Martyn’s Law for gyms and leisure centres: does it apply, and what to do

Does Martyn’s Law apply to gyms and leisure centres?

The Terrorism (Protection of Premises) Act 2025 covers premises used for a listed purpose, in this case sports or recreation, where it is reasonable to expect 200 or more people, including staff, to be present at the same time from time to time. Count gym floor, studios, pool, spectator areas, café and staff at their busiest overlap. A leisure centre with a 25-metre pool and a sports hall is usually well over 200.

Between 200 and 799 people means standard tier. From 800 upwards the premises are enhanced tier, with much heavier duties: documented procedures and public protection measures submitted to the SIA, and penalties up to £18 million. If you are near that line, record how you set your capacity figure.

Typical examples in scope:

• leisure centres
• gyms
• swimming pools
• sports halls
• climbing centres
• trampoline parks

What you must do

The standard tier asks for three things, none of which cost money:

1. Notify the SIA. When the Act commences, expected spring 2027, the responsible person tells the Security Industry Authority they are responsible for the premises, through an online service the SIA is building. Nothing is submitted for approval.
2. Have four procedures in place, so far as reasonably practicable: evacuation, invacuation, lockdown and communication. The Act does not prescribe a document, but an inspector will ask to see what you have.
3. Make sure the people on duty know them. Staff, volunteers or hirers must be able to carry the procedures out quickly. A one-page briefing and a signed log is the practical way to show it.

There is no requirement for physical measures, security staff, CCTV or searches at the standard tier. The maximum penalty for non-compliance is £10,000.

What is different about gyms and leisure centres

• Swimmers cannot evacuate into a car park in January. Invacuation and a warm holding area are more important here than in most premises.
• Changing rooms and studios have closed doors and loud music. Communication needs a signal that reaches them, not just a tannoy in reception.
• Lifeguards and instructors are the people who will act. Make sure the briefing reaches casual and agency staff, not only the duty manager.
• Operators running centres for a council need to agree who the responsible person is; usually it is the operator.

Five steps before spring 2027

1. Set your capacity figure: the most people, including staff, at your biggest regular event.
2. Name the responsible person and one day-to-day lead. Write both down.
3. Walk the building and decide three places: the outside assembly point, the safest room inside, and which doors can be locked.
4. Generate the procedures pack, correct anything that does not match the building, and print it.
5. Brief everyone on duty with the one-page sheet, log it, and put a review date in the diary.

Open the free generator with leisure centre defaults .