Does it apply to your shop?
The Act covers premises that consist of a building, or a building and other land, wholly or mainly used for a Schedule 1 use, where it is reasonable to expect that from time to time 200 or more people may be present at the same time (s.2(2)).
Shops are covered by use for "the retail sale of goods", "the display of goods for sale" or "the provision of a service", where the sale, display or service is principally to visiting members of the public (Sch 1 para 1). That takes in department stores, supermarkets, DIY and furniture stores, farm shops and garden centres. A warehouse or trade counter that mainly serves businesses rather than the public may not be covered; record your reasoning.
Count everyone who might be on the premises at the busiest regular time, including staff: the Christmas run-up, Black Friday, a bank holiday weekend, the spring rush at a garden centre, a Santa's grotto or a late-night shopping event.
- 200–799 people: Standard Tier.
- 800 or more: Enhanced Tier (s.2(3)). Large supermarkets, retail warehouses and destination garden centres may be here. Enhanced Tier brings extra duties, so take professional advice and read the SIA and ProtectUK guidance. This guide covers Standard Tier.
Check your shop in two minutes with our free scope checker.
Garden centres, outdoor areas and cafés
Outdoor sales areas. The Act counts "a building and other land" as premises (s.2(2)), so for many garden centres the plant area and yard are likely to be part of the premises and the people in them part of the count. Where exactly the boundary falls (car park, a separate outdoor market) is less clear; write down what you included and why.
Cafés, restaurants and concessions. A café or restaurant is a separate Schedule 1 use (food and drink, Sch 1 para 2). Where one set of premises has more than one use, the Home Office principal use guidance explains how to decide which one counts, looking at things like what the premises were built for and how much space and time each use takes. For most garden centres and stores with a café, retail is likely to be the main use, but the guidance says its examples "are not instructions", so check it against your own site.
Units in shopping centres and retail parks
The principal use guidance says a unit in a shopping centre is its own premises. Where qualifying premises sit inside other qualifying premises, the Act applies to each of them, unless the same person is responsible for both, in which case they are treated as one (s.2(5)). So a large store in a centre may have its own duty, and the centre may have another. Talk to centre management and agree how your procedures fit together.
Who is responsible?
Whoever has control of the premises in connection with that use (s.4(1)). For a chain that is usually the retailer, not each store manager personally. For an independent shop or family-run garden centre it is the owner or operator. If control is shared, for example with a landlord, each may be responsible and can act jointly (s.4(4)).
What you have to do (Standard Tier)
So far as is reasonably practicable, have appropriate procedures for evacuation, invacuation (moving people to a safer place inside), lockdown and communication if there is reason to suspect an act of terrorism is happening or about to happen on the premises or nearby (s.5). Make sure the people who would carry them out are informed and, where appropriate, trained, and notify the SIA within three months of the duties starting, using its free service (Notification Requirements Regulations 2026). The notification asks for the most people you expect at once and how you worked that out, so keep a note of your counting. No physical alterations are required at Standard Tier.
What the four procedures might look like in a shop
Examples to help you think, not legal requirements:
- Evacuation: your fire evacuation is the base, but plan for leaving by exits away from the main entrance or car park if that's where the threat is, including through the warehouse or goods-in door.
- Invacuation: stockrooms, staff rooms or a back office that can be closed off, and roughly how many people each holds. At a garden centre, think about how you'd bring people in from the outdoor area.
- Lockdown: who closes the main doors, any entrance from a mall, the garden centre gates and the goods-in shutter, and how tills and the café are secured.
- Communication: a short PA announcement or code word staff will recognise, radios or a group message for the shift, and who calls 999. If you're in a centre, agree how you'd hear from and tell centre security.
Briefing staff
Retail teams change often and grow at Christmas. Add a two-minute briefing to induction and shift huddles, make sure every shift leader knows how to make an announcement and close the doors, and keep a simple record of who has had it, including seasonal staff.
Checklist
- Check whether your shop is in scope and which tier, and keep a dated note of your reasoning (including outdoor areas and any café)
- Agree who is responsible: retailer, landlord, centre management, or more than one
- Write short procedures for the four areas
- Make sure every shift leader can make an announcement and close the doors
- Brief permanent and seasonal staff, and record it
- Practise before your busiest season and note what you'd change
- Write down how you worked out your maximum number of people (for example peak footfall counts or till data, plus staff)
- Notify the SIA within three months of the duties starting (it is free)
- Review once a year, or when the layout or opening hours change