Martyn's Law for sports clubs and leisure centres

Whether a sports venue is covered depends on what kind of premises it is, whether there are checks on entry, and how many people can reasonably be expected at the same time. The 200 threshold includes everyone present: players, spectators, coaches, staff, bar workers and volunteers. Most clubs and leisure centres that are covered will be in the standard tier, from 200 to 799 people. The free checker will confirm where you sit.

Indoor facilities and leisure centres

Sports halls, swimming pools, gyms, climbing walls and leisure centres fall under the "entertainment and leisure" use in Schedule 1 of the Act, which covers entertainment, leisure or recreation activities provided mainly for visiting members of the public. Members and paying customers still count as members of the public for this purpose. A busy leisure centre on a weekend morning, with a swimming lesson programme, a gym and a café, can pass 200 more easily than it might appear.

Open-air pitches and grounds

Sports grounds are a listed use in their own right, but Schedule 2 of the Act excludes open-air parks, recreation grounds, sports grounds that are not designated under the Safety of Sports Grounds Act 1975, and other open-air leisure premises, where there are no measures to check that people entering have paid, hold a ticket or are members or guests. The statutory guidance gives the example of a publicly accessible football ground with no access controls and no spectator stands, which is not in scope.

Two details matter. Checks that apply only to particular events are disregarded if the public can get in freely at other times. And when the guidance discusses entry checks for events, it says a suggested entry charge or donation does not count, and that checks need a well-defined and secure perimeter to be meaningful; the same common sense is a useful guide for a ground. A ground behind locked gates with membership controls is a different matter and may be covered.

Clubhouses, bars and function rooms

Even where the pitch is excluded, your clubhouse is a building. If 200 or more people can reasonably be expected in it at the same time, through a presentation night, a big match screening or regular functions, it can be covered in its own right. Its main use might be food and drink, entertainment or a hall for hire, depending on how it is used.

Large annual events

If your club hosts an event of 800 or more people that recurs each year, the club can become an enhanced tier premises. The Home Office gives the example of a golf club with a usual peak of 300 that holds an annual firework display for 1,200 people, and concludes that the club is enhanced tier. Enhanced duties are outside the scope of this guide and our pack.

The responsible person is whoever has control of the premises for their main use. For a members' club, that is usually the club itself, whether it is an incorporated company, a charity or an unincorporated association acting through its committee. For a school or college sports facility, see the rules for education settings on our Martyn's Law explained page.

For council-owned leisure centres it depends on the arrangement. Where a council runs the centre itself, the council is responsible. Where a leisure trust or operator runs it under a lease or management agreement, the answer turns on who actually has control of the premises. The statutory guidance is clear that a responsible person cannot delegate its legal responsibility to a contracted service provider, so confirm the position in writing between the council and the operator.

Whoever holds the duty should name a lead contact, such as a club secretary, general manager or centre manager, and a deputy. Record this on a responsible person and SIA notification record. If the club hires its hall or clubhouse to other groups, it usually remains the responsible person for the building and should explain its procedures to hirers.

Count your biggest regular occasions, not an ordinary week. A cup final, a swimming gala, a tournament day, a junior festival or an annual presentation night counts because it comes round again. A weekday training session does not set your figure, and nor does a one-off occasion that you do not expect to recur.

For a leisure centre, the fire safety occupancy figure or your booking and turnstile records will usually be the clearest method. For a clubhouse, use the occupancy figure or records of your busiest functions. Write down your figure, the method and your reasoning in a capacity assessment record, because the SIA can ask how you reached it. Our guide on how to work out your capacity explains every method.

The Act requires procedures for evacuation, invacuation, lockdown and communication, so far as reasonably practicable. Sports venues have particular features that should shape each of them.

Evacuation

Wet-side evacuation needs specific thought. People on poolside may be barefoot and in swimwear, in winter, and some will be young children in lessons. Decide which exits poolside staff and lifeguards use, where swimmers go and how you will keep them warm once outside, for example with foil blankets or a nearby building. For any venue, choose an assembly point away from the main entrance and the car park. Set this out in your evacuation procedure.

Invacuation

If the danger is outside, changing rooms are often good invacuation areas: solid walls, few windows and away from the main doors. At an outdoor venue, decide how players and spectators on the pitch will be brought into the clubhouse quickly, through which door, and who closes it behind them. The steps are in the invacuation procedure.

Lockdown

Sports halls are large open spaces with few lockable rooms. Plan for that honestly: identify the store rooms, offices, plant rooms and changing rooms that can be secured, check which lock from the inside, and know who holds the keys. Record this in the lockdown procedure.

Communication

Use the PA in the hall or on poolside where you have one, and decide who operates it. On the pitch side, a whistle and a clear voice may be all you have, so agree the signal in advance and make sure officials, coaches and stewards all know it. Short scripts are in the communication procedure.

When calling 999 and unable to speak, stay on the line, listen to the call handler and press 55 when prompted.

Junior sessions and groups of children

Junior sessions mean adults are responsible for groups of children who may not be with their parents. Build into each procedure that every coach or session leader stays with their group, moves them together and accounts for every child at the assembly point or safe area. Keep session registers where they can be picked up quickly.

Leisure centres have shift patterns and casual staff; clubs rely on volunteers who change through the season. Make a one-page briefing sheet part of induction for staff, lifeguards, coaches and bar volunteers, and keep a briefing and review log. A wall poster on poolside, in the clubhouse and by the reception desk reminds everyone of the three options.

1. 01Work out whether your pitch or ground is excluded and whether your clubhouse or centre is covered.
2. 02Pick your biggest regular occasion and count everyone there, staff and volunteers included.
3. 03Confirm who the responsible person is and who acts for them, including any council or operator arrangement.
4. 04Walk the building with your duty staff, including poolside, and agree exits, invacuation areas and lockable rooms.
5. 05Write down your four procedures and brief staff, coaches and volunteers.
6. 06Add a line to every junior session plan about keeping groups together, and review everything each season.

The law does not require a written document at standard tier, but the statutory guidance says documenting even simple procedures is good practice. With volunteers and coaches changing through the season, a written plan keeps everyone working from the same page. Our Standard Tier Pack prepares all ten documents for your club or centre from £79 a year. See pricing. It is a set of templates to review and adopt, not legal advice.

For the wider picture, read Martyn's Law explained and the full list of covered buildings.