IoL publishes response to SIA consultation on Martyn’s Law statutory guidance

The Institute of Licensing has submitted its formal response to the Security Industry Authority’s consultation on the draft Section 12 statutory guidance for Martyn’s Law, highlighting the need for clearer alignment with existing licensing frameworks and stronger collaboration with local regulators.

In its response, the IoL welcomes the supportive tone of the draft guidance and the emphasis on helping premises achieve compliance. However, it warns that the document does not sufficiently acknowledge the extensive regulatory regimes already governing most affected venues, including those licensed under the Licensing Act 2003 and Gambling Act 2005. The IoL argues that without explicit recognition of these frameworks, there is a risk of duplication, conflicting requirements and unnecessary burdens on operators.

The submission stresses that licensing authorities and police already carry out routine multi‑agency inspections and hold detailed knowledge of local premises. The IoL urges the SIA to embed collaborative working throughout the guidance, including joint inspections, shared information pathways and coordinated enforcement activity.

A key area where the IoL seeks clarity is the role of inspectors. While the Act allows the SIA to authorise “suitably qualified” individuals, the draft guidance states that compliance decisions can only be made by SIA staff. The IoL has asked the SIA to confirm whether licensing officers could be authorised as inspectors, noting the potential benefits, efficiencies and cost savings of such an approach.

The response also calls for improvements to drafting in several sections, including clearer wording on how the SIA will assess whether measures “differ materially” from what is reasonably expected, and greater transparency around appeals, notice suspension and enforcement timelines. The IoL further recommends that the SIA publish a regular table of civil penalties—similar to the Gambling Commission’s approach—to support consistency and awareness across the sector.

The IoL reiterates its willingness to work closely with the SIA as the guidance is refined and as preparations continue for implementation of Martyn’s Law in 2027. With its national membership of licensing officers, police, industry representatives and legal practitioners, the IoL emphasises that it is well placed to support communication, engagement and practical implementation across the UK.