SIA consultation on Martyn’s Law guidance closes as IoL urges clearer alignment with licensing frameworks

The Security Industry Authority (SIA) has closed its consultation on how it intends to regulate Martyn’s Law, following extensive engagement with venues, local authorities and security professionals across the UK. The consultation focused on the SIA’s draft Section 12 statutory guidance, which sets out how the regulator plans to oversee compliance once the Terrorism (Protection of Premises) Act comes into force in spring 2027.

According to the SIA, nearly 200 written submissions were received, alongside feedback from more than 1,800 participants who joined webinars and engagement events. The regulator said the responses will help refine its approach to inspections, compliance and enforcement, which it intends to deliver in a “supportive, proportionate and risk‑based” way.

Laura Gibb, Executive Director for Martyn’s Law at the SIA, said the organisation was encouraged by the level of engagement and will use the feedback to ensure the final guidance “meets the needs of those it is intended to support.” The SIA plans to publish its final guidance and a full consultation report in autumn 2026.

The Institute of Licensing (IoL) published its formal response, welcoming the opportunity to comment but raising several concerns about how the draft guidance interacts with long‑established regulatory systems.

The IoL’s key points include the following:

  • Avoiding duplication with existing licensing frameworks
    The IoL warns that the draft guidance does not sufficiently recognise the regulatory duties already placed on many premises under the Licensing Act 2003 and Gambling Act 2005. Without clearer integration, operators could face overlapping inspections and inconsistent expectations.

  • Embedding joint working with local authorities and police
    Licensing authorities and police routinely inspect venues and hold detailed local knowledge. The IoL argues that the SIA should formally build joint inspections, shared intelligence and coordinated enforcement into the final guidance.

  • Clarifying who can act as an inspector
    While the Act allows the SIA to authorise “suitably qualified” individuals, the draft guidance suggests only SIA staff will make compliance decisions. The IoL has asked whether licensing officers could be authorised, noting potential efficiencies and reduced burdens on businesses.

  • Greater transparency in enforcement and appeals
    The IoL calls for clearer drafting on how the SIA will determine when measures “differ materially” from what is reasonably expected, as well as more detail on appeals, notice suspensions and enforcement timelines. It also recommends publishing a regular table of civil penalties, similar to the Gambling Commission’s approach.

The IoL emphasises that it stands ready to support the SIA as the guidance is refined, highlighting its national membership of licensing practitioners, police, legal experts and industry representatives. It says early, clear communication will be essential to help venues prepare ahead of Martyn’s Law coming into force in 2027.

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