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New white paper examines what Martyn’s Law will mean for football clubs
Football Pyramid Partnership has joined forces with leading UK law firm TLT LLP and StadiumLink to provide legal guidance and practical advice for professional and non-league clubs
Football clubs are being urged to start preparing for Martyn’s Law now, as a new white paper examines what the legislation will mean for clubs, directors, volunteers and supporters across the professional and semi-professional game.
Martyn’s Law and Football: The implications for non-league football is published today by Football Pyramid Partnership (FPP), in association with TLT LLP, one of the UK’s leading law firms, and StadiumLink, on 15 October.
The paper brings together specialist legal guidance from TLT with FPP’s first-hand understanding of the operational realities of non-league football.
Martyn’s Law – formally the Terrorism (Protection of Premises) Act 2025 – introduces new requirements intended to improve preparedness for terrorist attacks at publicly accessible premises, including football grounds.
Under the legislation, premises where it is reasonable to expect 200–799 people to be present at the same time from time to time will fall within the Standard Tier, while premises where 800 or more can reasonably be expected will fall within the Enhanced Tier.
The white paper highlights a potentially important issue for non-league clubs: published average attendances do not determine whether a ground falls within the legislation or which tier applies.
The relevant number can include not only supporters but players, management teams, officials, directors, stewards, bar and catering staff, volunteers and others present at the ground. FPP warns that this could mean some clubs with apparently modest average gates exceed the 200-person threshold – or even reach 800 on predictable occasions such as derbies, play-offs and promotion deciders.
The white paper therefore urges clubs to start understanding their attendance patterns, matchday workforces, ground arrangements and existing procedures rather than waiting until football-specific guidance is published.
It also examines the implications for volunteer-led clubs, groundshares and leased grounds; the responsibilities of those controlling premises; the difference between Standard and Enhanced Tier requirements; and the practical preparations clubs can make now without committing prematurely to potentially unnecessary expenditure.
Mark Harris, Founding Partner of Football Pyramid Partnership, said:
“The danger is that clubs look at their average attendance, see a figure below 200 or 800 and assume Martyn’s Law either doesn’t apply to them or puts them in a particular tier. It isn’t that simple.
“A club averaging 150 spectators could have well over 200 people on site once players, officials, volunteers, staff and everyone else are counted. Predictable bigger crowds for derbies and play-offs could also change the picture.
“Our message to clubs is don’t buy first, understand first. Understand your numbers, your ground, your people and your responsibilities. Then, when the detailed football guidance is available, clubs will be much better placed to respond proportionately.”
TLT’s contribution to the white paper provides legal guidance relevant to both professional and semi-professional clubs, including determining whether premises fall within scope, identifying the responsible person or persons, establishing the appropriate tier and understanding obligations to co-ordinate and co-operate with other parties.
Piers Warne of TLT LLP said: “Martyn’s Law will create important new responsibilities for football clubs and those responsible for their premises. Clubs should not wait until commencement before considering how the legislation applies to them.
“Understanding which premises are in scope, who is responsible, the number of people who can reasonably be expected to be present and what procedures or measures may be required will all be important. Early preparation will give clubs the best opportunity to approach compliance in a planned and proportionate way.”
For supporters, the legislation is ultimately intended to make the places they visit safer and better prepared. Depending on the ground and applicable tier, its effects could include better-defined emergency procedures, clearer communications and better-trained staff and volunteers rather than necessarily major visible changes to the stadium.
The paper also stresses that the legislation is based around what is reasonably practicable and proportionate, an important consideration for a game in which the resources and operating models of clubs vary enormously.
FPP believes one of the biggest unanswered questions is how many of the 996 clubs at Steps 1–6 of the National League System could ultimately fall within the Standard or Enhanced Tiers once total numbers on site and predictable attendance peaks are considered.
FREE WHITE PAPER
Martyn's Law and Football Clubs: The implications for non-league football will be published by Football Pyramid Partnership in association with TLT LLP and StadiumLink on 15th October.
The white paper combines TLT LLP's legal guidance for professional and semi-professional clubs with FPP's examination of the practical implications for non-league football.
FREE copies on request from enquiries@footballpyramidpartnership.com
You can also find out more at the Club Sustainability Summit hosted by Football Pyramid Partnership at Accu Stadium, Hudderfield on Thursday 15th October from 6pm - 9pm. The event is free for non-league clubs to attend, to reserve your place email joe@sportsglobal.co.uk