Martyn's Law for Gyms and Leisure Centres

The Terrorism (Protection of Premises) Act 2025, known as Martyn's Law, received Royal Assent on 3 April 2025. It places new public protection duties on those responsible for many public premises, including gyms, leisure centres and the wider sport and recreation sector.

The Act sets two tiers based on how many individuals may reasonably be expected to be present at the same time, counting staff as well as members and visitors. Standard duty premises cover 200 to 799 people. Enhanced duty premises cover 800 or more.

The regulator is the Security Industry Authority (SIA). There is an implementation period of at least 24 months from Royal Assent, so the Act is expected to come into force in Spring 2027. There is no legal duty to comply until commencement.

For gyms and leisure centres, the headline issue is capacity. A single venue can hold a gym floor, studio classes, a swimming pool, a sports hall and a cafe at the same time, and the combined peak figure decides which tier applies.

The section 27 statutory guidance was published on 15 April 2026. You can read the official section 27 statutory guidance for the full detail behind the points summarised here.

How Martyn's Law applies to gyms and leisure centres

Leisure premises are unusual because attendance moves through the day. A gym may be quiet mid-morning and full at 6pm, while a pool fills during weekend family sessions and a sports hall peaks for a league fixture.

Capacity is assessed against peak use, not a daily average. You should identify the busiest realistic moment across all areas of the site and count everyone present at that time, including reception, instructors, lifeguards, cleaners and contractors.

Occasional higher-attendance events matter too. A charity fitness event, a gala swim or a hired-out sports hall can lift a normally standard duty venue into a different bracket on that day, so plan for your busiest scenarios rather than your quietest.

Working out your capacity

Add together everyone who could reasonably be present at the same time across the whole premises. For a leisure centre this usually means the gym floor, any studios running classes, the pool and changing areas, the sports hall, any spectator seating, the cafe and all staff on shift.

If that combined figure reaches 200, you are at least standard duty. If it reaches 800 or more, you are in the enhanced tier. Our capacity assessment guide sets out a step by step method for multi-area sites like leisure centres.

Standard duty: the four procedures (section 5)

If your venue sits in the standard tier, section 5 requires you to put in place appropriate and reasonably practicable public protection procedures. These are expected to be simple and low cost, with no requirement to buy equipment.

The four procedure areas are:

• Evacuation: getting people out of the premises safely, including from changing rooms, pool surrounds and busy studio spaces where people may be barefoot, wet or mid-class.
• Invacuation: moving people to safety inside the premises when leaving would put them at greater risk, for example holding members in a secure internal area rather than sending them outside.
• Lockdown: securing the premises to prevent or restrict entry, including reception, fire doors propped open during deliveries and any unstaffed side entrances.
• Communication: alerting staff and the public quickly, allowing for music in studios, the pool environment and members wearing headphones who may not hear a standard announcement.

Our standard tier procedures guide explains how to document each of these in proportion to your site.

Enhanced duty: additional measures (section 6)

Larger leisure complexes reaching 800 or more fall under the enhanced tier. In addition to the four procedures above, section 6 requires public protection measures across four categories.

Those categories are monitoring the premises, movement of individuals, physical safety and security, and security of information. For a leisure centre this can touch CCTV coverage of car parks and entrances, how queues form at peak class times, securing plant and pool chemical stores, and protecting membership data.

Enhanced premises must also designate a senior individual responsible for compliance. They must prepare a compliance document recording the procedures and measures and an assessment of how they reduce vulnerability and the risk of harm, and provide that document to the SIA. Our enhanced tier compliance document guide covers what that document needs to contain.

Quick reference: standard versus enhanced

Feature	Standard duty (200 to 799)	Enhanced duty (800 or more)
Core obligation	Four public protection procedures (section 5)	Procedures plus four categories of measures (section 6)
Senior responsible individual	Not required	Required
Compliance document for the SIA	Not required	Required
Equipment	None required	Not specified by the Act
Maximum penalty	£10,000 (daily penalty up to £500)	£18 million or 5% of qualifying worldwide revenue, whichever is greater (daily penalty up to £50,000)

What gym and leisure operators must do

1. Assess your true peak capacity across every area of the site at the same time, including all staff on shift.
2. Confirm your tier, treating 200 as the standard threshold and 800 as the enhanced threshold.
3. Map your evacuation, invacuation, lockdown and communication procedures to real spaces such as pools, studios, changing rooms and sports halls.
4. Plan separately for occasional events, galas and hired-out sessions that lift attendance above your normal day.
5. Train reception staff, instructors and lifeguards so they can act on each procedure, not just read it.
6. Record your procedures clearly, and if you are enhanced, prepare the compliance document and name a senior responsible individual.

Common errors to avoid

• Counting members only and forgetting staff, contractors and instructors, which understates capacity.
• Using a daily average rather than the realistic peak, so a busy 6pm or weekend session is missed.
• Treating the gym, pool and sports hall as separate premises when they share a building and operate at the same time.
• Ignoring occasional events that push a standard duty site into a higher attendance bracket on the day.
• Assuming a fire evacuation plan already satisfies Martyn's Law, when invacuation and lockdown are different responses.
• Overlooking communication in noisy or wet environments where standard announcements may not reach everyone.

Enforcement and penalties

The SIA can use compliance notices, restriction notices and monetary penalties. For standard duty premises the maximum penalty is £10,000, with a daily penalty of up to £500.

For enhanced duty premises and qualifying events the maximum is £18 million or 5% of qualifying worldwide revenue, whichever is greater, with a daily penalty of up to £50,000. The SIA's draft section 12 statutory enforcement guidance is out for consultation, closing at 11:59pm on Friday 12 June 2026, and you can review the SIA section 12 consultation directly.

How Policy Pros can help

Policy Pros prepares Martyn's Law documentation for gyms, leisure centres and multi-use sites, mapping the four procedures (and measures, where you are enhanced) to your actual spaces. Our Martyn's Law compliance documentation service produces clear, proportionate records you can show the SIA.

If you run a wider estate, our hotels and hospitality guide and the main Martyn's Law 2027 compliance guide set out the same duties for other venue types. You may also want our capacity assessment guide to confirm which tier your leisure site falls into.