A common starting assumption when Martyn’s Law comes up: “we’ve got a health and safety policy, doesn’t that cover this?” In almost every case, the answer is no. This page explains why, and what the gap typically looks like in practice.

In principle, terrorism is a workplace and visitor risk like any other, and could sit under a general health and safety framework. Some large organisations had already referenced terrorism response in their H&S documents before Martyn’s Law.

That kind of reference was useful good practice. It did not, and does not, meet the standard the Terrorism (Protection of Premises) Act 2025 now requires.

The Act requires specific, purpose-built procedures:

• Four public protection procedures (evacuation, invacuation, lockdown, communications), each written for the premises.
• Staff training on each procedure, with records kept.
• Exercises that test the procedures in practice.
• Evidence packaging that can be shown to a regulator on inspection.

A line in a general H&S policy saying “in the event of a terrorism incident, staff should follow emergency procedures” does not satisfy any of these.

Three specific issues arise when organisations rely on existing H&S coverage:

1. No purpose-built procedures

The procedures required under Martyn’s Law are different in structure to fire or general emergency procedures. A general H&S framework typically doesn’t contain them.

2. No terrorism-specific training

H&S training covers general risk awareness, manual handling, first aid. It doesn’t cover active threat scenarios, the difference between invacuation and evacuation, or how staff should communicate if the premises loses power or phone signal.

2a. Fire evacuation may conflict with appropriate terrorism response

A critical point: some existing procedures may not simply fall short of Martyn’s Law—they may actively conflict with appropriate terrorism response. A standard fire evacuation directs people toward exits and assembly points. But if an external threat exists, directing people toward exits could move them toward danger. In such scenarios, invacuation (moving people to a safer place within or into the premises) may be more appropriate. This is why existing H&S, fire, or safeguarding policies must be specifically reviewed against the Act’s requirements. Some may need rethinking, not merely adapting.

3. No exercise evidence

H&S policies rarely require a specific exercise of terrorism procedures. Without exercise records, a premises can’t show the regulator that its procedures work in practice.

Organisations with strong existing H&S practice can migrate to Martyn’s Law readiness efficiently. What tends to work:

1. Keep the governance layer. If you already have a responsible person, a safety committee, a reporting structure, that can carry across.
2. Keep the training infrastructure. Learning management systems, training records, refresher cadence.
3. Build the procedures fresh. The four public protection procedures, purpose-built for the premises.
4. Build the exercise layer fresh. Terrorism-specific scenarios, not adapted fire drills.
5. Package the evidence. In a format a Martyn’s Law regulator will recognise.

A purpose-built platform like Prova Risk handles points 3, 4, and 5 directly, and integrates with existing governance and training infrastructure from points 1 and 2.

When inspections begin, the regulator will look for documents and evidence produced specifically for the Terrorism (Protection of Premises) Act 2025. A general H&S policy will not be accepted as substitute documentation.

This is not interpretation: it’s how regulatory regimes work. The regulator inspects against the specific duties of the specific Act it enforces.

The fastest way to know is our free Am I in Scope? tool. A handful of questions, a clear answer, no account needed.

If you already know you’re in scope, Get Started with Prova Risk to prepare your public protection procedures, train your staff, and keep the evidence you’ll need if inspected. £399 per year per site.

• Why Health and Safety and Fire Legislation Don’t Cover Martyn’s Law
• Will My Existing Provider Cover Martyn’s Law?
• What Are Public Protection Procedures?
• What Is Martyn’s Law?
• Is Martyn’s Law Mandatory?
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