Why Your Lockdown Plan Probably Won't Satisfy Martyn's Law

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We have known the primary legislation for Martyn's Law was coming for a while. But Six days ago—on 15 April—the Home Office finally published the definitive Terrorism (Protection of Premises) Act 2025 Statutory Guidance. This is the official instruction on exactly how the regulator expects you to comply.

While most secondary schools and large primaries have spent years refining evacuation and lockdown drills, reading through this new guidance reveals a specific requirement that is missing from almost every school emergency plan I’ve seen.

The good news is that under the Act, education settings have a deliberate carve-out. Even if you have 1,200 pupils and staff on site, schools automatically fall into the Standard Tier, not the Enhanced Tier. This keeps your compliance burden focused on procedures rather than expensive physical security upgrades.

The catch is what the Security Industry Authority (SIA) will be looking for when enforcement begins in spring 2027. They won't just want to see a generic major incident plan. They are looking for four specific, documented public protection procedures: evacuation, lockdown, information sharing, and invacuation.

That last one is where almost everyone has a gap.

We know how to lock down a building. We know how to get everyone out during a fire. But invacuation is subtly different. It is the specific process of bringing people from outside into a safer internal area in response to an external threat.

If there is an incident on the road outside, or a threat in the surrounding neighbourhood, the safest response is to bring anyone outdoors—pupils in the playground, staff in the car park, visitors at the gate—inside and secure them. Right now, if you ask a site manager what happens in that scenario, they’ll likely say, "we bring the kids inside."

Under Martyn's Law, that verbal understanding isn't enough. It has to be a formally documented procedure, distinct from a standard internal lockdown, and attributable to a named 'Responsible Person'.

The compliance gap here isn't a lack of intent; it's a lack of specific language. Most schools are 75% of the way there. The work between now and 2027 is mapping what you already do against the specific requirements of the Act, writing that distinct invacuation procedure, and making sure the SIA has the paperwork they expect.

There is also a minor administrative trap here for multi-academy trusts regarding exactly who registers as that 'Responsible Person' across 30 different sites, but that is a bridge to cross once the SIA portal goes live. For now, check your emergency framework. If "invacuation" isn't explicitly listed, you have 12 months to write it in.

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