Martyn's Law for pubs with function rooms
Martyn's Law is likely to apply where 200 or more people may reasonably be expected across your premises at the same time — bars, function room, beer garden and staff counted together on your biggest realistic nights. For most pubs the ordinary trade never gets there; the function room, the cup-final screening and the bank-holiday garden are what decide it. Expected in force Spring 2027.
An ordinary weeknight in most pubs is nowhere near the law's threshold. The question Martyn's Law actually asks of you is about three or four nights a year — and whether your function room changes the answer.
The count: the whole premises, on the biggest night
The test is whether 200 or more people may reasonably be expected to be present at the same time, across the premises as a whole — and "premises" means the building together with the grounds used with it. So the count on your busiest realistic occasion is:
- everyone in the bars
- the function room, if it's in use at the same time
- the beer garden — it's part of the premises, not an overflow that doesn't count
- and your own people: bar, kitchen, door, cellar
A pub trading at 90 in the bars, with a 100-cover wedding in the function room and thirty in the garden, is a 220-person premises that evening. Equally, a wet-led local whose record night is 120 souls wall-to-wall is, on any sensible reading, out of scope — and should write that down (see below).
The nights worth counting honestly: New Year's Eve, the big football screenings, the beer festival, the function room's largest regular bookings. The fire-capacity figures on your licence paperwork are a sanity check, not the answer — the legal test is realistic expectation, and our scope checker walks it through in three minutes.
Hirer-led events count too
If the function room is let out, the test doesn't care whose name is on the booking — what matters is what may reasonably be expected at the premises. A room that regularly hosts 150-person parties alongside ordinary bar trade is exactly the pattern that tips a pub over the line. The operator of the premises (typically you, the licensee or operating company, as the person in control) carries the duty — and a short paragraph in your function-room booking terms pointing hirers to your procedures covers the joined-up thinking the law expects. The dynamics are the same as for hired halls; the hirer section of our village halls guide translates directly.
What standard tier asks of a licensed operator
If you're in scope, it's the standard tier (enhanced starts at 800+), and you start further ahead than almost any venue type:
- Notify the SIA — free, online, once the regulator's system opens.
- Four workable procedures — evacuation, invacuation, lockdown, communication. You already run fire procedures, capacity management, an incident-aware door culture and a team trained to clear a building at closing time. The genuinely new thinking is mostly invacuation (bringing the garden and smoking area in, holding people inside rather than spilling them onto the street) and lockdown (which doors secure quickly, moving people from glazed frontages). Full plain-English breakdown in the standard tier guide.
- Staff who know them — including weekend casuals. Five minutes in the shift briefing and an entry in the training record does it; the record is what turns "we told everyone" into something you can show your insurer.
No physical security measures and no purchased products are required. For a trade already living with licensing reviews, EHO visits and fire risk assessments, this is one more thin folder — and the one whose paperwork keeps itself.
If you're under it
Most pubs without a function room will be. Count your two or three biggest realistic nights, everyone included; if you never reasonably approach 200, record the conclusion and the numbers, diarise an annual glance at it, and carry on. If trade changes — you add the marquee, the function room gets popular — the note is your prompt to look again.
Common questions
Does Martyn's Law apply to pubs?
Only where 200 or more people may reasonably be expected across the premises at the same time — bars, function room, beer garden and staff counted together on the biggest realistic nights. Most pubs without a function room fall below that; pubs with busy function rooms or major event nights may not. Count the big occasions, not the average.
Does the beer garden count towards the 200?
Yes — the premises is the building together with the grounds used with it, so the garden and smoking area count alongside the bars and function room. A summer bank holiday with the garden full is exactly the kind of occasion to include in your count.
Our function room is hired out — is that the hirer's problem or ours?
The duty sits with the person in control of the premises — typically the operator, not the hirer. Hirers' events count towards what may reasonably be expected at your premises, and the practical fix is a line in your booking terms pointing hirers to your procedures.
Three minutes, no sign-up: are you in scope?
Our free scope checker walks you through the 200 test properly. And if you'd like one plain-English email a month between now and commencement, join the countdown list.