Martyn's Law in a multi-academy trust: who's responsible, and how to run it across every school

Most Martyn's Law guidance is written with a single site in mind. A trust has one board and several schools, each with its own buildings, people and routines. So the questions change: who carries legal responsibility, does every school need its own procedures, and how does the board know each site is ready?

This is what the Act and the Home Office guidance actually say, and a practical way to run it across a trust without flattening what makes each school different.

Where things stand

• The Terrorism (Protection of Premises) Act 2025 received Royal Assent on 3 April 2025. Its main duties aren't in force yet. The SIA expects them to start in spring 2027, but no date has been set.
• A school is in scope if it's reasonable to expect that, from time to time, 200 or more people will be on site at the same time. Staff count towards that number.
• Schools in scope are always standard tier, however large they are.
• Each school in scope must be notified to the Security Industry Authority (SIA) within three months of the notification duty starting.

Who is the responsible person?

The Act gives the duty to whoever controls the premises for their school use. For schools, it names "the governing body or, where there is no governing body, the proprietor".

For an academy, the proprietor is the academy trust. In most multi-academy trusts, local governing bodies are committees of the trust board rather than separate legal bodies. So in most trusts, the trust will be the responsible person for every one of its schools in scope. It's worth checking this against your articles of association and scheme of delegation.

The Home Office guidance anticipates this, describing one responsible person covering several premises, such as "a governing body for an educational or medical trust".

It's often said that the headteacher is the responsible person. Heads will usually lead much of the work on their site, but the legal responsibility sits with the trust.

What the trust can hand to schools, and what it can't

The guidance is clear that the responsible person can delegate tasks, but not legal responsibility. A headteacher or site manager can even submit a school's notification, as long as they're authorised to, and the government's notification guidance recommends keeping a written record of who is.

That points to a natural split:

• The trust sets the standard, approves each school's procedures, keeps the record and reports to the board.
• Each school knows its site, adapts the procedures to it, makes sure staff know their role and practises.

One standard, not one size

The Act's duties attach to each premises. Where one responsible person has several sites, the guidance asks them to consider each one, "avoiding a one-size-fits-all approach". Its example of a supermarket chain makes the same point: each store is "premises in their own right with their own unique circumstances".

That's the balance a trust has to strike: a consistent response across every school, with procedures that genuinely fit each building. A model that works well is a trust standard with a short annex for each school.

The four procedures

At standard tier, the responsible person must make sure, so far as is reasonably practicable, that appropriate procedures are in place for people working on site to follow if a terrorist attack is suspected:

• Evacuation: getting people out of the building.
• Invacuation: moving people to a safer place on site.
• Lockdown: stopping people entering or leaving.
• Communication: giving information to people on site.

"Reasonably practicable" means weighing what each procedure achieves against its cost, time and difficulty. Where a school decides something isn't reasonably practicable, the guidance suggests it can help to record why. Our explainer on lockdown, invacuation and evacuation covers what each one means in a school.

Written down, trained and practised?

This is often overstated, so it's worth being precise.

• Writing procedures down isn't a legal requirement at standard tier. The guidance says the responsible person should still do it, because without a written record it's hard to show the SIA what's in place. For a trust, it's also the only practical way to give the board a clear picture across every school.
• Training isn't legally required in any specific form, but staff need to know the procedures and their own role in them.
• Drills aren't a legal requirement either. The guidance asks responsible persons to consider how procedures will be tested and practised, and suggests reviewing them, for example annually. The DfE's school security guidance adds that practice drills show where improvements can be made.

Across a trust, a shared record of each school's practice is the simplest way to see where you're strong and where a school needs support.

Notifying the SIA

Each school is notified separately. The details required include the responsible person, the site's address or addresses, how the premises are used, the expected peak number of people and how it was worked out, and whether the responsible person also covers other premises. There's no fee. If a school joins the trust later, the trust has 28 days from becoming responsible for it.

Notification isn't open yet. The SIA is preparing guidance on how notification will work, and an online tool to check scope is due in the new year.

Worth doing now: a single list of every school site, its expected peak number, how you counted it (the Home Office suggests several methods, including your fire safe-occupancy figure, as long as you can evidence it) and who is authorised to submit.

When something happens at one school

In a trust, communication runs two ways. The school needs to reach every member of staff on site with a clear instruction. The trust needs to know quickly, so central teams can support the school, handle parents and the media, and alert neighbouring schools if needed. It's worth agreeing who at the trust is told, how, and how fast, and then testing it.

A framework you can use

Our free trust-wide Martyn's Law procedures framework is a Word template with a trust standard for the four procedures, a one-page annex for each school, a tracker for notifications and practice, and a board sign-off page.

Download the trust framework

How teamSOS helps trusts

teamSOS Lockdown gives trusts one consistent emergency response across every school:

• Pre-set emergency messages deployed to every school, with room for each school to add its own.
• A lockdown started in one press and a quick confirm, reaching every member of staff at once.
• Drills and real incidents recorded automatically, so the trust can see and show practice across all its sites.
• The trust alerted the moment one of its schools has an emergency.

It rolls out across a trust with no extra hardware. It supports your procedures rather than replacing them. See teamSOS for academy trusts.

Sources: Terrorism (Protection of Premises) Act 2025, section 4 and Schedule 1; statutory guidance (Home Office, April 2026, corrected August 2026); notification requirement (Home Office, July 2026); ProtectUK: responsible person; the SIA on its role as regulator (July 2026); Martyn's Law: scope, support and what's next (SIA, September 2026); School and college security (DfE, updated July 2026).