For NHS Trusts, Martyn's Law (the Terrorism (Protection of Premises) Act 2025) should be treated as a governance, security and emergency preparedness issue alongside fire safety, business continuity and major incident planning. Healthcare premises are specifically included within the scope of the Act.
NHS Trusts - What should you do now?
Although the Act received Royal Assent on 3 April 2025, there is an implementation period of at least 24 months before the legal duties come into force. Trusts should use this time to prepare.
1. Identify which sites are in scope: Review all Trust premises, including:
- Urgent treatment centres
- Mental health facilities
- Administrative buildings open to the public
Determine anticipated occupancy levels and whether each site falls into the standard or enhanced duty category.
2. Appoint clear ownership: Assign a senior responsible officer, typically involving:
- Director of Estates and Facilities
- Local Security Management Specialist (LSMS)
- Emergency Planning Lead
Security, fire and emergency planning functions should work together rather than treating Martyn's Law as a standalone requirement.
3. Undertake a terrorism risk assessment. Assess threats such as:
- Marauding terrorist attacks
- Vehicle-as-a-weapon attacks
- Crowded places vulnerabilities
Focus on emergency departments, main entrances, atria, outpatient waiting areas, transport hubs and public gathering spaces.
4. Develop public protection procedures
The Act requires premises to be prepared for terrorist incidents through procedures covering:
- Invacuation (moving people to safer internal locations)
- Communication with staff, visitors and patients
- Emergency services liaison
These should be integrated with existing major incident, fire and business continuity plans.
5. Review physical security measures: Consider:
- Vehicle mitigation measures
- Wayfinding and emergency messaging
Larger premises may need to demonstrate that they have considered and implemented reasonably practicable protective security measures.
Provide awareness training on:
- Recognising hostile reconnaissance
- Suspicious behaviour reporting
- Run, Hide, Tell principles
- Command and control arrangements
Training should be incorporated into existing emergency preparedness programmes.
7. Exercise and test arrangements
Trusts should regularly test:
- Security response arrangements
- Interface with fire evacuation procedures
- Major incident escalation processes
Tabletop and live exercises should be undertaken and recorded.
As a Fire Engineer: A key consideration is the interaction between fire evacuation strategies and terrorist response strategies. For hospitals, a fire response often requires evacuation, while a terrorist incident may require lockdown or invacuation. Trusts should therefore review:
- Cause-and-effect programming of fire alarm systems
- Door release arrangements
- Smoke control interfaces
- Security lockdown functions
- Emergency communications
to ensure conflicting responses are understood and managed. This aligns security preparedness with existing HTM fire safety arrangements.
Practical recommendation: For an NHS Trust in 2026, we would recommend establishing a Martyn's Law gap analysis against current:
- Fire safety management (HTM 05 series)
- Security management standards
- EPRR (Emergency Preparedness, Resilience and Response) arrangements
- Business continuity plans
and producing a Trust-wide implementation programme before the Act becomes enforceable.
