Policy paper

Terrorism (Protection of Premises) Act 2025: Responsible person factsheet

Updated 24 July 2026

This factsheet explains who is responsible for certain premises and events under the Terrorism (Protection of Premises) Act 2025^{[footnote 1]}, hereafter referred to as the “responsible person”, and their role. The responsible person may not be a named individual or single person. It is most likely to be a company or an organisation.

The responsible person for qualifying premises ​

For qualifying premises, the responsible person is the individual, company or organisation with control of the premises for the purpose of their relevant Schedule 1 use (e.g. the use of a venue as a sports ground or a hotel). ​The responsible person will usually be the premises operator (e.g. if a person leases a building for retail use as a shop and is in control of the building for that use, they will be the responsible person).

Where premises have two or more Schedule 1 uses, the responsible person will be the individual, organisation or company with control of the premises in connection with the principal use of the premises.

Further information on which premises are in scope of the Act can be found in the scope (premises) factsheet and chapter 6 of the statutory guidance.

The responsible person for qualifying events

For qualifying events, the responsible person is the individual, organisation or company which has control of the premises in connection with their use for the event. The responsible person can be different to the individual, organisation or company which has control of the premises outside of their use for the event.

For example, a concert, which meets the criteria to be a qualifying event under the Act, is being held in a park. The park is owned by a local authority. The company putting on the event takes control of an area of the park for the purposes of holding the concert. The company has a contractual agreement with the local authority (for example, a contract to rent or hire the site) giving over control of that area for the purposes of delivering the concert. This means the company putting on the event, not the local authority, is the responsible person for the event.

However, if the local authority were to remain in control of the area of the park in which the concert takes place, the local authority would be the responsible person. This would be the case even if the local authority contracted organisations to deliver aspects of the event, for example, to provide stewarding and security or to sell and check tickets.

The responsible person cannot delegate their legal responsibility to a contracted service provider but may delegate tasks. For example, delegating organisation of the event to a provider.

Further information on which events are in scope of the Act can be found in the scope (events) factsheet and chapter 5 of the statutory guidance.

Requirements

The responsible person must ensure that the requirements of the Act are met. They cannot delegate their legal responsibility even if they delegate some tasks or hire out their venue (but retain relevant control).

Further information on the requirements for standard tier premises can be found in the standard tier requirements factsheet and chapter 7 of the statutory guidance. Information on requirements for enhanced tier premises and qualifying events can be found in the enhanced tier requirements factsheet and chapter 8 of the statutory guidance. Qualifying events are treated in line with the enhanced tier; there is no standard tier for qualifying events.

Where the responsible person for enhanced tier premises or qualifying events is an organisation or company, rather than a named individual or single person, the Act requires that the responsible person must designate a senior individual to ensure that the responsible person complies with the Act’s requirements.

Co-ordination

Those responsible for standard or enhanced tier premises or qualifying events must co-ordinate with each other, so far as is reasonably practicable, under specific circumstances:

• where more than one individual, organisation or company is responsible for qualifying premises or an event; and

• where qualifying premises form part of other qualifying premises.

For example, the responsible person of a department store reasonably expects 800 or more individuals to be on the premises from time to time, at the same time (including staff). Therefore, the department store is in the enhanced tier. The department store is located within a shopping centre, which is also enhanced tier premises. The responsible persons of both premises must co-ordinate with each other in complying with the requirements of the Act, so far as is reasonably practicable. The responsible persons co-ordinate to deconflict their evacuation plans and complement each other’s lockdown and communication plans.

The co-ordination requirements only apply to premises and events that fall within scope of the Act. Further details can be found in chapter 6 of the statutory guidance.

Co-operation

There may be instances where, to comply with requirements of the Act, the responsible person for enhanced tier premises or a qualifying event requires permission, support or other co-operative steps from another individual, organisation or company with control of the premises or event to any other extent but who is not the responsible person.

For example, a building owner who has leased the premises to a separate operator, premises within other premises, or a landowner who has given permission for a qualifying event to take place on their land. The building owner or landowner in these examples must, so far as is reasonably practicable, co-operate with the person responsible for the premises or event for the purposes of ensuring the responsible person’s compliance with the requirements of the Act.

The co-operation requirement will help to remove potential obstacles to the responsible person implementing appropriate measures. For example:

1. Where the responsible person has identified that implementing appropriate public protection measures would require structural changes to the building (e.g. to put in or move a door) but their lease prevents such a change, the co-operation requirement will require the freeholder to consider this request and cooperate so far as is reasonably practicable. (This does not mean that a freeholder must automatically consent to all such requests. Instead, they must co-operate so far is as is reasonably practicable).

2. Where the responsible person has identified the need to implement certain measures to meet their legal obligations under the Act and one of the measures requires freeholder permission. The responsible person’s lease also states that the freeholder should contribute a certain percentage of costs to ensure the premises remain fit for purpose. The freeholder is obliged to consider such requests to a reasonably practicable level.

The co-operation requirement requires co-operation so far as is reasonably practicable. An assessment of all relevant factors, including contracts and leases, will be necessary. If there is a dispute, the tribunal may be asked to determine whether a person is a responsible person or whether a person is required to co-operate with a responsible person.

1. The Act was granted Royal Assent on 3 April 2025, but these requirements have not yet been commenced. This means that they are not yet in force and so do not need to be complied with until brought into force by regulations. ↩