Martyn's Law around the world

With the Terrorism (Protection of Premises) Bill just having had its second reading in parliament, Jake Deadman looks at similar legislation/ regulations around the world, to see what level of equivalence, and importance, overseas governments put on protecting crowded spaces from the threat of terrorist attacks and asks whether Martyn's Law would be a relevant, and beneficial, piece of legislation in countries that have experienced terrorist attacks in the last decade.

Several countries have introduced laws and regulations that are similar in nature to the UK’s forthcoming Terrorism (Protection of Premises) Bill, also known as Martyn’s Law, which aims to improve security measures in crowded spaces and Publicly Accessible Locations (PALs) to mitigate the risk of terrorist attacks. These laws often focus on public safety, counter-terrorism measures, and enhancing preparedness for attacks, particularly in places that attract large crowds.

Starting in January 2015, we highlight global terrorist attacks that have shaped our worldview, and the legislation to mitigate against further attacks. Here are some key examples of similar legislation or regulations in other countries:

France – Vigipirate Plan (Plan Vigipirate)

Overview: France’s Vigipirate Plan is a national security measure that combines permanent vigilance, prevention, and protection efforts to combat the risk of terrorist attacks. It mandates increased security measures for public venues, including transportation hubs, cultural sites, and large events.     

Focus: The plan applies to public and private organisations, and it requires them to enhance preparedness, strengthen access controls, and train staff in identifying suspicious behaviour.     

Relevance: Like Martyn’s Law, Vigipirate emphasises safeguarding publicly accessible locations and encouraging public vigilance against terrorism.

United States – Protective Security Measures (DHS/NIPP)

Overview: In the U.S., the Department of Homeland Security (DHS), through the National Infrastructure Protection Plan (NIPP), provides guidelines and frameworks to secure public spaces and critical infrastructure, including commercial facilities, public venues, and mass gatherings.     

Focus: The DHS issues guidelines for managing security risks at public venues, large-scale events, and places with high foot traffic. Venue owners are encouraged to adopt risk management strategies, including threat assessments and emergency preparedness.     

Relevance: Although there is no single law directly equivalent to Martyn’s Law, the NIPP provides a comprehensive framework that encourages private and public collaboration in enhancing security at Publicly Accessible Locations.

Australia – Australia’s Strategy for Protecting Crowded Places from Terrorism

Overview: Australia has implemented a national strategy specifically designed to protect crowded places, such as shopping centres, stadiums, and tourist sites, from potential terrorist attacks. This strategy was developed in partnership with law enforcement agencies, industry, and private sector stakeholders.     

Focus: The strategy focuses on sharing intelligence, providing protective security advice, and encouraging businesses and local governments to adopt protective security measures, such as installing physical barriers and conducting vulnerability assessments.   

Relevance: Like Martyn’s Law, this strategy aims to ensure that owners and operators of crowded places take responsibility for enhancing their security measures to protect the public.

Germany – Video Surveillance Improvement Act (Videoüberwachungsverbesserungsgesetz)

Overview: Germany’s 2017 Video Surveillance Improvement Act encourages the increased use of video surveillance in public spaces, particularly in areas where terrorist attacks are deemed more likely, such as public transportation hubs, shopping centres, and stadiums.   

Focus: While not directly focused on the same areas as Martyn’s Law, it emphasises heightened security in publicly accessible locations, promoting increased use of video surveillance as a preventive measure.     

Relevance: Although narrower in scope, the Act shares the objective of increasing security in public places, particularly areas that may be vulnerable to terrorist attacks.

Canada – Critical Infrastructure Protection Act (CIPA)

Overview: Canada’s Critical Infrastructure Protection Act (CIPA) aims to safeguard key infrastructure and publicly accessible areas, including event spaces and venues, from terrorism. The act encourages the development of security and resilience strategies for these areas.   

Focus: The legislation focuses on conducting threat assessments, sharing intelligence, and enhancing the preparedness of venues that may be targeted by terrorists.     

Relevance: Similar to Martyn’s Law, this Act mandates a collaborative approach to protecting critical infrastructure and public spaces from potential terrorist attacks.

European Union – Directive on the Protection of Critical Infrastructure

Overview: The EU has established several directives concerning the protection of critical infrastructure, which include Directive 2008/114/EC (No longer in force, Date of end of validity: 17/10/2024;) on the identification and designation of European Critical Infrastructure and Directive 2022/2557 on the resilience of critical entities.     

Focus: These directives require member states to assess and improve the resilience of publicly accessible locations and infrastructure against various threats, including terrorism. They mandate preparedness and risk management procedures for operators of such venues.   

Relevance: Although focused on critical infrastructure, many of these directives also apply to Publicly Accessible Locations (PALs), mandating similar protective measures to those in Martyn’s Law.

New Zealand – National Security System Handbook

Overview: New Zealand’s National Security System Handbook outlines how the government, in partnership with local authorities and businesses, should approach counter-terrorism efforts and risk management for public venues and events.     

Focus: It includes preparedness measures, risk assessments, and emergency response planning for crowded places and high-risk public venues.     

Relevance: While not legislated in the same way as Martyn’s Law, New Zealand’s approach involves similar risk mitigation and preparedness strategies aimed at protecting Publicly Accessible Locations.

Singapore

Singapore has robust counter-terrorism measures in place, although it does not have a direct equivalent to the UK’s forthcoming Terrorism (Protection of Premises) Bill. However, Singapore’s counter-terrorism framework includes several key laws and initiatives that aim to protect the public from terrorist threats, particularly in crowded or publicly accessible areas.

Infrastructure Protection Act (IPA) 2017:

Overview: Singapore’s Infrastructure Protection Act (IPA) is the closest equivalent to Martyn’s Law. It mandates protective security measures for critical infrastructure and certain large, publicly accessible buildings. The IPA requires building owners to incorporate security measures into the design of new developments deemed to be at risk of terrorism, something that the current draft version of the Terrorism (Protection of Premises) Bill does not.     

Focus: The Act applies to a wide range of infrastructures, including transport hubs, government buildings, and large commercial premises. It mandates that developers conduct security-by-design assessments, which are reviewed by government authorities, and implement physical security measures such as barriers, surveillance, and controlled access.     

Relevance: Similar to Martyn’s Law, the IPA focuses on preventing attacks in crowded places and ensuring that public areas are better protected against terrorism. It also addresses the need for building resilience to potential attacks.

Public Order Act (POA)

Overview: The Public Order Act (POA) in Singapore gives the authorities the power to regulate and control public assemblies and events, especially those that may be potential targets for terrorist activity. This includes large-scale gatherings and events in public spaces.     

Focus: The Act enables the police to impose conditions on event organisers, including requiring them to implement security measures like bag checks, crowd control barriers, and vehicle mitigation solutions.     

Relevance: The POA plays a role in protecting public spaces and large events from potential terrorist threats, which aligns with the objectives of Martyn’s Law in safeguarding PALs. 

Counter-Terrorism Measures and Initiatives

SGSecure Initiative: This public awareness programme launched by the Singapore government is designed to engage the community in counter-terrorism efforts – much like the UK’s Protect UK site. It encourages businesses, event organisers, and the public to adopt security measures, including the reporting of suspicious behaviour, conducting drills, and preparing response plans for terrorist incidents.     

Security Screening and Access Control: Singapore mandates security screening and vehicle checks at sensitive and high-traffic locations, such as shopping malls, transport hubs, and tourist attractions, to prevent potential attacks.     

While Singapore’s Infrastructure Protection Act (IPA) is not an exact replica of Martyn’s Law, it shares the goal of protecting PALs from terrorist threats, but it goes further by mandating proactive security measures incorporated into building design. Alongside other initiatives like the Public Order Act and SGSecure, Singapore has a comprehensive counter-terrorism framework that reflects a strong commitment to public safety and protection from terrorism, similar to the intent behind the UK’s forthcoming Martyn’s Law.   

While Martyn’s Law is a unique legislative proposal tailored to the UK context following the 2017 Manchester Arena attack, several other countries have implemented comparable frameworks or laws aimed at protecting public spaces from terrorism. These laws focus on risk assessment, preparedness, and the implementation of security measures in public venues to reduce the risk of mass casualties in the event of a terrorist attack. Each country’s approach reflects its unique security landscape, but the overarching goal of protecting the public from vehicular and other forms of attacks remains consistent across these nations.

Figen Murray, mother of Martyn Hett, after who the law is named, observed: “Terrorism is a global blight, and it is therefore good to see that so many countries worldwide already have various legislative measures in place.  This detailed analysis of security legislation across the nations shows how each country could benefit from the introduction of Martyn’s Law or some aspects of it to enhance existing measures. As a global community we need to work together to get the best outcome for all nations to keep their citizens safe.”     

The introduction of Martyn’s Law in other countries — such as those previously discussed (France, the United States, Australia, Germany, Canada, Singapore, etc.) — would indeed offer significant benefits, although some already have robust frameworks for counter-terrorism and public safety.     

We have carried out a detailed analysis of whether Martyn’s Law would be relevant, necessary, and beneficial in these nations, and whether their existing legislation is sufficient to mitigate terrorist attacks in crowded spaces and provide an education framework for event organisers.

France – Vigipirate Plan

Relevance of Martyn’s Law: France has been a frequent target of terrorist attacks, particularly in public spaces. The Vigipirate Plan provides a comprehensive approach to preventing such attacks and maintaining vigilance across the country, but Martyn’s Law would enhance this framework by specifically mandating that venue owners and event organisers take direct responsibility for assessing and managing threats. France’s current framework is heavily centralised and led by government directives, whereas Martyn’s Law empowers local authorities and private entities to take more ownership.

Benefit: Introducing Martyn’s Law would further empower venue managers and event organisers to adopt a more structured, legal obligation toward enhancing preparedness for high-risk areas such as tourist attractions and sports venues. It would also embed ongoing public education and training into law.     

Existing legislation sufficiency: While Vigipirate is strong, it could benefit from Martyn’s Law’s focus on decentralising responsibility, providing more targeted, site-specific assessments.

United States – National Infrastructure Protection Plan (NIPP)

Relevance: The U.S. has a broad framework for protecting public spaces and critical infrastructure, but this is often voluntary for private entities and largely focuses on federal or state-led initiatives. Martyn’s Law would be highly relevant as it would mandate venue operators to assess risks and implement Hostile Vehicle Mitigation (HVM) solutions (where necessary) and emergency response planning for Publicly Accessible Locations and crowded places.

Benefit: Introducing Martyn’s Law would provide a more cohesive, national mandate for securing public venues, particularly during large events, and would extend the burden of responsibility beyond federal guidelines to state, and locally owned, operated and organised events. It would offer a standardised framework for assessments and preparedness measures, which could bolster existing practices.

Existing legislation sufficiency: While the NIPP is comprehensive, its voluntary nature means gaps in compliance exist. Martyn’s Law would close these gaps, making security measures mandatory and providing an educational framework to ensure organisers are well-prepared.

Australia – Strategy for Protecting Crowded Places

Relevance: Australia’s strategy is already quite aligned with the principles of Martyn’s Law, with strong government emphasis on protecting crowded places from terrorist attacks. However, Martyn’s Law would be relevant in formalising the legal responsibilities of those in charge of publicly accessible locations and ensuring that regular, mandatory training and risk assessments are conducted.     

Benefit: Martyn’s Law would provide a more formalised structure for venue owners and event organisers to follow, ensuring that threat and vulnerability assessments become standard practice. Additionally, it would establish a clear legal requirement for public education and proactive safety measures, thereby improving accountability.     

Existing legislation sufficiency: Australia has a solid framework, but Martyn’s Law could reinforce it by embedding legal mandates for risk assessment, security training, and public preparedness, rather than relying on voluntary compliance.     

European attacks featured again, before the focus moved eastward to the Middle East, then Pakistan.

Germany – Video Surveillance Improvement Act

Relevance: Germany has focused on enhancing video surveillance and securing public areas, but Martyn’s Law would broaden the scope by requiring venue operators to actively assess and manage threats, beyond just surveillance. Martyn’s Law’s focus on public education and regular drills would be a highly relevant addition to Germany’s existing measures.

Benefit: Implementing Martyn’s Law in Germany would provide a more holistic approach to public safety, moving beyond surveillance to more active threat management and resilience-building strategies. It would also mandate that event organisers undergo training and ensure that emergency planning is embedded in public venues.     

Existing legislation sufficiency: Germany’s current laws are strong but could benefit from the broader preventative measures Martyn’s Law offers. Introducing more proactive, rather than reactive, security strategies would strengthen Germany’s approach to counter-terrorism in public spaces.     

Nick Aldworth, Martyn’s Law campaigner commented: “The UK has led the way in mobilising the public to fight against terrorism for many years.  The creation of the crowded places model in the early 2000’s was the first systemised attempt to align protective security against threat.     

“The world had moved on and the many initiatives that globally reflect what we’ve been doing in the UK for decades can only make it harder for terrorists to operate across, and within, borders.     

“I’m delighted that Martyn’s Law is making progress through Parliament; it still has a long way to go, and we all need to stay focused on the core message of public protection. “

Canada – Critical Infrastructure Protection Act (CIPA)

Relevance: Canada’s CIPA is focused on critical infrastructure but does not explicitly mandate risk assessments or security measures for all publicly accessible locations. Martyn’s Law would be highly relevant here, particularly in ensuring that crowded spaces and venues for public events are safeguarded.     

Benefit: Martyn’s Law would formalise a public safety responsibility framework for venue owners and event organisers, requiring public safety training in high-risk locations. It would ensure consistency across the country in how public spaces are secured.   

Existing legislation sufficiency: While CIPA covers critical infrastructure, it does not mandate the same level of public venue protection that Martyn’s Law would provide. Hence, the addition of Martyn’s Law would fill this gap, especially for event organisers and venue managers.

Singapore – Infrastructure Protection Act (IPA)

Relevance: Singapore’s Infrastructure Protection Act (IPA) already mandates security-by-design for critical infrastructure and crowded places, so Martyn’s Law is less immediately necessary here. However, Martyn’s Law could still bring added value by ensuring regular, comprehensive training for event organisers and venue managers and embedding legal requirements for public education.     

Benefit: While Singapore’s IPA is robust, Martyn’s Law would offer more structured guidance for non-infrastructure-based events, such as public gatherings in parks, festivals, and other open-air venues. Martyn’s Law’s focus on public safety awareness, and education would complement the existing measures.     

Existing legislation sufficiency: Singapore’s legislation is generally sufficient, but Martyn’s Law could enhance public engagement and education efforts and formalise a broader risk management framework for temporary public events.

Conclusion

Martyn’s Law would bring added value in most of the countries discussed by standardising public safety responsibilities, ensuring that risk assessments, public training, and preventive security measures become a legal mandate rather than an optional practice. In places like the United States, France, and Germany, Martyn’s Law could strengthen existing frameworks by ensuring that local authorities, venue owners, and event organisers take more ownership of public safety.