If you look after more than a handful of venues — a diocese, an academy trust, a leisure operator, a county association of village halls — Martyn's Law presents a different problem from the one a single venue faces.
The work per site is small. Knowing the state of forty sites is not.
The duties apply per premises
This is the structural point everything else follows from.
The Act attaches its duties to qualifying premises, not to organisations. So a portfolio is not one compliance question; it is as many questions as you have sites.
Concretely:
- Capacity is assessed per site. A portfolio routinely contains sites that are out of scope, sites in the standard tier, and occasionally one in the enhanced tier.
- Procedures are written per site. They must describe the actual building.
- Notification is per premises. Expect one notification per qualifying site when the portal opens in spring 2027.
- Staff awareness is per site, because the people are different and so are the routes.
The mistake to avoid
The tempting move at scale is a single set of procedures issued centrally to every site.
It does not work, and it is worse than doing nothing because it looks like compliance.
Procedures have to be specific to the premises — where the second exit is, which room you move people into, which doors lock from the inside and who holds the keys. A document that says "proceed to the designated assembly point" describes no building in particular, and a volunteer reading it during an incident learns nothing they did not already know.
What you can standardise is the format: the same structure, the same headings, the same house style, so that a trustee moving between two sites recognises the document. The content underneath has to differ, because the buildings differ.
Who is the responsible person across a portfolio?
Whoever has control of each premises — and the answer may not be the same everywhere in your estate.
- Academy trust: the trust normally holds control of each school site.
- Diocese: control usually sits with each parish or PCC rather than centrally, which makes the diocese a coordinator rather than the duty holder.
- Leisure operator: the operator, even where a council owns the freehold.
- Village hall association: almost always each hall's own trustee body; the association supports rather than holds the duty.
Write down which model applies to each site. Portfolios where the centre assumed it held the duty, and the sites assumed the centre did, are the ones that arrive at spring 2027 with nothing done.
The real problem: knowing where you stand
The compliance work at a single site is a few hours. The problem at forty sites is visibility.
Questions a portfolio holder needs to answer, and usually cannot:
- Which sites are actually in scope?
- Which have procedures written?
- Which are on the current version?
- Which have briefed their people, and when?
- Which have a named responsible person recorded?
Email and a shared drive answer none of these without someone manually chasing. That chasing is the actual cost of Martyn's Law for a multi-site organisation — not the procedures themselves.
What good looks like at scale
A register of premises, with the capacity figure and how it was reached, per site. This is also what makes your notifications straightforward when the portal opens.
A named person per site. Not a central inbox. Someone at the building who knows where the doors are.
Delegated completion. The person who knows the building answers the questions about it; the centre sees the result. A trustee at one hall should not be able to see the other thirty-nine, and should not have to be given a login to a system built for someone else's job.
Status you can read at a glance. Not documents in a folder — a view that says which sites are current and which need action, so the conversation at a board meeting is about the four sites that are behind rather than a general worry about all forty.
One place the evidence lives. When an inspector, an insurer or a funder asks, the answer should be a document you can produce, not a fortnight of chasing.
Where to start
- List your premises and mark which are plausibly over 200. How to count your venue capacity sets out the accepted methods.
- Decide the control model for each site, and record it — see who is the responsible person.
- Name someone at each site.
- Agree a common format for procedures, and let each site fill in its own building.
- Decide how you will see status before you start, not after forty sites have replied by email.
VenueCompliant is built for this shape of problem: a venue list with readiness status per site, bulk import from a spreadsheet, invitations that let a site contact complete their own venue without seeing anyone else's, and a portfolio report you can take to a board or a trustee meeting.
If you would like to talk it through, the multi-site page explains how it works, or start with the scope checker on a single representative site.
Common questions
- Can we write one set of procedures for all our sites?
- No, and it is the most common mistake. Procedures must be specific to the premises — the actual exits, the actual room you move people into, the actual keyholders. A single document covering forty buildings describes none of them. Use a common format by all means; the content has to differ.
- Do we need to assess capacity site by site?
- Yes. Each premises is assessed separately, so a portfolio can contain sites that are out of scope, standard tier, and occasionally enhanced tier all at once.
- Who is the responsible person across a portfolio?
- Whoever has control of each premises. Often that is the central body for all of them, but where a local committee genuinely controls a site the duty may sit locally. Write down which model applies to each site rather than assuming one answer covers the estate.
- Does a trust with forty schools notify the SIA forty times?
- Notification is per qualifying premises, so expect one notification per site. The portal opens in spring 2027, and a portfolio is exactly the case where doing the preparation early matters.
- How do we keep track of which sites are done?
- This is the real problem at scale. The compliance work per site is small; knowing which of forty sites have completed it is the hard part. Whatever you use, it needs to show status per site rather than storing documents.
- One of our sites is over 800. Does that change the others?
- No. Each premises is assessed on its own, so one enhanced tier site sits alongside standard tier ones. Unless it is a place of worship, school or childcare setting, in which case it stays standard tier regardless of capacity.
Official sources
Not sure whether this applies to you?
Seven plain-English questions, about two minutes, and no email address needed. You will get a written answer for your specific venue.
Check if we're in scopeVenueCompliant is an independent guidance tool, not legal advice, and is not affiliated with the Home Office, the SIA or ProtectUK. The law was designed so venues can comply themselves — we make that faster and easier to evidence.