Martyn's Law and NHS estates . What Chairs and DoFs need to answer
White paper 2 of 5 . For NHS Chairs, DoFs and Estates Directors
Executive summary
Martyn's Law received Royal Assent on 3 April 2025 and statutory guidance for responsible persons followed in April 2026. The Act comes into force in April 2027, so the two-year clock is now running. Hospitals are in scope by name and enhanced-tier duties apply where reasonably expected occupancy is eight hundred or more, which captures almost every acute trust site. The paper sets out what a trust needs in place by April 2027, why the compliance burden lands unevenly across estates and soft-FM and how a governed partner converts the Act from a compliance line into a governance advantage.
The Act is a governance instrument, not a security procurement. The board is on the hook, not the estates team.
What is inside
- What the Act actually requires
- Why the compliance burden lands on soft-FM
- Where trusts are already exposed
- What a governed soft-FM partner brings
- Case reference. CS-041 first-outsourcing readiness
- What a board needs to answer by December 2026
Full paper
Key numbers
- 3 Apr 2025
- Royal Assent
- Apr 2026
- Statutory guidance published
- Apr 2027
- Expected commencement
- 800+
- Enhanced-tier occupancy threshold
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Part of the Governed First-Outsourcing knowledge bank. Verified 30 August 2026.