- Likely tier
- Depends on each shop’s or centre’s expected numbers
- Thresholds
- Standard at 200–799; enhanced at 800 or more
- Key point
- A centre’s total does not automatically become a shop’s total
- When
- Expected in spring 2027; exact date unconfirmed
01
Check the shop or centre you operate
Retail sale or display of goods, and services provided mainly to visiting members of the public, are listed uses. Premises must be wholly or mainly used for a listed use, include a building and meet the attendance threshold, with no applicable exclusion.
Start by identifying the premises you control. This might be a standalone shop, a unit within a centre or the wider centre. A separate shop within a larger site can qualify on its own numbers.
For a mixed building, review its main use over time. A small customer-facing area does not automatically make an otherwise ordinary office building qualifying retail premises.
02
Count people during predictable busy periods
Use the busiest number reasonably expected together, rather than average footfall or daily transactions. Predictable seasonal peaks, including sales and bank holidays, count. An unforeseen one-off spike does not determine the premises tier.
Include shoppers and staff in the qualifying use area, including contractors and volunteers. If a capacity figure or customer count excludes staff, add them. Consider tills, fitting rooms and other areas when choosing a reasonable method.
Use attendance evidence, a relevant occupancy figure or another justified method. Keep a short explanation of how you reached the number. Total daily visitors can be much higher than the number present together.
03
Separate the centre’s count from each unit’s count
For a shopping centre, the numbers in its units are added together for the centre assessment. An individual unit counts only its own people. A shop can therefore remain below 200 even when the wider centre is enhanced tier.
Nested qualifying premises usually have their own responsible person and qualify using their own numbers. If the same responsible person controls nested qualifying premises, they are treated as one.
Where separate premises qualify, their responsible people must co-ordinate. Map shared entrances, shutters, service routes and announcements with the centre operator. People with some control must co-operate with the responsible person.
04
Prepare procedures staff can use
After commencement, standard premises will need SIA notification and appropriate procedures, so far as reasonably practicable, for evacuation, moving people to a safer place inside, preventing entry or exit, and communication when terrorism is suspected.
Consider who can operate doors or shutters, how instructions reach stockroom colleagues and how customers receive clear directions. Discuss shared routes with the centre rather than assuming your shop can control them.
Standard tier requires no formal risk assessment or written plan. Documenting procedures is recommended, and staff with roles must know what to do. Paid training, CCTV and searches are not standard-tier requirements.
05
Plan the additional work for larger sites
Enhanced premises will need the standard duties plus assessed and reviewed measures covering monitoring, movement of people, physical safety and security, and information security, so far as reasonably practicable.
They will also need a required document describing procedures and measures and assessing how these reduce risk. An organisation must designate a senior individual in management or control. Existing centre arrangements can inform the work, but check them against the new duties.
Wardcote offers hands-on enhanced tier support from an experienced team it works with for enhanced venues. The law does not require buying specialist services or software.
06
Start with evidence and shared contacts
Core duties are not yet enforceable. Commencement is expected in spring 2027, with no fixed date set. Gather your busiest-period figures, confirm who controls the premises and arrange a conversation with neighbouring operators where relevant.
Notification preparation will include the greatest expected number and its calculation method. Wardcote’s standard-tier subscription helps with procedures, staff briefings, records and preparing that notification; you can start free from the pricing page.
Prepare the SIA notificationWardcote’s standard-tier software
FAQ
Common questions
Does Martyn’s Law apply to small shops?
A shop with fewer than 200 people reasonably expected together is outside the premises threshold. Check predictable peaks and include staff.
Does an enhanced shopping centre make every shop enhanced?
No. A separately assessed unit counts its own people, while the centre adds the numbers across its units. Where the same responsible person controls nested qualifying premises, they are treated as one.
Should we count sales and Christmas peaks?
Yes, where they are predictable. The assessment uses reasonably expected peak numbers, rather than average footfall.
Do delivery contractors and volunteers count?
Count staff, contractors and volunteers present in the qualifying use area. Add them if your customer-counting method excludes them.
Must a standard-tier shop install CCTV?
No. CCTV and searches are not required at standard tier, which also requires no formal risk assessment or written plan.
Official sources
- SRC-01The Act as enacted
- SRC-02Home Office statutory guidance
- SRC-03Home Office myth buster
- SRC-04SIA role and commencement update
This page explains the law. It is not legal advice. Check the official guidance for your circumstances.