The Terrorism (Protection of Premises) Act 2025 (the Act) received Royal Assent on 3 April 2025 and imposes a requirement on those responsible for certain premises and events to consider the threat from terrorism and implement appropriate and proportionate mitigation measures. Where the requirements of the Act are not complied with, sanctions could include a fine of up to £10,000 or £18 million depending on the size of the premises or event. It is expected that the implementation period for the Act will be at least 24 months.
Requirements under the Act
Both premises and events may be in scope of the Act:
- Premises – A premises will be in scope where it: (1) consists of a building (including part of a building or a group of buildings) or a building and other land; (2) is used for one or more qualifying activities; and (3) meets the threshold for the number of individuals present at a time. The qualifying activities include uses such as shops, bars and restaurants, places of worship and schools, amongst others. The Act contains two tiers of premises depending on the number of individuals present. The threshold for the standard tier is 200 to 799 individuals, whilst premises which may host 800 or more individuals will be in the enhanced tier and subject to additional requirements. Places of worship and premises used for childcare or primary, secondary or further education that are in scope will always fall within the standard tier.
- Events – For an event to be in scope of the Act, it must: (1) take place on open land, on land with a building (unless the building already falls within the enhanced tier) or within a building that is not already captured by the Act; (2) host at least 800 attendees at a time; (3) have people checking that attendees have a ticket, invitation or entry pass; and (4) be accessible to members of the public. Events will be subject to the same requirements as enhanced tier premises.
The responsible person (RP) for in scope premises or events must be identified. For premises, the RP will be the person who has control of the premises in connection with the qualifying use, such as the tenant under a lease. The RP for an event will be the person who has control of the place at which the event is held for the purposes of that event, for example, the event organiser.
For all premises and events, the RP must ensure that as far as reasonably practicable, appropriate public protection procedures are in place, such as the ability to evacuate, invacuate and lockdown the premises or event. The RP for an event or enhanced tier premises must also put in place appropriate public protection measures which may relate to physical safety and security measures, controlling the movement of individuals and monitoring the premises or event.
Failure to comply with the Act
The Security Industry Authority (SIA) will have sanction powers to use in cases where non-compliance with the Act is serious and persistent. It may issue compliance notices, restriction notices, or penalty notices of up to £10,000 for standard tier premises and £18 million or 5% of worldwide revenue for enhanced tier premises and events. There will also be new criminal offences for failing to comply with information, compliance and restriction notices, providing false or misleading information, obstructing the SIA, and impersonating an inspector.
Impact on landlords
A premises which contains multiple properties may be in scope of the Act, with both the premises and the individual properties having to meet the requirements imposed. The RPs for the landlord and tenants must co-ordinate to ensure that necessary procedures and measures are put in place.
Landlords of enhanced tier premises or premises where an in-scope event is being held will also be required to co-operate with the RP for the premises or event so far as is reasonably practicable to allow the RP to comply with the Act's requirements. Where a tenant's RP determines that structural alterations to the premises are required and the lease states that the landlord's consent is required for this, the landlord must consider such requests to a reasonably practicable level.
At this stage, those responsible for premises and events should consider whether their premises or event could fall within scope of the Act and if so whether the standard or enhanced tier applies. Risk assessments, security reviews and training could be conducted which will highlight any obvious issues and assist with the gradual implementation of changes.
If you have any queries or would like to discuss the new requirements, please contact Nishita Gudka at Nishita.Gudka@lbmw.com.