Where Are We Now with Martyn’s Law?
We are now roughly twelve months into the anticipated 24-month implementation period of Martyn’s Law, formally known as the Terrorism (Protection of Premises) Act. Yet one of the most anticipated elements, Section 27 guidance, remains outstanding.
For many organisations, this has created a sense of pause. A feeling that meaningful action should wait until the full picture is published. It is understandable, but it is also risky.
Because the foundations of Martyn’s Law are not new. They are built on expectations that have existed for years across safety, security and risk management. The difference now is not the introduction of responsibility, but the clarity and scrutiny that will follow.
The Legal Reality: You Are Already Accountable
Even in the absence of Section 27 guidance, organisations are already operating within a well-established legal framework. The Health and Safety at Work etc. Act 1974, the Management of Health and Safety at Work Regulations 1999, and the Occupiers’ Liability Acts all place clear duties on those responsible for premises and events.
These duties require organisations to assess foreseeable risks and to take proportionate steps to mitigate them. The threat of terrorism and serious violence is no longer hypothetical. It is a recognised and foreseeable risk within the UK.
This means the standard you will be judged against is not whether you waited for guidance, but whether you acted reasonably based on what you already knew.
Why Waiting for Guidance is a Risk in Itself
There is a growing narrative across industries that action will follow once the final guidance is released. The reality is that incidents do not align themselves with legislative timelines.
Delays in preparation create gaps. Gaps in planning, in understanding, and ultimately in response. When incidents occur, reviews repeatedly highlight the same issues. Communication breaks down. Roles are unclear. Plans exist but are not understood or are too complex to follow under pressure.
Martyn’s Law is not introducing these problems. It is bringing them into focus.
Communication: The Difference Between Control and Chaos
If there is one area that consistently defines outcomes during an incident, it is communication. In those first few moments, clarity and speed are everything.
Yet many organisations still rely on outdated or fragmented systems. Radios that do not reach all areas. Messages passed verbally. Teams working in isolation without a shared understanding of what is happening.
In reality, effective communication must provide immediate reach, clear instruction, and the ability to receive information back from those on the ground. Without that, even the most well-written plan becomes ineffective.
This is often the single biggest point of failure, and equally the single biggest opportunity to improve.
Lockdown, Invacuation and Evacuation: Plans Must Work Under Pressure
Most organisations will say they have plans in place for evacuation or lockdown. The real question is whether those plans are usable in a live environment.
In a fast-moving situation, there is no time to interpret lengthy procedures or debate the correct course of action. Staff need to instinctively understand what to do, when to do it, and who is responsible for making that decision.
Lockdown, invacuation and evacuation are often confused or poorly understood. Without training and realistic exercising, this confusion becomes delay. And delay in these situations can have serious consequences.
Plans should be simple, clear and practised. Anything more complex risks failing when it matters most.
First Aid Provision: Moving Beyond a Tick Box
First aid is another area that is often approached as a minimum requirement rather than a risk-based necessity. However, expectations are shifting.
The level of medical provision should reflect the environment, the type of activity, and the potential severity of incidents. A small office environment will have very different needs to a crowded venue or large-scale event.
Where higher risks exist, there is increasing scrutiny around whether provision is truly proportionate. This includes not only the presence of equipment, but the competence of those expected to use it and the ability to escalate effectively when required.
In the aftermath of an incident, this is rarely an area that avoids attention.
Training and Exercising: Where Plans Become Reality
A plan that has not been tested is simply an assumption. It may look effective on paper, but until it is exercised, its weaknesses remain hidden.
Training should go beyond awareness. It should place individuals in realistic scenarios where they are required to make decisions, communicate clearly and operate under pressure. This is where confidence is built and where organisations begin to understand how they will actually perform.
It is also where gaps become visible, allowing them to be addressed before they are exposed in a real incident.
What Should Organisations Be Doing Now?
The absence of guidance should not delay progress. If anything, it should encourage organisations to focus on what is already known and within their control.
This means taking a practical and proportionate approach. Understanding your risk profile, reviewing current arrangements, and identifying where improvements can be made. Strengthening communication, ensuring staff understand their roles, and testing plans in realistic conditions are all steps that can and should be taken now.
None of this requires waiting. It requires intent.
A Measured Approach to Support and Solutions
There is an increasing number of products and services positioning themselves as solutions to Martyn’s Law. Some are helpful. Others risk adding complexity without addressing the core issues.
Effective preparedness is not about adopting the most advanced system. It is about ensuring that whatever is in place is understood, reliable and supports decision making in a crisis.
For many organisations, this may include targeted training, structured exercises, or the introduction of communication platforms such as Share999 to support real-time information sharing. The key is that these solutions are implemented in a way that aligns with the organisation’s actual risks and operational reality.
Final Thought: This Will Be Judged in Hindsight
At some point, decisions made today will be examined in the context of an incident.
The absence of formal guidance will not remove responsibility. The question will be whether reasonable and proportionate steps were taken based on the information available at the time.
This is not simply about compliance. It is about accountability.
And ultimately, it is about being able to stand behind your decisions and know that you did everything that was reasonably practicable to protect the people in your care.
Because when it matters most, that is the standard that will define you.