The two-tier approach

The Act establishes a proportionate, tiered approach. The tier that applies to your premises depends on the number of people it is reasonable to expect may be present at the same time. This includes staff, visitors, customers, pupils — everyone on the premises.

Standard Tier: 200–799 capacity

The standard tier applies to qualifying premises where it is reasonable to expect that between 200 and 799 individuals may be present at the same time.

Requirements:

The standard tier does not require physical security measures, equipment purchases or structural alterations. The focus is on simple, practical procedures and staff readiness.

Examples: primary schools, smaller secondary schools, boutique hotels, mid-sized restaurants, community centres, smaller leisure facilities.

Enhanced Tier: 800+ capacity

The enhanced tier applies to qualifying premises where it is reasonable to expect that 800 or more individuals may be present at the same time.

In addition to all standard tier requirements, enhanced tier premises must:

Examples of enhanced measures might include bag search policies, CCTV monitoring, vehicle access controls, and enhanced staff training. What is appropriate depends on the nature, size and context of each premises.

Examples: large secondary schools and grammar schools, conference hotels, shopping centres, stadiums, large leisure complexes, entertainment venues, major event spaces.

How capacity is calculated

The threshold is based on the number of individuals it is reasonable to expect may be present at the same time from time to time. This does not mean the absolute maximum capacity — it means a realistic assessment of how many people are typically present during busy periods.

For a school, this includes all pupils, teaching staff, support staff, and any visitors or parents typically on site. For a hotel, it includes guests, staff, restaurant diners, conference delegates and visitors.

If you are unsure whether your premises meet the 200 or 800 threshold, a structured assessment is the right starting point.

What ‘reasonably practicable’ means

Both tiers are subject to the concept of reasonably practicable. This is a well-established legal concept also used in health and safety and fire safety legislation. It means you must do what a reasonable person in your position would do, taking into account the nature of the premises, the level of risk, the resources available and the cost of any measures.

A 250-capacity community centre is not expected to implement the same measures as a 5,000-seat arena. The Act is designed to be proportionate.

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