30 outdoor seats comes to 210 and is in scope; a restaurant counted by its fixed seats plus 30 staff is too.

What a standard-tier restaurant will have to do

The SIA lists two duties for the standard tier. First, tell the SIA who the responsible person is, once the law is in force; the SIA is building an online notification system for this, to be tried by volunteers from early 2027. Second, so far as is reasonably practicable, have appropriate public protection procedures in place. Section 5 defines them as procedures, to be followed by the people working on the premises if there is reason to suspect an attack is happening or about to happen there or nearby, for:

  • Evacuation: getting people out of the building, or part of it.
  • Invacuation: moving people to a safer place inside.
  • Lockdown: stopping people entering or leaving.
  • Communication: telling the people on the premises what is happening and what to do.

"Reasonably practicable" weighs the benefit of a step against its cost, time and difficulty, and the resources of the business. The Home Office factsheet is plain that the Act does not require physical alterations to premises, and expects the standard-tier requirements to be simple and low cost, with no equipment to buy. The enhanced tier adds physical and monitoring measures, a written document sent to the SIA and a designated senior individual; few independent restaurants will be there, though a large hotel restaurant or a venue with a big events space may be.

Turning the four procedures into a service routine

  1. Start from your fire plan

    Your fire risk assessment already names the exits, the assembly point and who leads people out. Evacuation for Martyn's Law starts there, with one difference: in an attack, the street outside may not be the safe place, so decide where people go and who decides when to move.

  2. Pick the safer room

    Invacuation means knowing, before the night, which part of the building is furthest from the entrances and the glass: often the kitchen corridor, a stockroom or the private dining room. Decide how the terrace comes inside quickly.

  3. Know who locks what

    Lockdown in a restaurant is the front door, the terrace gate, the kitchen's back door and the yard gate. Name the role that closes each one, not the person, so it works on every shift.

  4. Agree the words

    Communication is how staff tell each other, and then the guests, without causing a crush. A short code phrase for the team, and a plain sentence for the room, written down and the same on every shift.

  5. Make it part of the briefing

    The procedures are for the people working on the premises, so the people working tonight have to know them. In practice that means new starters on their first shift and a reminder in the pre-service briefing, rather than a binder in the office.

Between now and spring 2027

Nothing has to be filed until the Act is in force, and the SIA says it will publish its notification process once its system is built, nearer the start. Its draft section 12 guidance was consulted on from 15 April to 12 June 2026, and the SIA had said the final version and the consultation report would follow in autumn 2026. On 4 November 2026 the consultation page on GOV.UK still said the feedback was being analysed, with no outcome and no final guidance published there. What an owner can do in the meantime costs little: make the count and keep the working; write one page of procedures from the fire plan; walk the team through it; and check the SIA's page again when the final guidance and the commencement date appear.

One thing the SIA is clear about: the responsibility cannot be handed to a consultant. You can take advice from a security adviser, but the duty stays with whoever controls the premises.

Where Slotina fits, and where it does not

Slotina does not write your procedures or make a restaurant compliant with anything. It is where the routine you write can live, so the people on tonight see it.

  • The pre-service briefing shows the evening's large parties, first visits and allergies, and the previous shift's handover note, so a reminder of who locks the terrace gate reaches the next team.
  • Each member of staff signs in with their own login, and every change is recorded with who made it, so you can see afterwards who did what on the night.
  • Each room is drawn to scale with its tables, the private room and the terrace as rooms of their own: the plan you will want in front of you when you decide where people go.
  • The covers report shows how many people you served, and how full the chairs were, over the stretch of dates you choose: a start for the history of your busiest nights, though the law counts people present at once, staff included.
  • Several tablets and phones see the same floor, so the host stand and the floor team are looking at the same evening.

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Martyn's Law: short answers for restaurants

Does Martyn's Law apply to restaurants?

It applies to premises used for selling food or drink principally for consumption on the premises where 200 or more people, staff included, may reasonably be expected at the same time from time to time. A restaurant that reaches that number at its peaks is in scope; most small restaurants are not.

Do staff count towards the 200?

Yes. The Home Office's counting document says everyone on the premises counts, including employees, contractors and volunteers.

When does Martyn's Law come into force?

The day is set by regulations, and none had been made when this guide was written. The SIA and the Home Office say it is expected in spring 2027, after an implementation period of at least 24 months from Royal Assent on 3 April 2025. Until then there is no legal requirement to comply.

Will I need to buy security equipment or alter the building?

Not in the standard tier. The Home Office factsheet says the Act does not require physical alterations, and expects the standard-tier procedures to be simple and low cost with no equipment to buy.

Who is responsible if I lease the premises?

The person who has control of the premises for the restaurant use, which is usually the operator rather than the landlord. If more than one person has control, each is responsible.

The pre-service briefing and the handover note · Staff logins and shared devices · Pricing

Opening a restaurant in the UK: the checklist · Laying out the floor plan · All guides