The Act does not place its duties on "the venue" in the abstract. It places them on a responsible person for each qualifying premises. Working out who that is takes about five minutes, and it is worth doing early, because almost every failure to comply starts with nobody being sure it was theirs.
The test: who controls the premises
Section 4 defines the responsible person by control of the premises. In most cases that is the person or body who decides how the building is used, who can enter it, and what happens in it day to day.
Some common cases:
| Premises | Usually the responsible person |
|---|---|
| Village hall run by a trust | The trustee body |
| Parish church | The PCC, or incumbent and churchwardens, depending on structure |
| Maintained school | The governing body |
| Academy | The trust |
| Leisure centre run by a contractor | The operator, not the council that owns the freehold |
| Independent shop | The business operating it |
| Community centre owned by a council but run by a committee | Usually the committee, if it genuinely controls use |
The recurring theme is that ownership and control are not the same thing. A council that owns a building but has contracted its operation to someone else has generally not retained the control that the duty follows.
The responsible person can be an organisation
This surprises people, but the responsible person is frequently a body rather than an individual — a trust, a PCC, a governing body, a company.
At enhanced tier, section 10 requires that where the responsible person is a body, a named senior individual must be designated to take responsibility for that body meeting its duties.
At standard tier there is no such requirement. But naming someone anyway is the single most useful thing a committee can do, because "the trustees" is a body and a body does not remember to do things. Minute the name. It costs nothing and it is why some halls have procedures and others have a good intention.
Hired and shared buildings
Hiring out. If you hire your hall to a birthday party, a yoga class or a community group, the duty normally stays with you. You have control of the premises; they have a booking. A clause in the hire agreement does not transfer a statutory duty.
What that means in practice is that you should brief hirers — a one-page summary in the hire pack, acknowledged at booking — while understanding that the duty remains yours.
Sharing. Where two organisations genuinely share control — a church and a separately constituted hall committee, a building split between two tenants — each may have duties in relation to what it controls.
The failure mode in shared buildings is symmetrical assumption: each party believes the other has it. Agree it in writing. A short exchange of emails recording who is doing what is worth more than either party's private confidence.
Changes of hands
The duty follows control, so it moves when control moves.
A new operator becomes the responsible person and must notify the SIA in their own right — the previous operator's notification does not carry over. Handing over the existing procedures is good practice and means the new operator is not starting from a blank page. If you sell, lease or transfer a venue, put the procedures in the handover pack.
Notifying the SIA
Notification is one of the two standard tier duties, alongside having the procedures in place.
Section 9 sets the notification requirements, with the detail in regulations. The portal opens in spring 2027, in the same window as enforcement.
Two practical points:
- You cannot do it yet. Nobody can. Any service offering to notify the SIA on your behalf today is offering something that does not exist.
- Expect congestion. A large number of premises will be notifying at once when it opens. Having your capacity figure and your procedures ready beforehand means notification is a form-filling exercise rather than the start of the work.
What to do today
- Decide who has control. For most organisations this is a five-minute conversation.
- Write it down — minute it, if you have a committee.
- Name someone to lead, even at standard tier where the Act does not require it.
- If the building is shared, agree the split in writing with the other party.
- Put a note in the handover pack so the next operator inherits the position rather than rediscovering it.
Then get the substantive work done: the four procedures and staff awareness.
If you are not yet sure whether any of this applies, the scope checker will tell you in about two minutes.
Common questions
- Can the responsible person be an organisation rather than an individual?
- Yes. It is whoever has control of the premises, which is frequently a body — a trustee body, a PCC, a governing body, a company. At enhanced tier a named senior individual must also be designated under section 10; at standard tier that is not required, though naming someone is sensible.
- We hire our hall out. Does the hirer become responsible for their event?
- Normally no. Control of the premises usually stays with the owner or operator, and a hire agreement does not transfer a statutory duty. Brief your hirers, but do not assume the duty moves with the booking.
- We share a building with another organisation. Who is responsible?
- Whoever has control. If control is genuinely shared, both may have duties in relation to the parts they control. Agree it in writing between you — the common failure in shared buildings is each party assuming the other has it.
- What happens if the premises changes hands?
- The duty follows control. A new operator becomes the responsible person and needs to notify the SIA in their own right. Handing over the existing procedures is good practice and saves the new operator starting from nothing.
- When do we have to notify the SIA?
- The notification portal opens in spring 2027, alongside enforcement. Notification requirements sit in section 9 of the Act, with the detail set by regulations.
- Is the responsible person personally liable?
- Penalties under the Act are directed at the responsible person, which is frequently a body rather than an individual. If you are a trustee or governor and want to understand your own exposure, that is a question for your organisation's own legal advice rather than a guidance page.
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 scopeRelated guides
- Standard tier vs enhanced tier: what's the difference?Most venues are standard tier, and the duties are much lighter than people expect. Here is what separates the two tiers and what each one actually asks you to do.
- What is Martyn's Law, and does it apply to my venue?A plain-English explanation of the Terrorism (Protection of Premises) Act 2025 — who it covers, what it asks for, and what to do before enforcement begins in spring 2027.
VenueCompliant 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.