Martyn's Law for Hotels: What Accommodation Providers Need to Know

How Hotels Fall Within Scope

Hotels are explicitly within the scope of Martyn's Law. Whether your property falls into the standard or enhanced tier depends on your maximum capacity, which includes guest rooms, public areas (lobbies, bars, restaurants, conference facilities), and staff. A 120-room hotel with a restaurant, bar, and conference suite could easily have a combined capacity exceeding 200 people, putting it squarely in scope.

Larger hotels and resorts with capacity exceeding 800 will fall into the enhanced tier, carrying additional obligations around risk assessment, security planning, and active monitoring measures.

Calculating Your Capacity

Hotel capacity is not just about bedrooms. You need to count the maximum number of people who could be on the premises at any one time across all areas. This includes:

• Guest rooms (based on maximum occupancy per room)
• Reception and lobby areas
• Bars, restaurants, and breakfast rooms
• Conference and meeting rooms
• Spa, gym, and leisure facilities
• Staff on shift at peak times
• Visitors who are not staying overnight

Add these figures together for your peak scenario. That is your capacity for the purposes of the Act.

Public Areas Are the Focus

Hotels present a particular challenge because they have extensive public areas that anyone can walk into. A hotel lobby is essentially an open-access space. So are hotel bars and restaurants that serve non-guests. Conference facilities often welcome hundreds of external attendees who have no relationship with the hotel beyond a day pass.

Your compliance procedures should focus on these public-facing areas. Individual guest rooms, while part of the capacity calculation, are lower-risk zones with natural access control (key cards). The lobby, car park, loading bay, and conference wing are where your attention should be directed.

Multi-Site Hotel Groups

If you operate multiple hotels, each property needs to be assessed individually. A hotel chain with 30 properties might have some in the enhanced tier, some in the standard tier, and some below the 200 threshold entirely. Compliance responsibilities sit with the responsible person for each premises, though corporate groups can create standardised procedures and training programmes that are then adapted for each property.

This is an area where centralised technology makes a real difference. An AI behaviour detection platform deployed across multiple properties allows a single security team to monitor all sites from one location, with each property's system configured for its specific layout and risk profile.

Balancing Security and Guest Experience

Hotels operate in a competitive market where guest experience matters. Nobody wants to feel like they are checking into a fortress. The good news is that Martyn's Law does not require visible, intrusive security measures for most hotels. Standard tier compliance is about procedures and awareness, not metal detectors and bag searches.

Even for enhanced tier hotels, the measures should be proportionate. Well-trained reception staff who know how to spot suspicious behaviour, monitored CCTV in public areas, clear evacuation procedures, and an incident response plan are all measures that operate behind the scenes without affecting the guest experience.

Practical Steps for Hotels

1. Calculate your true capacity across all areas and determine your tier.
2. Designate a responsible person. In a managed hotel, this is typically the general manager. In a franchised property, clarify whether responsibility sits with the franchisee or the management company.
3. Review existing emergency procedures. Most hotels already have fire evacuation plans. Extend these to cover invacuation, lockdown, and terrorism scenarios.
4. Train reception and front-of-house staff in recognising suspicious behaviour and hostile reconnaissance indicators.
5. Audit your CCTV. Is it working? Does it cover public areas adequately? Is anyone monitoring it, or is it just recording to a hard drive that nobody checks?
6. Consider AI monitoring for your existing cameras. It turns passive recording into active surveillance without hiring additional security staff.
7. Document everything. Write your procedures down. Record your training. Log any incidents. Keep records ready for SIA inspection.

Where AI Behaviour Detection Helps

Hotels have cameras everywhere, but rarely enough people to watch them. AI behaviour detection changes this by monitoring every feed continuously. It can detect aggressive behaviour in a lobby, unusual loitering near fire exits, unattended items in conference areas, and crowd density building in ways that suggest a problem. For hotel groups, the technology scales across properties while the monitoring team does not need to scale at the same rate.