Martyn's Law for gyms and leisure centres
Last reviewed:
If you manage a gym or leisure centre, Martyn's Law may well apply to you at your busiest hour, whatever your membership numbers say. This guide sets out what the law expects of a site like yours, who's responsible for meeting it, and what that actually involves once the pool, the classes and the gym floor are all running at once.
Standard and enhanced tier, side by side
Before working out where your site fits, it helps to understand how the law categorises premises and what those categories demand. Martyn's Law places public premises into two main tiers based strictly on maximum expected headcount at once, including members, visitors and staff together.
Standard tier (200–799 people)
- What it means: focuses on simple, low-cost preparedness.
- Key requirement: you must notify the regulator and maintain basic procedures for four emergency responses (evacuation, invacuation, lockdown and communication).
- Implications: no mandatory paid training, expensive security upgrades, or heavy documentation are required.
Enhanced tier (800+ people)
- What it means: asks more of high-capacity premises, because of the larger potential impact of an incident.
- Key requirement: includes all standard tier duties, plus formal requirements like a documented vulnerability assessment, a designated senior responsible individual, and measures designed to reduce the premises' vulnerability.
Most gyms and leisure centres sit well under this tier. It's the larger multi-activity centres, a full pool, several studios and a café running at once, where the numbers are worth checking properly.
How to tell if your gym or leisure centre needs a plan for Martyn's Law
Gyms and leisure centres sit in the Act's entertainment and leisure activities category. Membership doesn't change that: the guidance is clear that requiring membership or payment to get in does not stop a premises being publicly accessible (para 4.7).
Your tier depends on the headcount you can reasonably expect on site at once during your busiest realistic hour, including predictable spikes like an annual gala or expo, defined in the guidance as occurring "from time to time." That number must include staff on shift, not just members and visitors.
Below are some examples to help illustrate this:
- Gym A (out of scope). An independent 24-hour gym with an access system that genuinely caps occupancy at 40 people never approaches 200, whatever time of day.
- Gym B (standard tier, simultaneous activities). A leisure centre running a pool session, soft play and a fitness class at the same time, plus staff, can easily reach 250 or more. No single activity looks busy on its own, but they all count together.
- Gym C (standard tier, recurring event). A leisure centre's annual inter-club swimming gala draws 280 swimmers and spectators, every year, well over a normal Tuesday's 130. Because that happens reliably, the centre is in scope on that occasion under the "from time to time" test.
To double check whether your site comes under the scope of Martyn's Law, use our free checker.
Who is the "responsible person"?
Someone has to be legally on the hook for getting this done. The law calls that person the responsible person, and for an independent gym, that's usually the owner-operator. For a council leisure centre, control typically sits with the operator or trust running the site day to day, rather than the council as building owner.
If you run a franchised gym, check your franchise or management agreement rather than assuming: it should say plainly who holds control of the premises, and that's who the duty falls on.
See who the responsible person is for the full control test.
What you must do (standard tier)
If you're in the standard tier, compliance requires two primary actions:
- Register your site with the Security Industry Authority
(SIA), the law's regulator.
- This is a simple registration, not an application process.
- There's no fee and no approval process to wait for. The SIA portal isn't open yet, so no action is required until it launches.
- Prepare four core emergency procedures. You must
establish basic, practical procedures for four scenarios:
- Evacuation. Getting people out of the building safely.
- Invacuation. Moving people to safe spaces inside the building.
- Lockdown. Securing doors to keep an external threat out.
- Communication. Quickly telling everyone on site what to do.
Leisure centre challenge: a PA announcement needs to cut through a noisy gym floor or a class with music playing, which is a different problem to reaching a quiet room. A pool changes the evacuation picture too: getting swimmers out safely takes longer and needs its own step, separate from your normal pool safety procedures, which are about drowning risk rather than an external threat. A changing-room sweep, making sure nobody's left behind, is worth building into your plan explicitly rather than assuming staff will think of it under pressure.
What you do not have to do (standard tier)
A lot of the worry around Martyn's Law comes from assuming it means extra security staff, CCTV upgrades, or mandatory training courses for your team. None of that is required at the standard tier.
- You do not need a written plan by law, though the guidance recommends one because it's hard to demonstrate compliance without it (para 7.32).
- You do not need to hire extra security staff or install CCTV beyond what you already have.
- You do not need paid or accredited training. Using a third-party product or service is never mandatory to comply (para 6.7).
- You do not need to review your procedures on a fixed schedule. Reviewing periodically is good practice, not a legal requirement (para 7.29).
- You do not need a risk assessment document or a designated senior individual at the standard tier. Those apply only at the enhanced tier.
How to get Martyn's Law ready in minutes
If you're in scope for the standard tier, every duty above can be worked out and written down by hand, for free. It's perfectly possible, and we'd rather tell you that straight than fear-monger you into hiring a consultant or buying a tool you don't need.
The part that takes time, especially across a gym floor, classes, a pool and a café all running at once, is reading the official guidance, applying it to your actual site, and keeping it documented in a way that would hold up at inspection.
That's what Martyn's Law Plan was built to solve. It's a short online questionnaire any manager can complete, about your site and how each area runs, that turns your answers into a plan written for your gym floor, studios and pool, with printable briefing cards for reception, instructors and lifeguards. Above all, it gives you peace of mind that you're prepared for when an inspection comes.
For now, start with the free tier checker, no email required, or see how the service works for gyms if you already know you're in scope.
Similar venues: golf and sports clubs and village halls.
Common questions
Does it count our total membership, or just how many are in at once?
Just how many are in the building at the same time. The test is your busiest hour, not your membership list. A gym with several thousand members on the books but never more than 150 people on site at once is out of scope. A leisure centre with a full pool, a busy class studio and a café all going at once might easily reach 250 and be in scope, even with far fewer members overall.
We run a 24-hour gym with a cap of 40 people. Are we in scope?
No. If your access system genuinely caps occupancy at 40 and your realistic busiest moment, including staff, never approaches 200, you're out of scope. Keep a dated note of how your cap works and how you checked it holds up in practice (para 4.25), and you have your answer.
We're a franchise. Is this on us or head office?
It depends on who controls the premises, so this is worth checking rather than assuming. For an independent gym, the duty sits with the owner-operator. For a council leisure centre, it usually sits with whichever operator or trust runs the site day to day, not the council as building owner. If you're a franchisee, your franchise or management agreement should say where control sits, and that's who the duty falls on.
About this guide. Written by the Martyn's Law Plan team, based on the statutory guidance published under the Terrorism (Protection of Premises) Act 2025. Last reviewed: . Read the official guidance on GOV.UK.
Sources: Terrorism (Protection of Premises) Act 2025; Home Office statutory guidance (April 2026, updated May 2026) and supplementary documents. Paragraph references are to the statutory guidance. General information, not legal advice. Contains public sector information licensed under the Open Government Licence v3.0.