Martyn's Law for gyms and leisure centres
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Gyms and leisure centres are covered by the Act like any other venue open to the public, and membership does not change that. If your site can reasonably hold 200 or more people at once, from time to time, counting members, visitors and staff together, you're in scope at the standard tier. What decides it is your busiest hour, not how many people hold a membership card.
Does Martyn's Law apply to gyms and leisure centres?
Gyms and leisure centres sit in the Act's entertainment and leisure activities category. A premises is in scope when it meets four conditions: it's a building, it's used for one of the Act's listed activities, it's open to the public, and 200 or more people can reasonably be expected there at once, from time to time.
The condition that catches gyms out is "open to the public". The guidance is clear that requiring membership or payment to get in does not stop a premises being publicly accessible (para 4.7). A members-only gym is treated the same as a pay-as-you-go leisure centre. The only thing that matters is how many people, staff included, could reasonably be in the building at the same time.
Working out your peak-hour capacity
Count everyone who could reasonably be on site at once during your busiest realistic hour: the gym floor, a class studio mid-session, the pool, the café, and staff on shift, all added together. This is not your total membership and not your fire safety certificate, it's a snapshot of your genuine peak.
Two worked examples show how differently this lands. An independent gym with 90 on the floor, 25 in a class and 15 staff comes to 130, out of scope. A leisure centre running a pool session, soft play and a fitness class at the same time, plus staff, can easily reach 250 or more, well into scope. Both are common setups, and the difference comes down entirely to how many activities are running simultaneously in the same building.
Whatever figure you land on, keep a dated note of how you worked it out. The guidance expects your method to be capable of satisfying the SIA if asked (para 4.25). Our free checker takes about two minutes and gives you a printable record of your assessment.
Who is the responsible person at a gym or leisure centre?
The duty sits with whoever controls the premises for its use as a gym or leisure centre. For an independent gym, that's usually the owner-operator. For a council leisure centre, control typically sits with the operator or trust running the site day to day, rather than the council as building owner. If you run a franchised gym, check your franchise or management agreement rather than assuming: it should say plainly who holds control of the premises, and that's who the duty falls on.
What the standard tier actually requires
Two duties: a one-time notification to the regulator that your site exists, and public protection procedures covering evacuation, invacuation, lockdown and communication, in place so far as reasonably practicable. See the standard tier explained for what each one covers in full.
A few things are specific to gyms and leisure centres. PA announcements need to reach people in a noisy gym floor or a class with music playing, which is a different problem to reaching a quiet room. A pool changes the evacuation picture entirely: getting swimmers out safely takes longer and needs its own step, separate from your normal pool safety procedures, which are about drowning risk rather than an external threat. And a changing-room sweep, making sure nobody is left behind during an evacuation, is worth building into your plan explicitly rather than assuming staff will think of it under pressure.
What you do not have to do
- You do not need a written plan by law, though the guidance recommends one because it's hard to demonstrate compliance without it (para 7.32).
- You do not need to hire extra security staff or install CCTV beyond what you already have.
- You do not need paid or accredited training. Using a third-party product or service is never mandatory to comply (para 6.7).
- You do not need to review your procedures on a fixed schedule. Reviewing periodically is good practice, not a legal requirement (para 7.29).
- You do not need a risk assessment document or a designated senior individual. Those apply only at the enhanced tier, for sites expecting 800 or more.
What it costs, and how the service helps
None of the above requires spending, and we won't pretend otherwise. What takes time, especially across a gym floor, classes, a pool and a café all running at once, is working through the detail properly and keeping it documented in a way that holds up at inspection. That's what our service does: a short questionnaire any manager can complete, turned into a plan written for your actual site, with printable briefing cards for reception, class instructors and lifeguards.
Start with the free tier checker, no email required, or see how the service works for gyms if you already know you're in scope.
Similar venues: golf and sports clubs and village halls.
Frequently asked questions
Does it count our total membership, or just how many are in at once?
Just how many are in the building at the same time. The test is your busiest hour, not your membership list. A gym with several thousand members on the books but never more than 150 people on site at once is out of scope. A leisure centre with a full pool, a busy class studio and a café all going at once might easily reach 250 and be in scope, even with far fewer members overall.
We run a 24-hour gym with a cap of 40 people. Are we in scope?
No. If your access system genuinely caps occupancy at 40 and your realistic busiest moment, including staff, never approaches 200, you're out of scope. Keep a dated note of how your cap works and how you checked it holds up in practice (para 4.25), and you have your answer.
We're a franchise. Is this on us or head office?
It depends on who controls the premises, so this is worth checking rather than assuming. For an independent gym, the duty sits with the owner-operator. For a council leisure centre, it usually sits with whichever operator or trust runs the site day to day, not the council as building owner. If you're a franchisee, your franchise or management agreement should say where control sits, and that's who the duty falls on.
Sources: Terrorism (Protection of Premises) Act 2025; Home Office statutory guidance (April 2026, updated May 2026) and supplementary documents. Paragraph references are to the statutory guidance. General information, not legal advice. Contains public sector information licensed under the Open Government Licence v3.0.