Martyn's Law applies to a church or other place of worship only if 200 or more people may be present at the same time, counting clergy, volunteers and musicians as well as the congregation. If it does apply, a place of worship is always standard tier, never enhanced, however many people it holds. A cathedral and a large town-centre church have the same duties.
Why the tier is fixed
For most premises the tier is set by capacity: 200 to 799 is standard, 800 or more is enhanced. Places of worship are treated as standard tier whatever their numbers, in recognition of the fact that they are open, publicly accessible buildings usually run with limited resources.
This is helpful. It means a large church that would otherwise face enhanced tier duties, including a documented assessment sent to the regulator and protective measures, instead has the lighter set: the four procedures and making sure people know them.
Are small churches in scope at all?
The 200 threshold still determines whether the Act applies at all. A chapel that never has 200 people present is out of scope.
The figure to check is your peak, not your average Sunday. Carol services, weddings, funerals, harvest festivals and civic services regularly bring numbers well above normal attendance, and the count includes clergy, servers, choir, volunteers and visiting musicians.
Historic buildings
Many places of worship are listed. Trustees and PCCs often assume this makes compliance harder or more expensive.
It should not. Standard tier duties do not require physical alterations, so nothing here demands faculty permission or works to the fabric. The duties are about deciding what people would do and making sure they know it.
The open door
A church that is open during the day for private prayer presents a genuine difficulty for lockdown, and pretending otherwise helps nobody. The honest procedure describes what is actually possible: who is present, what they can secure, which spaces can be closed off, and what the realistic response is when the answer is that the building cannot be locked down by one volunteer.
The guidance is explicit that duties apply so far as is reasonably practicable. A small congregation with two volunteers on site is not expected to respond like a stadium.
Who needs to know
Clergy, wardens, sidespeople, vergers, musicians, flower guild, the people who run the toddler group, and anyone hiring the church hall. That last group is often the largest and the least connected to whoever wrote the procedures.
Church halls are separate premises
If your church hall is a distinct building with its own use, assess it in its own right. A hall hired out for parties and classes may be in scope on its own terms, and it will often have a higher peak capacity than the church itself.
Where a diocese is involved
Responsibility depends on who controls the premises. In the Church of England that is usually the PCC at parish level rather than the diocese, though dioceses are increasingly coordinating guidance and templates across their parishes. If your diocese is providing a framework, use it: consistency across a large number of buildings is worth more than each parish inventing its own wording.
Common questions
Does Martyn's Law apply to small churches?
Only if 200 or more people may reasonably be expected to be present at the same time. A church that never reaches 200 is out of scope. Check your busiest occasions, such as carol services, weddings and funerals, and count clergy, choir, servers and volunteers as well as the congregation.
Is a church ever in the enhanced tier under Martyn's Law?
No. Premises used for religious worship are always treated as standard tier, however many people they hold. A separate building the church runs for another purpose, such as a conference centre, is assessed on its own terms.
What does a church in scope have to do?
Notify the Security Industry Authority of the responsible person, put in place procedures for evacuation, invacuation, lockdown and communication so far as is reasonably practicable, and make sure the people who work there, including volunteers, know them. No physical alterations are required.
Who is the responsible person for a Church of England parish church?
Usually the parochial church council, because it controls the building day to day, rather than the diocese. The PCC should record who carries out the work on its behalf.
Does the church hall count as part of the church?
Not if it is a separate building with its own use. Assess the hall in its own right; a hall hired out for parties and classes may be in scope even when the church is not.