# How to count people for Martyn’s Law > Count people present together, including staff and volunteers, using reasonable evidence. Compare the six example counting methods. Count the greatest number reasonably expected at the same time from time to time, rather than average attendance or daily footfall. Include employees, contractors and volunteers in the area used for the qualifying purpose. Your method must be reasonable and evidenced, and the greatest expected number and calculation method go in the SIA notification. ## At a glance - **Count**: People present at the same time - **Include**: Visitors, staff, contractors and volunteers - **Use**: Predictable peaks, rather than averages - **Thresholds**: 200 and 800, subject to special treatment ## Define the premises and relevant people Start with the building and associated land. A beer garden used with a pub can form part of the premises, so an indoor-only figure may miss people who should be included. People in the immediate vicinity do not need to be counted. Include employees, contractors and volunteers in the area used for the listed purpose. A ticket figure that only covers customers may need staff added. Check what each source of numbers includes before adding figures together, so you neither omit nor double count your team. For groups of buildings, add numbers together. A shopping centre counts people across its units for the centre, while an individual unit counts its own people. Nested premises can have separate scope and responsibility rules, so define what you are assessing before calculating. ## Look at predictable peaks Use the number reasonably expected at once from time to time. Predictable seasonal peaks, such as sales or bank holidays, count. An unforeseen one-off spike does not establish the same expectation. Think about regular busy services, school assemblies, matchdays or larger bookings that form part of expected use. The guidance gives a village hall example where a one-off concert of 250 does not bring the hall into scope, but such concerts becoming expected would make it standard tier. Total admissions over a day can be much higher than simultaneous attendance. Equally, a quiet weekly average can hide a predictable busy period. Choose evidence that explains the peak rather than the most convenient number. ## Choose a reasonable counting method The Home Office’s supplementary document gives six example methods. They are non-exhaustive and non-statutory: you are not required to use one particular method, but your choice must be reasonable and evidenced to the SIA’s satisfaction. Check whether the evidence describes the relevant premises, expected use and people included. Add staff where the method excludes them, and explain any adjustments. - Fire-safety safe occupancy: use relevant occupancy information, checking what the figure covers. - Historic attendance data: use records that help establish the number present together at expected peaks. - Fixed seating or standing positions: use the available positions, accounting for people not included in them. - Tickets or pre-registration: check what these figures show about simultaneous attendance and whether staff are excluded. - Restrictions: consider limits such as licence capacity and what they cover. - Other justified means: use another reasonable approach with evidence explaining the calculation. [SIA notification guide](https://wardcote.co.uk/martyns-law/sia-notification) ## Learn from the official worked examples The supplementary document includes a café with 180 people indoors and 30 outdoors, giving 210 and standard tier. The example shows why associated outside space matters. When applying a method to your own venue, check whether staff and volunteers are already included. Another example is a stately home with 850 daily visitors but a maximum of 300 at once. It is standard tier because the simultaneous figure, rather than the day’s total, is relevant. These examples illustrate counting. They do not replace the other premises tests, exclusions or special treatment. A qualifying school or place of worship remains standard tier even at 800 or more. ## Check events and keep the calculation understandable Qualifying events use an expectation of 800 or more people at the same time, including staff. Timed entry that keeps the number below 800 at every point means the event does not meet that threshold. The other event criteria and exclusions must still be checked. Record the number, evidence used, people included and reasoning as useful preparation for notification. Explain how the estimate reflects expected peaks. If attendance expectations change, the premises’ tier can change too. Counting is not a requirement for a formal risk assessment at standard tier. The core duties are not yet enforceable, and commencement is expected in spring 2027. The law does not require you to buy software or specialist counting services. Wardcote’s free tier tool gives you a starting point once you have considered your numbers and use. [Check your tier](https://wardcote.co.uk/check-your-tier) · [Martyn’s Law for events](https://wardcote.co.uk/martyns-law/events) ## Questions ### Do staff count towards Martyn’s Law thresholds? Yes. Include employees, contractors and volunteers in the relevant use area. ### Should I use daily visitors or people present together? Use people present at the same time. Daily footfall can give a misleading picture where visitors arrive and leave throughout the day. ### Does a pub beer garden count? Land used with the building can form part of the premises. Include relevant people in the beer garden rather than relying only on indoor attendance. ### Can I use our fire-safety occupancy figure? It is one example method in the supplementary guidance. Check its coverage and add staff if the figure excludes them. ### Do people on the pavement count? People in the immediate vicinity do not need to be counted. That is separate from considering procedures that reduce harm in the vicinity within what you control. ## Sources - [Home Office example counting methods](https://www.gov.uk/government/publications/the-terrorism-protection-of-premises-act-2025/non-statutory-supplementary-document-a-methods-for-assessing-the-reasonable-expectation-of-individuals-present-at-the-premises-and-events-accessible) - [Home Office statutory guidance](https://www.gov.uk/government/publications/the-terrorism-protection-of-premises-act-2025/terrorism-protection-of-premises-act-2025-statutory-guidance) - [Home Office notification guidance](https://www.gov.uk/government/publications/terrorism-protection-of-premises-act-2025-notification-requirement/terrorism-protection-of-premises-act-2025-notification-requirement-accessible) ## Related - [Martyn’s Law standard tier: what you need to do](https://wardcote.co.uk/martyns-law/standard-tier) - [Martyn’s Law enhanced tier: requirements](https://wardcote.co.uk/martyns-law/enhanced-tier) - [Martyn’s Law SIA notification: what to submit and when](https://wardcote.co.uk/martyns-law/sia-notification) - [Martyn’s Law crowd management and event security](https://wardcote.co.uk/martyns-law/events) --- Source: https://wardcote.co.uk/martyns-law/counting-people · Last reviewed 2026-10-16 · Wardcote, venue and event security. General guidance, not legal advice.