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Martyn's Law and aviation events: what organisers need to know

The Terrorism (Protection of Premises) Act 2025 will apply to bigger UK airshows, open days and aviation venues. Here is who is in scope, what each tier asks for, and what to do before it comes into force.

By Events.Aero Checked by Anthony Escott-Lawrence Last checked 10 October 2026

Martyn's Law is the name most people use for the Terrorism (Protection of Premises) Act 2025. It is named after Martyn Hett, who was killed in the Manchester Arena attack in 2017, and it asks the people responsible for busier public venues and events to plan for a terrorist attack, in proportion to their size.

If you run an airshow, an airfield open day, a large fly-in or an aviation museum, it may apply to you. If you run a club night for forty members, it almost certainly won't. This guide explains where the lines fall and what you can sensibly do now.

It is general information, not legal advice. The law, the Home Office guidance and the regulator's guidance are all linked at the end; check them, or take advice, before you decide anything for your own site or event.

Where things stand

The Act received Royal Assent on 3 April 2025. Its duties are not yet in force. So far, only the section requiring the Home Office to publish guidance has been brought in (on 10 April 2026), and that guidance has been published.

The Home Office has said it expects an implementation period of at least 24 months from Royal Assent. The Security Industry Authority (SIA), which will regulate the Act, says it expects the Act to come into force in spring 2027 and will confirm the exact date beforehand. As of October 2026, no date has been set. Until regulations bring the duties into force, nobody has to comply, but this is the time to prepare.

The two tiers, and qualifying events

The Act works in tiers based on how many people it is reasonable to expect on site at the same time, counting staff, volunteers and contractors as well as visitors.

Standard tier premises. A building (or a building with land around it) used wholly or mainly for one of the uses listed in Schedule 1 of the Act, where 200 to 799 people may be present at the same time from time to time. The list includes entertainment and leisure, food and drink, museums and galleries (including outdoor sites displaying historic objects), visitor attractions, halls and conference venues, and aerodromes: premises used for the landing and departure of aircraft, unless they are used only for military purposes.

Enhanced tier premises. The same, but where 800 or more people may be present at the same time.

Qualifying events. An event is in scope, whatever kind of ground it is held on, when all of these are true:

  • it is held on land, in a building, or both, that is not already enhanced tier premises;
  • the public can attend;
  • it is reasonable to expect 800 or more people present at the same time at some point during the event;
  • there are measures in place to check that people have paid, have a ticket or pass, or are members or guests;
  • it is not at excluded premises.

A one-day airshow with a fenced showground, a paid gate and a few thousand visitors is the textbook case. Outdoor events are not exempt: the Act's exclusion for parks and open-air leisure grounds only covers places with no entry checks, and it says in terms that events held there can still be qualifying events.

Points that matter for aviation

Free does not mean out of scope. What counts is whether entry is checked, not whether money changes hands. The Home Office scope factsheet says a free event can qualify if there is a specific entry check, such as a wristband or QR code checked at the gate, and its worked examples treat a free event with compulsory online registration as a qualifying event. A suggested donation on the gate is not a condition of entry. A free, unfenced open day with no checks is unlikely to be a qualifying event, though the premises it is held on might still be in scope.

Airfields can be premises in their own right. Because aerodromes are a listed use, an airfield's buildings could be standard or enhanced tier premises if enough people are reasonably expected there at once from time to time. Peaks count, so a regular busy open day may matter more than a quiet Tuesday. One-off spikes that cannot reasonably recur do not.

Recurring events can change the answer. In one Home Office example, a club's annual fireworks display for about 1,200 people makes the club's own grounds enhanced tier premises, rather than making the display a qualifying event, because it happens every year. An annual show at your own airfield could work the same way. Who is responsible also depends on who controls the site: for an event, it is the person who will have control of the premises for that event.

Larger airports are mostly excluded. Premises with an aerodrome security plan in force under the Aviation Security Act 1982 are excluded, as are events held there. Most general aviation airfields don't have one.

What each tier has to do

Standard tier (maximum penalty £10,000):

  • Notify the SIA that you are responsible for the premises.
  • Have procedures, so far as reasonably practicable, that staff would follow if an attack was happening or about to happen: evacuating people, moving them somewhere safer, stopping people entering or leaving, and telling people what is going on.

Enhanced tier and qualifying events (maximum penalty £18 million or 5% of worldwide revenue, whichever is higher):

  • Notify the SIA. The Home Office's notification guidance says qualifying events should be notified within 14 days of the event first being publicised, through an SIA online portal that is not open yet.
  • Have the same procedures as the standard tier.
  • Assess and put in place, so far as reasonably practicable, public protection measures covering monitoring the site and its surroundings, how people move in, out and around, the physical security of the site, and the security of information about it.
  • Write a compliance document setting out those procedures and measures, and send it to the SIA.
  • If the responsible person is an organisation, such as a club, charity or company, designate a senior individual to make sure it complies.

Counting people

The test is the greatest number reasonably expected at the same time, not the total through the gate. Home Office supplementary guidance suggests methods such as safe occupancy for fire safety (buildings only), historic peak attendance, fixed seating, the maximum number of tickets or registrations issued, or a licence or other cap. Whichever you use, write down how you got your figure; the SIA's notification asks for the method as well as the number.

For a free event, an RSVP limit gives you a number to plan with. On Events.Aero you can set an RSVP limit when you list your event and download your guest list as a CSV (see free RSVPs). Bear in mind that if you check names at the gate, that check is exactly the kind of entry control the Act looks for.

What to do now

Small clubs and strips (club nights, fly-ins well under 200 at once):

  • Write down your realistic peak, including volunteers, and keep it with your event notes.
  • If your peak is comfortably under 200 and you don't check entry, you are very likely out of scope. Look again if the event grows.
  • Free counter-terrorism awareness training on ProtectUK is worth an hour of a volunteer's time anyway.

Open days and mid-sized events (a few hundred at once):

  • Check whether your airfield, hangar or museum building could be standard tier premises.
  • Draft simple procedures for evacuation, moving people to safety, locking down and communicating, and brief your marshals.

Airshows and large events (800 or more at once with a checked gate):

  • Assume you are a qualifying event, or that the site is enhanced tier, until you have shown otherwise.
  • Agree in writing who controls the site for the event: the airfield owner, the show company or the club.
  • Start your assessment and compliance document now, alongside your safety plan and display permissions, and name your senior individual.
  • Note the date you first publicise each event, since notification runs from then.
  • Watch the SIA's pages for the commencement date and its final guidance.

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