You sent them the guidance. Who acted on it?
Most brokers with hospitality or leisure clients have already emailed them about Martyn's Law. Very few can say what happened next. From spring 2027, that matters.
Why this lands on brokers
Terrorism risk at publicly accessible premises used to be an insurance question, dealt with in the policy wording. The Terrorism (Protection of Premises) Act 2025 makes it a governance question, dealt with by evidence. The trade press has spent 2026 pointing out that broker advice on it now sits inside the liability frame.
That puts brokers in an awkward spot. Say nothing and you look absent on a risk your client is now legally responsible for. Say something specific and you've given advice you could be held to. Sending the ProtectUK link is the safe middle, and everyone's already done it.
Fund the record keeping instead of giving advice. Your policyholders get a tool that holds their procedures, training and drill logs. You get an aggregate picture of preparedness across the funded book. Nobody gets told their procedures are adequate, because Musterlog never makes that call.
How it works
We've kept the commercial side simple so it gets through a compliance review.
- You license it for part of the book. You choose the segment. It's priced on the number of policyholder premises covered, and you pay annually.
- Policyholders are invited in and pay nothing. They see it as something their broker arranged, not something they've been sold, which is why take-up is good.
- They keep their own records. Procedures, ACT Awareness completions, drill and review logs, and an export they can hand to an inspector.
- You see the aggregate. How much of the funded book has procedures in place, how far training has got, and where nothing's happened since sign-up.
What you can see
The portfolio view is narrow on purpose. It covers what an underwriter or account executive would ask at renewal, and no more.
| You can see | You can't see |
|---|---|
| Share of funded premises with documented procedures | The content of any policyholder's procedures |
| Training completion rates across the book | Named individual staff records |
| When each site last logged a drill or review | Any assessment of whether what they did was adequate |
| Which sign-ups have never been opened | Anything at all from premises you don't fund |
Policyholders are told at sign-up exactly what the funder can see. Nothing is shared without them knowing.
It's a licence fee, not commission. No share of premium changes hands, nothing depends on a policy being written or renewed, and Musterlog plays no part in arranging, advising on or concluding any contract of insurance. Commission linked to policies written or renewed could bring an arrangement like this within insurance distribution, which needs FCA authorisation or appointed representative status. That's why we've set it up as a flat fee.
What it doesn't do
- It doesn't make any policyholder compliant. No supplier can. Your client is still the responsible person under the Act.
- It isn't endorsed by the Home Office or the SIA. No product has that endorsement.
- It doesn't assess premises, rate risk or drive an underwriting decision on its own.
- It issues no certificate, because Martyn's Law doesn't have one.
What it costs
Insurer and broker licences are priced by arrangement, on the number of policyholder premises covered rather than the size of the book. A pilot across a few hundred premises is a different conversation from a scheme covering several thousand, and we're happy to have either.
For comparison, operator pricing on the main page runs from £2,400 a year for a small group to £18,000 for a large operator. Funded book pricing comes in below the equivalent per-premises rate, because you're saving us the cost of selling to those premises one at a time.
Questions brokers ask
Does this make us look like we're advising on their security?
No, though the wording matters. You're funding a record keeping tool, the same way many brokers already fund risk management portals, health and safety templates or driver training. Musterlog holds what your client did. It never tells them whether it was enough.
What if a funded policyholder is prosecuted anyway?
Then there's a record, which helps everyone. Musterlog doesn't claim to prevent enforcement action. It means your client can show what was in place and when, instead of piecing it together afterwards.
Can we white label it?
Co-branding on the policyholder side is fine, and we'd expect it. Full white labelling isn't, because a policyholder should be able to see who holds their data and on what terms.
Our clients are mostly single-site. Is this still worth it?
For each policyholder on their own, sometimes not, and we'll tell you that. The free ProtectUK templates are good. The value to you is the aggregate: one funded scheme gives you a picture of preparedness across hundreds of premises that would otherwise take a survey.
Who holds the data?
Musterlog, as processor for the policyholder. The policyholder is the controller of their own records. The funder gets aggregate figures only, on terms the policyholder sees before they start. Musterlog Ltd is in formation and its Information Commissioner's Office registration will be in place before any policyholder data is held.
We're taking three pilot groups by 30 October 2026, free until April 2027, and at least one place is kept for an insurer or broker. The list closes then because November is when the build is briefed, and the pilots are what shape it. A pilot is a one-paragraph letter of intent, not a contract, so either side can walk away.
This page describes a commercial model, not regulatory advice. Whether a particular arrangement falls inside insurance distribution is a question for your own compliance team and the FCA Handbook. Put it to them in writing before you sign anything.
Primary sources: the Terrorism (Protection of Premises) Act 2025, the Home Office statutory guidance published April 2026, and ProtectUK, which is run by the Home Office, NaCTSO and Counter Terrorism Policing and is free to use.
Written by Abdul Khalique, who builds Musterlog. If you want to see the numbers behind a funded book, the estate view on the home page models it for a single operator, and it scales the same way.