Martyn’s Law — what retailers need to know & how to prepare

Retailers are no strangers to managing risk. From cyber‑attacks and theft to vandalism and staff safety, the sector operates in an increasingly complex risk landscape. The introduction of Martyn’s Law adds a further dimension, placing a new and specific focus on how retailers prepare for and respond to the risk of terrorism.

Officially titled the Terrorism (Protection of Premises) Act 2025, Martyn's Law is designed to ensure that public premises take proportionate and practical steps to reduce the risk of physical harm to the public in the event of a terrorist attack. While it isn’t expected to come into force until a later date, retailers should already be considering how it may affect their operations.

Here, Claire Burrows and Hannah Hobson from our regulatory team explore the key challenges that retailers face in preparing for Martyn’s Law, how compliance can be balanced with operational practicality (particularly in multi‑site environments) and what ‘reasonably practicable’ looks like in a retail context, while also addressing some common misconceptions.

What challenges do retailers face in preparing for Martyn’s Law?

Although Martyn’s Law has received Royal Assent, it’s not yet in force — but that doesn’t mean that retailers should wait. Early preparation will be critical, particularly for those operating large or complex estates.

Document preparation & compliance

Retailers operating qualifying premises will be expected — so far as is reasonably practicable — to ensure that appropriate public protection measures are in place. 

This includes having clear and workable procedures covering matters such as:

• evacuation
• moving people away from danger
• restricting access to premises where necessary
• sharing information with those on site.

For enhanced duty premises, the documentary requirements are more extensive and include formal statements of procedures, assessments of how those procedures reduce risk and details of existing or proposed security measures and their intended effect.

For retailers with multiple sites, preparing and reviewing this documentation, including risk assessments, plans and protocols, can be time‑consuming. Carrying out a structured gap analysis against existing procedures can help to identify what’s already in place and where further work is required.

Non‑compliance: the cost of getting it wrong

Martyn’s Law will be enforced by the Security Industry Authority (SIA), which will have powers to issue compliance, restriction and penalty notices.

Failure to comply can result in civil penalties and — in certain circumstances — criminal offences, including where false or misleading information is provided or where compliance notices are ignored. Enforcement action is also likely to bring operational disruption and reputational risk, both of which are particularly sensitive in the retail sector.

Training

Ensuring that staff are adequately trained is likely to be one of the most significant practical challenges, particularly for retailers with high staff turnover or seasonal workforces.

Employees need to understand what to look out for, what procedures apply and what their role is in the event of an incident, regardless of how long they have been with the business.

Guidance from the Home Office and the SIA

Further guidance from the Home Office and the SIA is expected ahead of commencement. While this guidance will be important in shaping compliance, retailers shouldn’t assume that preparation must wait. Any measures already being considered should be reviewed carefully once the guidance is published to ensure alignment.

Balancing compliance with operational practicality

Compliance doesn’t need to mean starting from scratch.

Retailers should consider whether existing policies and procedures — for example, those relating to health and safety or fire safety — can be adapted or expanded to incorporate Martyn’s Law requirements. Centralising documentation and adopting consistent approaches across similar sites can significantly reduce duplication.

Training on counter‑terrorism measures can often be built into existing induction and refresher training programmes. Records should be kept to demonstrate that training has been delivered and understood.

Clear signage, accessible checklists and regular discussion of security issues at team and management meetings can all help to embed good practice without excessive cost or complexity.

What does ‘reasonably practicable’ look like for retailers?

‘Reasonably practicable’ requires a balance between the level of risk and the time, effort and cost involved in reducing that risk.

What’s proportionate will vary. A small independent retailer is unlikely to be expected to install expensive security infrastructure or employ dedicated security staff, whereas such measures may be more appropriate for larger premises or enhanced duty sites.

The key is being able to demonstrate that risks have been properly assessed and that sensible, proportionate steps have been taken in response.

Common misconceptions about Martyn's Law

One common misconception arises where a retailer occupies a small unit within a larger building, retail park or shopping centre. In these cases, it’s the capacity of the overall premises, rather than the individual unit alone, that’s relevant. This makes communication and coordination with the person responsible for the wider site particularly important, especially in relation to evacuation procedures and emergency planning.

Another misunderstanding is that Martyn’s Law will require all retailers to invest in costly physical security measures. In reality, it’s deliberately flexible. What’s required will depend on the size, use and risk profile of the premises — and in many cases, compliance may be achieved through proportionate procedures, staff training and preparedness rather than new infrastructure.

Some organisations also assume that preparation must wait until statutory guidance is published. While guidance will be important, many of the underlying principles, such as risk assessment, clear procedures and staff awareness, are already well understood and can be developed in advance. Responsibility for compliance is also not always limited to landlords or shopping centre operators: in practice, obligations may be shared and individual retailers may still need to align with site‑wide arrangements.

Finally, although Martyn’s Law is focused on the risk of terrorism, many of the measures it promotes will also support wider emergency preparedness and day‑to‑day operational resilience.

The ‘Future of Retail’ conference

On 21 April 2026, our retail team will host the Future of Retail: Risk and Resilience Conference in London. This event brings together leading voices to explore the issues shaping the sector’s next chapter — from Martyn’s Law and compliance strategies to safety, crisis response and the realities of digital transformation, including artificial intelligence (AI) and cybersecurity. We’ll also examine the rise of false claims and the evolving world of intellectual property enforcement.

Get in touch with Helena Davies to register your interest.

Talk to us

If you’re unsure how Martyn’s Law may apply to your premises or where to start with preparation, now is the right time to seek advice. Our retail sector specialists and regulatory team can help with gap analysis, documentation, training and ongoing compliance support.

Talk to us by calling 0333 004 4488, emailing hello@brabners.com or completing our contact form below.