Having a communication procedure and being able to show you have one are different things. The statutory guidance is blunt about the consequence: if staff responsible for carrying out procedures are not informed or trained in them, “it is likely to be difficult for the responsible person to demonstrate that appropriate and reasonably practicable procedures are in place” (para. 7.52). This page is about closing that gap — what counts as evidence, and how to build it as a by-product of ordinary operations rather than as paperwork.
Source: Terrorism (Protection of Premises) Act 2025: statutory guidance, Home Office, published 15 April 2026 and last updated 18 May 2026.
What the guidance asks you to be able to show
Para. 7.48 sets out the fourth consideration for a communication procedure: “How to embed communication channels, processes, and roles and responsibilities prior to needing to use them. This could be achieved by documenting procedures, briefing staff and testing the communication procedure to ensure effectiveness and that staff are alert.”
Three verbs: document, brief, test. Each leaves a trace, and those traces are your evidence.
Para. 7.28 adds the same point for procedures generally — how staff will be made aware of them and their role, and how procedures will be tested and practised. Para. 7.51 confirms there is no statutory requirement to complete specific counter-terrorism training, but that those responsible for carrying out procedures “must be made aware of the procedures and their specific role” and be given the understanding, experience and tools to carry them out.
Four things worth being able to evidence
- That the content exists. Not “we will warn people” but the actual messages, per procedure, in the languages your audience speaks, ready to send. A plan that requires someone to write copy during an incident is not ready.
- That the channel reaches people. Para. 7.49 asks where people will be and whether information will reach them effectively there. A channel used only in emergencies has never been tested against that question.
- That staff know their role. Who activates, who is informed, how information flows between staff and decision-makers (para. 7.48). Briefing records are evidence; assumptions are not.
- That it has been exercised. Para. 7.28 asks how procedures will be tested and practised. A log of actual use is stronger than a record of a tabletop exercise, because it shows the channel working under real conditions.
The everyday-use argument
Para. 7.49 includes a consideration that is easy to skim past: “How the communication procedure could be used without activating another procedure – for example, to encourage general awareness of suspicious activity or to give instructions related to measures like bag checks.”
This is the most useful sentence in the chapter for anyone thinking about evidence. A channel used every day for ordinary instructions — which gate, which queue, which route, where the bag check is — is a channel whose reach is measured rather than assumed, whose audience is already conditioned to look at it, and whose operation is second nature to the staff who run it.
It also generates a record without anybody writing one. Every routine message is a data point about coverage and timing.
Turning use into a record
The practical question is what to capture. At minimum: what was shown or said, when, where, on which channel, and who initiated it. That is enough to answer, months later, the questions para. 8.61 asks about how and when procedures are used and who makes decisions.
For enhanced tier premises and qualifying events this feeds directly into the section 7 document — see what goes in a Martyn’s Law communication document. For standard tier premises there is no documenting duty, but the same record is what makes para. 7.52 a non-issue.
Para. 8.6 recommends reviewing procedures and measures periodically, possibly annually. A year of usage records makes that review a reading exercise rather than a reconstruction.
What none of this requires
No product and no consultant. Para. 6.7: “It is not mandatory to use third-party products or services to comply with the Act’s requirements.” Para. 7.25: no statutory requirement to purchase equipment for public protection procedures. Para. 6.1: the responsible person cannot delegate the legal responsibility, only tasks.
A logbook in a control room satisfies most of the above. What a system adds is that the record is produced automatically, in the same act as communicating — which is the difference between evidence you have and evidence you have to remember to create.
See also which scenarios your communication should cover and what the communication procedure requires.
Frequently asked questions
Does Martyn’s Law require me to keep records of communication?
The Act does not prescribe a logging format. Para. 7.52 states that if staff responsible for carrying out procedures are not informed or trained, it is likely to be difficult for the responsible person to demonstrate that appropriate procedures are in place — so records of briefing, testing and use are how you show that you can.
What counts as testing a communication procedure?
Para. 7.48 names documenting procedures, briefing staff and testing the communication procedure to ensure effectiveness and that staff are alert. Para. 7.28 asks more generally how procedures will be tested and practised. Everyday operational use of the same channel is one form of exercise, and para. 7.49 explicitly contemplates using the communication procedure without activating another procedure.
How does evidence relate to the compliance document?
Para. 8.61 requires enhanced tier documents to state, for each procedure and measure, how and when it will be used and who can make relevant decisions. Usage records answer both directly.
Do standard tier premises need any of this?
They have no documenting duty under section 7, but they must have procedures in place and, per para. 7.52, be able to demonstrate that staff know them. They must also notify the SIA (para. 7.64).
Do I need software to do this?
No. A control room log satisfies most of it. Para. 6.7 and para. 7.25 are explicit that no third-party product or purchase is required, and para. 6.1 keeps the legal responsibility with the responsible person regardless of what you buy.
Last reviewed 29 July 2026 against the statutory guidance published 15 April 2026 (updated 18 May 2026). This page explains published government guidance. It is not legal advice, and only the SIA determines compliance.
