Martyn’s Law: The Section 27 Guidance Has Arrived… Now What?

What does it mean for you?

The long-awaited Section 27 statutory guidance for the Terrorism (Protection of Premises) Act 2025 has now been released. For many, this marks the moment where Martyn’s Law moves from conversation into something far more real.

For the first time, we have clear, structured direction on what the legislation expects in practice. It outlines who is in scope, what responsibilities sit with the “responsible person”, and what organisations should now be considering in terms of preparedness, procedures and proportionate security. It brings clarity, and that clarity is important.

But if we are honest, much of what is now written down is not new.

What the Guidance Actually Tells Us

At its core, the guidance reinforces principles that have been understood for some time. Premises and events above certain thresholds must be prepared to respond to a terrorist incident. Larger venues must go further, considering how they reduce vulnerability as well as how they respond. The emphasis is not on predicting where an attack might occur, but on accepting that it could, and being ready for that reality.

Central to all of this is the concept of what is “reasonably practicable”. Not perfection, not excessive spend, but a balanced and justifiable approach that reduces risk and protects people.

The guidance also formalises expectations around scope, responsibility, and the distinction between standard and enhanced tiers. It makes clear that organisations must have workable procedures in place for evacuation, invacuation, lockdown and communication. These are not abstract ideas. They are the foundations of how people will respond in the moments that matter most.

All of this is necessary. All of it is welcome. But none of it should come as a surprise.

The Question We Should Be Asking

The more uncomfortable question is why so many organisations have waited.

Over the past year or more, there has been a tendency to pause, to hold off meaningful action until formal guidance was released. Yet the core expectations have been visible for a long time. Understanding risk, having a plan, training people, and being able to justify decisions are not new concepts. They are the same principles that underpin health and safety, fire safety and good operational management.

The legislation was never intended to create something entirely different. It was designed to bring protective security into line with these existing frameworks, to ensure consistency and accountability across sectors. In that context, the delay in acting may now place some organisations at a disadvantage, not because they were unaware, but because they chose to wait.

The Risk of Waiting Too Long

There is still an implementation period before full enforcement, and that window is important. But it should not be mistaken for time to delay. It is there to prepare properly.

When the legislation comes into force, the question will not be whether organisations had time. It will be whether they used that time effectively. The focus will shift quickly to what has been done, what decisions were made, and whether those decisions were reasonable in the circumstances.

The cost of doing nothing is no longer theoretical. It sits across reputation, operational resilience, and in the most serious cases, the safety of people. That is the reality this legislation is trying to address.

From Guidance to Reality

Perhaps the most important takeaway from the Section 27 guidance is that this is not about paperwork. It is about whether plans work in practice.

In a real incident, what matters is not the existence of a document, but whether people understand it. Can staff recognise a developing threat. Do they know what to do in the first few moments. Can clear instructions be communicated quickly and confidently. Would the procedures in place stand up under pressure.

These are the questions that matter, because these are the conditions under which performance will be judged. Not in a quiet office, but in a fast-moving and uncertain situation.

Where 1705 Consultancy Fits

This is where many organisations are now seeking support. Not because the guidance is unclear, but because applying it properly requires experience, judgement and an understanding of how things work in the real world.

At 1705 Consultancy, our focus is on turning legislation into something practical, proportionate and defensible. That means helping organisations understand whether they are in scope and what that genuinely means for them. It means carrying out structured gap analysis against the Act and guidance, developing procedures that are usable rather than theoretical, and supporting enhanced tier requirements in a way that is appropriate to the specific risks and environment.

It also means working with teams through training and exercises, so that plans are tested, refined and understood. Because a plan that has never been practised is unlikely to perform when it is needed most.

Above all, our approach is built around a simple principle. Supporting organisations to reach a position where, if the worst were to happen, they could look a family in the eye and know they did everything humanly possible.

Time to Stop Talking

The guidance is now in place. The direction is clear, and the expectations are defined.

This is the point to move beyond discussion and into action. To review current arrangements, to understand responsibilities, and to take a realistic view of whether existing plans are sufficient.

“Reasonably practicable” does not mean doing everything. It means doing what is right, proportionate and justified for your organisation, and being able to stand behind those decisions with confidence.

The organisations that act now will not just be compliant. They will be prepared.

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