Enforcement expected spring 2027
For insurers and brokers

You sent them the guidance. Who actually acted on it?

Most brokers with hospitality or leisure on the book have already emailed clients about Martyn's Law. Almost none of them can tell you what happened next, and from spring 2027 that gap stops being an administrative detail.

A row of British high street shops, pubs and restaurants seen from above on an overcast day.
A book of policyholders is a lot of premises that somebody else is responsible for, and that you carry the consequences of.

Why this is landing on brokers

Terrorism risk at publicly accessible premises used to be an insurance question, answered with a policy wording. The Terrorism (Protection of Premises) Act 2025 turns it into a governance question, answered with evidence, and the trade press has spent 2026 pointing out that broker advice on it now sits inside the liability frame rather than beside it.

That leaves a broker in an awkward position. Say nothing and you look absent on a risk your client has just been made legally responsible for. Say something specific and you have given advice you may be held to. Sending the ProtectUK link is the safe middle, and everybody has already done it.

The proposition

Fund the record keeping instead of the 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 has to be told their procedures are adequate, because Musterlog never makes that judgement.

How it works

The commercial shape is deliberately dull, because dull is what survives a compliance review.

  • You licence it for a defined slice of the book. A segment you choose, priced on the number of policyholder premises covered, paid annually by you.
  • Policyholders are invited in and pay nothing. They see it as something their broker arranged, not as a product they have been sold. That is the whole reason take-up is any 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 has moved since sign-up.

What you can actually see

The portfolio view is deliberately narrow. It answers the questions an underwriter or an account executive would ask at renewal, and nothing beyond them.

You can seeYou cannot see
Share of funded premises with documented proceduresThe content of any policyholder's procedures
Training completion rates across the bookNamed individual staff records
When each site last logged a drill or reviewAny assessment of whether what they did was adequate
Which sign-ups have never been openedAnything at all from premises you do not fund

Policyholders are told at sign-up exactly what the funder can see. Nothing is shared quietly, because a broker who is found to have been passing client data around has a much larger problem than Martyn's Law.

The part your compliance team will ask about

This is a licence fee, not commission. No share of premium changes hands, nothing is contingent on a policy being written or renewed, and Musterlog plays no part in arranging, advising on or concluding any contract of insurance. Taking a commission on software sold to policyholders would be insurance distribution and would need FCA authorisation or appointed representative status. That is precisely why the model is built the other way round.

What it does not do

Worth stating plainly, because the wrong claim here would create the exposure it is supposed to remove.

  • It does not make any policyholder compliant, and no supplier can. The responsible person under the Act is still your client.
  • It is not endorsed by the Home Office or the SIA. No such endorsement exists for any product.
  • It does not assess premises, rate risk or feed an underwriting decision on its own.
  • It issues no certificate, because Martyn's Law has no certificate to issue.

What it costs

Insurer and broker licences are priced by arrangement, on the number of policyholder premises covered rather than on the size of the book. A pilot across a few hundred premises is a different conversation from a scheme covering several thousand, and both are worth having.

For context, the 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 sits below the equivalent per-premises rate, because you are removing the sales cost of reaching those premises one at a time.

Questions brokers ask

Does this make us look like we are advising on their security?

No, and the wording matters. You are funding a record keeping tool, in 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 the record exists, which is better for everyone than the alternative. Musterlog does not claim to prevent enforcement action. It means your client can show what was in place and when, rather than reconstructing it after the fact.

Can we white label it?

Co-branding on the policyholder-facing side is straightforward and expected. Full white labelling is not, 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 the policyholder individually, sometimes not, and we would say so. The free ProtectUK templates are genuinely good. The value to you is the aggregate: one funded scheme gives you a preparedness picture across hundreds of premises that would otherwise take a survey to assemble.

Who holds the data?

Musterlog Ltd, as processor for the policyholder. The policyholder is the controller of their own records. The funder receives 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.

Pilot

Three pilot groups are being taken before November, free of charge until April 2027, and at least one of those places is held for an insurer or broker. A pilot is a one-paragraph letter of intent rather than a contract, so either side can walk away.

abu@musterlog.co.uk

This page describes a commercial model, not regulatory advice. Whether a particular arrangement falls inside insurance distribution is a question for your own compliance function and the FCA Handbook, and it is worth putting 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 arithmetic behind a funded book, the estate view on the home page models it for a single operator and the same shape scales.