What Martyn's Law obligations do financial services firms have?

Financial services firms are caught by Martyn's Law (the Terrorism (Protection of Premises) Act 2025) where their premises are publicly accessible at the qualifying capacity threshold. HQ buildings of large FS firms in Canary Wharf and the City often hit the enhanced tier (800+ capacity) due to combined office headcount, visitor density and on-site event spaces. Trading floors typically aren't separately classified as publicly accessible, but visitor reception, client floors, conference centres and ground-floor event spaces almost always are.

Tier assessment is the first question, not the last. A 40-storey Tier-1 bank tower in Canary Wharf might present as one premises (enhanced tier across the whole building) or as a series of qualifying spaces (reception in standard tier, conference centre in enhanced tier, executive client floor in enhanced tier). The classification depends on how access is managed, how the floors are operationally separated and whether the landlord or tenant holds the responsible-person duty. Coordination duty for landlord-managed buildings is a defining feature in this sector. Most major Canary Wharf and City towers are multi-tenant, landlord-managed buildings where the landlord (Canary Wharf Group, British Land, Land Securities, Brookfield) typically holds the responsible-person duty for shared zones (reception, lobby, ground floor, public areas) and individual FS tenants hold duty for their own demised floors. Coordination is mandatory; the tenant cannot rely on landlord measures alone, and the landlord cannot ignore tenant-side risk.

Branch networks in retail banking typically sit below the 200-capacity standard tier threshold and are often exempt, with a handful of flagship locations (Bank, Canary Wharf, Manchester, Edinburgh) potentially hitting standard tier. Asset manager and hedge fund offices below 200 staff are usually exempt from the headcount-based threshold but may still be caught if they host regular client events on-site.

The FCA SYSC operational resilience overlay matters. Regulated firms have already mapped their Important Business Services (IBS) under SYSC 15A, identified critical premises, and set impact tolerances. Martyn's Law compliance work overlaps with that mapping: the premises identified as IBS-critical under SYSC are typically the same premises caught by Martyn's Law, and the public protection procedures required under Martyn's Law (evacuation, invacuation, lockdown, communications) need to be consistent with the firm's existing operational resilience playbook. Practically: get a proper tier assessment before scoping any remediation, and run the gap analysis against existing SYSC mapping. The financial services AV brief often already includes the public address, mass communications and signage layer that Martyn's Law expects, so the marginal cost of compliance can be lower than firms expect.

Quick reference: HQs in City and Canary Wharf typically enhanced tier (800+ capacity), trading floors not separately public but reception / client floors / event spaces are; multi-tenant landlord-managed buildings have coordination duty between landlord and tenant; branches usually below standard tier or exempt; tier assessment first, then gap analysis against existing FCA SYSC operational resilience mapping.