For a multi-academy trust, the responsible person under the Terrorism (Protection of Premises) Act 2025 is the trust itself. Not the individual school, and not its local governing body.

The duty is then phrased across the whole portfolio: the trust must ensure that across all of its schools, public protection procedures are in place so far as is reasonably practicable. That single clause is what makes this a trust-level piece of work rather than a set of separate school projects.

The Act defines a responsible person as the individual or entity with control of, or legal responsibility for, the site in the context of its primary use. In a multi-academy trust, legal responsibility for each academy sits with the trust as the entity, so the trust is the responsible person for each of them.

That does not create one duty for the group. It creates the same duty for every premises, all of it held by the same body. A trust with twelve schools has twelve premises to account for and one responsible person accounting for them.

The practical consequence is that a trust cannot treat this school by school and assume the set adds up. Whatever the position is at the least-resourced primary in the group, that is the trust’s position too.

So the first piece of trust-level work is usually an inventory rather than a document: which schools meet the threshold, what each already holds, and where the gaps are. Every school in scope needs procedures in place, and the trust has to be able to evidence all of them rather than a representative sample.

The temptation at group level is obvious: write one set of procedures, brand it, and roll it out across every school. It is the wrong instinct, and it fails the statutory test at both ends of the group.

So far as is reasonably practicable is assessed for each premises. It weighs the likely effectiveness of a procedure against the burden of putting it in place, taking account of the nature and use of that site, its location, its visitor profile, the resources available there and the mitigation already in place. It is not a size test, and it is not a group-level judgement.

A split-site secondary with six buildings and a single-storey village primary under identical governance will produce genuinely different evacuation, invacuation, lockdown and communication procedures. What should be consistent across a trust is the method, the standard and the reporting — not the content.

Holding the duty and doing the work are different things. The trust can delegate tasks to the people best placed to carry them out, and at school level that will usually mean the head teacher, the school business manager and the site team. They know the buildings.

What delegation cannot move is the responsibility. If a task is delegated across twelve sites and quietly does not happen at two of them, the trust’s position is unchanged.

Which makes this a reporting problem as much as a compliance one. Somebody at trust level has to be able to say honestly that the procedures are in place across every school, which only works if the delegated work reports back somewhere they can see it.

For a state-run school maintained by the local authority, the answer is different: the board of governors is the responsible person, and will almost certainly delegate to the head teacher. That case, together with pupil referral units, is worked through in who is legally responsible at a school.

Trusts with a mixed estate, or schools moving in or out of a trust, are worth checking individually rather than by pattern — the question is always which entity holds legal responsibility for that site in the context of its primary use.

Nothing is submitted to the regulator for approval at standard tier, but each premises has to be able to evidence its procedures on inspection — and at trust level that means being able to produce them for any school on request, not just the ones that were done first.

Prova Risk builds site-specific procedures for every school in a group, holds the training and exercise records against each one, and gives the trust a single view of what is in place across the portfolio. Pricing for groups and trusts works differently from single-site pricing — the multi-site page is the place to start, or talk to us about the shape of your estate.

The school question splits by how the school is governed. The clip below covers the other case.

• Who is legally responsible for Martyn’s Law at a school
• Who the responsible person is under Martyn’s Law
• What “so far as is reasonably practicable” actually means
• Martyn’s Law for schools
• Martyn’s Law for multi-site organisations
• Does Martyn’s Law only apply to large premises?
• Martyn’s Law hub