The passage of the legislation was reported in a joint Downing Street and Home Office press release of 3 April.

The objective of the new Act - Terrorism (Protection of Premises) Act 2025 - is to ensure that occupiers of premises and those who organise events accessible to the public have a legal duty to put public protection measures in place to reduce the vulnerability of premises to terrorism attacks and to reduce the risk of harm from such attacks. 

The threshold for the standard duty applying is a reasonable expectation that more than 200 people would be present at the premises and if more than 800 are expected to be present an enhanced version of the duty will apply.

Measures that those subject to the duty will be expected to implement will be subject to the test, well-known in the health and safety world, of being required “so far as is reasonably practicable”. This approach brings proportionality to what the Act asks of businesses and has been a constant theme as the legislation has evolved.

The duty will be enforced and overseen by the Security Industry Authority (SIA) acting as statutory regulator. It will develop capacity and resources to do this during what is being referred to as an “implementation period” of up to two years before the regime outlined in the new Act takes effect. This suggests that the duty may not be up and running until early 2027

There has been concern that compliance could impose serious burdens and/or cost on smaller businesses and on community events. The government has recognised this not only by adopting the “so far as is reasonably practicable” test but also by increasing the threshold from 100 to 200 people and in committing to developing consultation and guidance on the detail of the duty in collaboration with potential dutyholders and the SIA during this period.

We have been following the proposals since they first appeared as Home Office consultation in 2021 describing the ‘Protect Duty’. They will touch nearly all sectors and industries in the UK economy and will involve disciplines such as fire and public safety, disaster and business continuity planning, risk management and insurance, licencing and, inevitably, health and safety. 

The new legislation provides the framework for the duty and its enforcement rather than specifying in detail what compliance will look like, but this will be refined during the proposed consultations over the implementation period. 

The passage of the Act should mark the beginning of planning for implementation of the duty: that should not wait until the end of the implementation period. We will be engaging fully with the consultation and implementation process and would be happy to discuss what it will mean in practice for your sector, your business or your clients and risks. Please feel free to contact any of us if you would like to explore that further.