Keeping the public safe whilst attending a Sunday service or event is imperative and a priority for those in leadership. However, we are concerned that the responsibilities placed on churches and leaders are too burdensome and difficult to follow.

Since 2021 we have been engaging with the proposals to introduce counter-terrorism procedures to everyday businesses and public venues, first through the Protect Duty consultation and again in November 2023 under the previous Conservative government.

The Labour Party in opposition were supportive of this bill and during the general election campaign, Keir Starmer made a personal pledge to Martyn Hett’s mother to introduce a law that would enforce public venues to implement a counter-terrorism response and plan to protect the public. 

The Terrorism (Protection of Premises) Bill, also known as Martyn’s Law following the tragic death of Martyn Hett, who lost his life at the Manchester Area terrorist incident in 2017, will soon return to the House of Commons for report stage and a vote on amendments before moving on to the Lords for further scrutiny. We remain concerned that the lack of clarity throughout the bill makes it challenging for churches and Christian events to prepare and understand what is required of them to keep the public safe. 

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The proposals set out different measures that must be enforced by different ​‘premises’ and ​‘events’ in order to mitigate the impact of an attack. As churches and ministry leaders it is important to understand how the bill categorises use and building types. 

  • Premises are defined in this bill as being a building (or parts of a building, multiple buildings or a piece of land) that is mainly used for one or more qualifying activity.
  • An event that is included in the scope of Martyn’s law must take place on premises, be open to the public and host at least 800 attendees at the same time. 

There is also a tiered approach linked to the type of activity or the number of individuals at the premises, with different requirements for different tiers: 

Standard tier: qualifying premises where it is reasonable to expect between 200 and 799 individuals. 

  • The general aim of this tier is to improve staff preparedness and responses. 
  • There are no requirements to put in place physical measures in this tier. 
  • There is a requirement to have a designated person responsible, who needs to notify the regulator of the premises and put in place the correct public protection procedures. 
  • Procedures need to be in place in the event of evacuation, invacuation and the lockdown of premises.

Enhanced tier: this includes premises or events where it is reasonable to expect 800 or more individuals at the same time. 

  • There needs to be a designated senior individual (DSI) who is responsible for managing the affairs of the responsible person and they must notify the regulator of their premises/​event. They will need to notify the Security Industry Authority (SIA).
  • They have a responsibility to reduce both the vulnerability of the premises to an act of terrorism occurring and the risk of physical harm being caused to individuals if an attack were to occur. Eg they will need to monitor the premises and the immediate vicinity. 


Implications for places of worship specifically

The good news is that regardless of the size of your church all churches fit into the standard tier. Therefore, even if your church has a congregation size of over 800 people, you will not be classified as enhanced tier. This will alleviate the pressures to follow strict protocol and bring in physical measures such as CCTV and the monitoring of the local area. 

However, churches do much more than host a service each Sunday. We are aware that many rent out their buildings for other activities, host community events that may not be counted as ​‘acts of worship’ and many churches do not meet in premises where they are the sole occupier/​building owner. This is an area that requires greater clarity as churches are more nuanced than the proposed legislation accounts for. 

Evangelical Alliance's engagement with the Home Office department

During committee stage of the bill, we wrote to the Home Office to outline various scenarios of evangelical churches, community outreach events and conferencing to share how the bill fails to understand and appropriately accommodate how churches meet and serve in local communities. 

The bill’s current approach to defining public venues and places of worship specifically, and their use, is a ​‘one size fits all’ approach which does not work in the context of churches. Many gather in schools, community halls or theatres, and these venues have specific actions which are hard for some churches to implement. We are arguing for greater clarity around the clause defining a ​‘place of worship’. 

In a recent response to our questions, the Home Office confirmed that when hiring external premises for your church, the premises operator will remain the person responsible. This could potentially mean that the responsibility to ensure procedures are followed will remain with the building rented. 

We are awaiting a response in relation to the specifications of classifying an event of over 800 people that a church may hold every so often and whether this constitutes an ​‘act of worship’ as set out in the law. So much remains unclear in the bill. 

As the bill concludes its stages going through the House of Commons, we will continue our engagement with peers, the government and shadow spokespeople in the House of Lords. 

Please pray the team will find a workable solution for churches and Christian ministries, so that they can continue to serve those in the community, share the gospel through outreach events and know how to keep the public safe should a terrorist incident occur.