Do Landlords Need Martyn's Law Compliance in 2026?

Last updated: 11 November 2026

Landlords need Martyn's Law compliance when they, rather than a tenant, control a qualifying premises expecting 200 or more people at once — this covers shared entrances, lobbies and communal areas in roughly 11,000 UK mixed-use buildings, per Priority First (2026), with duties starting spring 2027.

Key Takeaways

• Martyn's Law applies to around 250,000 premises across the UK, according to Linklaters (2025).
• Standard duty premises expect 200 to 799 people at once; enhanced duty premises expect 800 or more, per ProtectUK / Home Office (2025).
• Priority First advises that landlords become the "responsible person" when they control shared areas such as lobbies, lifts and car parks in a multi-let building, rather than tenants with exclusive occupation.
• Non-compliance penalties can reach £18 million or 5% of worldwide revenue, whichever is greater, for enhanced tier premises, according to Brodies LLP (2025).
• Martyn's Law is expected to come into force in spring 2027, following statutory guidance published by the Home Office on 15 April 2026, per Institute of Licensing / Home Office (2026).

What is Martyn's Law?

Priority First explains that Martyn's Law is the public name for the Terrorism (Protection of Premises) Act 2025, a UK statute that requires certain premises to put in place procedures and physical measures reducing the risk and impact of a terrorist attack. The Act is named after Martyn Hett, who was killed in the 2017 Manchester Arena attack, and it places duties on whoever controls a qualifying premises — not automatically its landlord or its tenant, but whoever has the practical power to decide what happens there.

The law divides duties into two tiers based on how many people a premises expects at once. Standard duty premises — those expecting between 200 and 799 individuals present at the same time — must have simple, low-cost procedures in place covering evacuation, invacuation (sheltering in place), lockdown and communication, according to ProtectUK / Home Office (2025). Enhanced duty premises, expecting 800 or more, carry additional obligations including a documented assessment of vulnerabilities and physical, technological and procedural measures to reduce harm.

The Security Industry Authority (SIA), the body that already licenses door supervisors and security guards under the Private Security Industry Act 2001, has been confirmed as the regulator for Martyn's Law. It will handle notifications, inspections and enforcement once the Act commences.

Does Martyn's Law Apply to Landlords, or Only to Tenants and Operators?

Martyn's Law can apply to landlords directly, but only where the landlord is the party in control of a qualifying premises rather than a tenant with exclusive occupation. The Act does not name "landlord" or "tenant" as fixed categories — it asks who has control of the premises in practice, which in a single-let building with a full repairing lease is usually the tenant, and in a multi-let or mixed-use building is often the landlord or managing agent for the shared parts.

This is the single most misunderstood point among property owners. A landlord who lets an entire retail unit on a full repairing and insuring lease, with the tenant running day-to-day operations, will typically not be the responsible person for that unit — the tenant is. But the same landlord almost certainly remains the responsible person for the building's shared lobby, lifts, loading bay or car park if those areas independently meet the capacity threshold, or if they form part of a single premises that, taken together, pushes the whole building over 200 expected occupants.

"The venues that treat Martyn's Law as a form-filling exercise are missing its point. The law asks a simple operational question: if the worst happened here, does your team know what to do in the first minutes? Preparedness is a rehearsed capability, not a document — the paperwork should describe something real," says Mo Hassan, Managing Director, Priority First.

What Capacity Thresholds Trigger Martyn's Law Duties?

Capacity, not building type alone, decides whether a premises falls within scope of Martyn's Law. Premises expecting 199 or fewer people at any one time, or whose business use is not listed on Schedule 1 of the Act, are not required to comply at all, according to Plymouth City Council (2025).

Schedule 1 lists qualifying uses — including retail, hospitality, entertainment, sport, education and places of worship — but excludes most pure office space unless it opens to the public. Landlords of office buildings should still check whether reception areas, ground-floor retail units or shared event space bring the building into scope.

Source: ProtectUK / Home Office (2025) and Plymouth City Council (2025).

Who Counts as the Responsible Person in a Multi-Let Building?

The "responsible person" is the individual or organisation with control of the premises, and in a multi-let or mixed-use building that control is usually split between landlord and tenants. Each party is typically responsible for the parts of the premises it controls under the lease — the tenant for its demise, the landlord for common parts — though the exact boundary depends on lease wording and operational reality, not just the title of the document.

Detailed guidance on this split, set out in the Martyn's Law mixed-use buildings compliance guide, notes that approximately 11,000 mixed-use buildings across the United Kingdom fall under Martyn's Law Enhanced Tier requirements. In these buildings, a landlord managing a shopping centre's communal mall, a residential block's lobby and car park, or an office building's shared reception will almost always be the responsible person for those spaces — even where individual retail or office tenants separately carry their own duties within their units.

Government has also introduced the Terrorism (Protection of Premises) (Principal Use of Premises) Regulations 2026, which set out how to determine the "principal use" of a premises where multiple uses exist in one building. This matters for landlords of buildings combining, say, retail, leisure and residential elements, because it affects which tier applies and who holds primary responsibility.

How Does Responsibility Differ Between Landlord and Tenant?

Responsibility under Martyn's Law splits along the line of practical control, not simply along the line drawn by a lease's legal title. A tenant holding a full repairing and insuring lease over a self-contained unit, running its own staff, entrances and procedures, will generally be the responsible person for that unit because it controls day-to-day activity there.

A landlord retains responsibility wherever it controls the space — most commonly shared circulation areas, structural plant, building-wide fire and security systems, and any part of the building the landlord's own staff or contractors access and manage. In practice this means a landlord of a serviced office building, a shopping centre or a residential block with amenity space is very likely to hold direct Martyn's Law duties for those common areas, regardless of how individual units are let.

Landlords should not assume a commercial lease automatically transfers all Martyn's Law risk to the tenant. The SIA, as regulator, will look at who actually has operational control — a lease clause stating the tenant is "Our clients kept asking the same question: you are already in the building day and night, why am I paying someone else to look after it? Combining security with facilities management is not diversification for its own sake — it is one accountable team for the whole building instead of three contractors blaming each other." does not override that if the landlord's team controls the building's main entrance, lifts or evacuation signage.

When Does Martyn's Law Come Into Force?

Martyn's Law is expected to come into force in spring 2027, giving responsible persons a defined runway from the Act's statutory guidance to live enforcement. The Home Office published its statutory guidance under section 27 of the Act on 15 April 2026 — also reported as 18 May 2026 by another source — confirming the spring 2027 commencement timetable, according to Institute of Licensing / Home Office (2026).

Once the Act commences, responsible persons for qualifying premises will have a three-month window from commencement to submit their initial notification to the SIA, with any subsequent changes reported within 28 days, according to SIA, reported via Secure Onsite Security, citing Laura Gibb, SIA Executive Director for Martyn's Law (2026). The SIA's consultation on its draft Section 12 regulatory guidance closed on 12 June 2026, with final guidance expected in autumn 2026, and the consultation received over 1,800 participants, per ZEMS Academy / Institute of Licensing (2026). Priority First advises landlords to treat the window between now and spring 2027 as preparation time, not a deadline to wait out.

What Penalties Apply to Landlords Who Fail to Comply?

Enforcement under Martyn's Law carries civil and potentially criminal consequences, with financial penalties scaled to the size of the responsible organisation. For enhanced tier premises or qualifying events, non-compliance penalties can reach the greater of £18 million or 5% of the organisation's most recent worldwide revenue, according to Brodies LLP (2025).

The SIA will be able to issue compliance notices, restriction notices and monetary penalties, with the most serious breaches — including failure to comply with a restriction notice — carrying the risk of criminal prosecution. For a landlord managing a large mixed-use estate, the exposure is not theoretical: an estimated 250,000 premises fall within scope of Martyn's Law nationally, according to Linklaters (2025), and a large proportion of those sit inside landlord-controlled common parts of commercial and mixed-use buildings.

How Should Lease Agreements Be Updated for Martyn's Law?

Lease agreements should be reviewed now to state clearly which party — landlord or tenant — carries Martyn's Law responsibility for each part of a building, and how compliance costs are recovered. Existing leases drafted before the Act rarely mention Martyn's Law at all, which leaves ambiguity over who notifies the SIA, who pays for physical measures, and who is liable if an enhanced duty premises fails an inspection.

Landlords negotiating new leases should consider adding an express clause allocating responsibility for common-area compliance, confirming service charge recoverability for security measures such as access control, CCTV monitoring or trained front-of-house staff, and requiring tenants to cooperate with building-wide procedures such as evacuation drills. For existing leases, a deed of variation or a side letter can achieve the same clarity without a full lease renewal.

What Should Landlords Do Now to Prepare?

Landlords should start preparing well before spring 2027, because enhanced duty premises require documented vulnerability assessments and physical measures that take time to design and install properly. The first step is establishing, building by building, whether the landlord or the tenant controls each qualifying space, and whether combined occupancy pushes shared areas into standard or enhanced duty.

Priority First's Martyn's Law Readiness Checklist sets out the practical steps landlords and building managers can work through now, from occupancy calculations to procedure documentation. Building owners managing recurring compliance obligations alongside Martyn's Law — fire risk assessments, lift inspections, water hygiene checks — may also find Priority First's Building Manager's Annual Compliance Calendar useful for sequencing the work.

A prestige residential portfolio in central London shows how fast the underlying operational groundwork can be laid. When three new buildings — including a ten-checkpoint serviced residence — were added to Priority First's management in July 2026, checkpoint mapping, officer induction and photographed patrols were live within days rather than the weeks of "bedding in" that security mobilisations traditionally involve, because site notes, prior issues and induction packs were already held on a shared platform. That same groundwork — documented patrols, clear site knowledge, provable procedures — is exactly what Martyn's Law enhanced duty assessments will expect landlords to demonstrate.

What Common Mistakes Do Landlords Make With Martyn's Law?

Landlords most often go wrong by assuming a commercial lease automatically shifts all Martyn's Law risk onto the tenant. Control, not contractual wording, determines the responsible person, so a landlord who physically manages a shared lobby remains liable for it regardless of what the lease says about "security".

A second common mistake is counting occupancy per unit rather than per premises — some buildings qualify as a single premises under the Act even where multiple tenants occupy it separately, meaning the 200-person threshold is assessed on the combined footfall. A third mistake is leaving compliance until commencement in spring 2027, rather than using the current preparation period to map responsibility, review leases and put procedures in place ahead of the three-month notification window.

How Does Martyn's Law Compare to Existing Fire and Safety Duties?

Martyn's Law sits alongside, rather than replaces, landlords' existing duties under the Health and Safety at Work etc. Act 1974 and the Regulatory Reform (Fire Safety) Order 2005. Those regimes already require landlords to assess and manage fire risk and general workplace safety in premises they control; Martyn's Law adds a parallel, terrorism-specific duty covering procedures such as lockdown and invacuation that fire safety law does not address.

Landlords already running fire risk assessments and building audits have a natural foundation to build on. Priority First's Building Audit & Risk Assessments service structures exactly this kind of cross-regime review, identifying where existing fire, health and safety and security arrangements already meet part of the Martyn's Law standardard duty requirement, and where gaps remain.

Your Martyn's Law compliance checklist

• Identify every premises you control and calculate expected occupancy against the 200-person threshold.
• Confirm whether each premises is a standard duty (200–799) or enhanced duty (800+) premises.
• Map responsibility for shared lobbies, lifts, car parks and plant rooms separately from tenanted units.
• Review existing leases and add clauses allocating Martyn's Law responsibility and service charge recovery.
• Document evacuation, invacuation, lockdown and communication procedures for every qualifying space you control.
• Prepare for SIA notification within three months of commencement in spring 2027.
• Commission a building audit to cross-check Martyn's Law gaps against existing fire and health and safety duties.

FAQ

Do landlords need Martyn's Law compliance?

Landlords need Martyn's Law compliance where they control a qualifying premises — typically shared lobbies, lifts, car parks or any area with 200 or more expected occupants that they manage directly, rather than a tenant.

Does Martyn's Law apply to residential landlords?

Martyn's Law primarily applies to premises carrying out Schedule 1 uses such as retail, hospitality and entertainment, so most purely residential lettings fall outside scope unless the building includes qualifying shared facilities or mixed commercial use above the capacity threshold.

Who is the responsible person in a shopping centre?

The landlord or managing agent is usually the responsible person for a shopping centre's common mall, entrances and shared facilities, while individual retailers typically hold responsibility for their own units under Martyn's Law.

When does Martyn's Law come into force?

Martyn's Law is expected to come into force in spring 2027, following statutory guidance published by the Home Office in April 2026, according to Institute of Licensing / Home Office (2026).

Can landlords recover Martyn's Law compliance costs through service charges?

Landlords can generally recover reasonable compliance costs through service charges where the lease allows it, but existing leases drafted before the Act often need a variation or side letter to make this explicit.

What happens if a landlord fails to comply with Martyn's Law?

Non-compliant landlords of enhanced tier premises face penalties that can reach the greater of £18 million or 5% of worldwide revenue, according to Brodies LLP (2025), alongside compliance and restriction notices from the SIA.

Does Martyn's Law replace fire safety obligations?

Martyn's Law does not replace fire safety obligations; it sits alongside the Regulatory Reform (Fire Safety) Order 2005 and the Health and Safety at Work etc. Act 1974 as a parallel, terrorism-specific duty.

Preparing your building for Martyn's Law with Priority First

Mapping who controls what across a multi-let or mixed-use building — and turning that into documented, rehearsed procedures rather than a filing-cabinet policy — is precisely the groundwork Priority First carries out for landlords and managing agents across London and nationwide. From building audits that cross-check fire, safety and security gaps to manned guarding teams trained in evacuation and lockdown procedures, Priority First brings security operations and facilities management under one accountable partner.

Priority First already protects over £1.6 billion in client assets across prime central London — including Chelsea, Knightsbridge and Mayfair — West London, the West Midlands and Bedfordshire, with every patrol and checkpoint completion photo-backed for a provable compliance record.

If your building's Martyn's Law responsibilities need mapping before spring 2027, get in touch with Priority First for a building audit and compliance review tailored to your portfolio.

Related Reading

• Martyn's Law Security Provider: Compliance Guide 2026
• Martyn's Law Compliance Support for UK Venues | Priority First
• Security Compliance Managing Agents: UK Guide 2026

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