Being entirely volunteer-run does not change what the Terrorism (Protection of Premises) Act 2025 asks of a premises. A voluntary-run organisation in scope puts the same public protection procedures in place as any other premises in scope.

Where volunteers do make a difference is the training question, and the answer carries a condition. Volunteers are, for all intents and purposes, treated like staff — provided they will be involved, or could conceivably be involved, in implementing one of the public protection procedures. Where somebody is never going to be involved in that, there is no need to train them or teach them about the plans.

The Act does not have a lighter setting for organisations that run on donated time. If the use is listed in Schedule 1 and 200 or more individuals are reasonably expected on site from time to time, the premises is in scope and needs the four public protection procedures: evacuation, invacuation, lockdown and communication, as four distinct items.

That is worth saying plainly, because “we don’t have any staff” is often offered as a reason the legislation cannot apply. It is not one. What it does change is who is standing in the building when a procedure has to run.

Volunteers also count towards scope. The 200-person threshold is everyone reasonably expected on site from time to time, and staff and volunteers sit in the same total as everyone attending — which often puts the base number higher than a volunteer-run premises assumes.

Salaried or volunteer, the same thing is asked of them. They must know — or be able to show that they understand — the plan, and that they are able to implement it.

That is a test of the role, not of the payroll. Nothing in it turns on whether somebody is paid, on a contract or on a rota. It turns on whether they are one of the people who would be putting a procedure into practice.

The general treatment of this obligation — including what the guidance says about awareness as distinct from formal training — is in do staff and volunteers need training. What follows is the volunteer-run case.

For a training regime, volunteers are treated like staff where they will be involved, or could conceivably be involved, in implementing one of the public protection procedures. Where they are clearly integral to implementing those plans, volunteer or staff makes no difference.

“Could conceivably” is doing a lot of work there, and it is deliberately wider than a rota. The question is not whether somebody is scheduled to hold a role next week. It is whether it is reasonably imaginable that they would be acting if a procedure were called.

For many faith communities that widens the group considerably. Where the same twenty or thirty people unlock the building, steward, count and lock up again, most of them are inside the condition.

The condition has a negative half, and it is real. Where a volunteer is never going to be involved in implementing one of the procedures, there is no need to train them or to teach them about the plans.

That takes a great deal of anxiety out of the question. A community with a long list of volunteers is not being asked to put the whole list through something. Somebody who helps at one fundraiser a year is not automatically in scope.

The judgement has to be made honestly rather than conveniently. Deciding that somebody could never conceivably be involved, and then relying on them on a busy day, is the version that does not hold up.

The condition only becomes usable once somebody has decided who holds a role in each procedure. That is a task for the responsible person, and the step that most often has not happened:

• Who carries out each of the four procedures, named rather than assumed.
• Who could conceivably end up carrying one out — the people who cover, stand in and turn up early.
• What each of them actually does when a procedure is called, in concrete terms.
• Who is genuinely outside it, and why — the decision that keeps the group a sensible size.

The difficulty in a volunteer-run organisation is rarely willingness. It is continuity: the answer has to be true for whoever is on this week, not only for the people who wrote the procedures. Nothing is submitted to the regulator for approval at standard tier, but the responsible person has to be able to evidence the procedures and the briefings on inspection.

Prova Risk builds the four public protection procedures around your premises, assigns the roles within them, and holds the training and exercise records in a single compliance document you can put in front of a regulator. £399 per year per site.

• Do staff and volunteers need training under Martyn’s Law?
• Are places of worship exempt from Martyn’s Law?
• What “so far as is reasonably practicable” actually means
• Do Martyn’s Law procedures have to be written down?
• Who the responsible person is under Martyn’s Law
• Martyn’s Law for places of worship and faith communities
• Martyn’s Law hub