Residential PEEPs: Understanding the Fire Safety Regulations

The fire safety landscape for residential buildings in England is undergoing significant change, with new legal duties soon to be placed on building owners and managers. The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 (SI 2025/797) (the Regulations) – coming into force on 6 April 2026 – introduce the first statutory framework requiring responsible persons to identify vulnerable residents who may need support to evacuate during a fire and to take proportionate steps to assess and mitigate the risks they face.

This article summarises the new regime and what it will mean in practice for residents, owners and managers of residential high-rise and higher-risk buildings. As the implementation date approaches, understanding these obligations and preparing for them will be critical.

Purpose

The Regulations aim to improve the fire safety and evacuation of residents who have difficulties evacuating a building by themselves in the event of a fire (relevant residents). The Regulations apply to residential buildings which are over 18 metres in height, or have at least seven storeys. They also apply to residential buildings over 11 metres in height which have a simultaneous fire evacuation strategy, i.e. that all persons must leave the building immediately in the event of a fire. 

The Regulations require that the responsible person in relation to a relevant building, as defined in the Regulatory Reform Order (Fire Safety) 2005 (the Fire Safety Order) and which is typically the building owner or manager (RP), uses reasonable endeavours to identify relevant residents. Once identified, relevant residents are entitled to:

1. A person-centred fire risk assessment to consider their specific individual risks and ability to evacuate in the event of a fire;
2. The measures that could be reasonably and proportionately introduced to mitigate against their risks;
3. A written statement recording what they should do in a fire; and
4. Information shared with their local Fire and Rescue Service so they know where the most vulnerable residents live and can support their evacuation or rescue in the event of a fire.

Background

The Phase 1 Report of the Grenfell Tower Inquiry, published on 30 October 2019, recommended that owners and managers of all high-rise residential buildings be legally required to prepare personal emergency evacuation plans (PEEPs) for residents who may struggle to self-evacuate, such as those with reduced mobility or cognitive impairments.

The Government initially consulted on PEEPs proposals in the 2020 Fire Safety Consultation, followed by a dedicated PEEPs consultation in 2021. The latter consultation highlighted significant practical, proportionality and safety concerns around mandating PEEPs in higher-risk buildings, and the Government ultimately decided not to proceed with a mandatory PEEP requirement at that time.

Since then, wider fire safety reforms have progressed through the Fire Safety (England) Regulations 2022 and the Building Safety Act 2022. In light of ongoing stakeholder engagement and further research, the Government developed a revised approach through the 2022 Emergency Evacuation Information Sharing Plus (EEIS+) consultation. This focussed on requiring RPs to identify mobility-impaired residents, offer person-centred fire risk assessments, and share relevant information with fire and rescue services.

The Regulations were laid before Parliament on 4 July 2025 under Article 24 of the Fire Safety Order and will come into force on 6 April 2026.

Overview

Enforcing authorities under the Fire Safety Order, such as fire and rescue authorities, have the power to enforce RPs’ compliance with their duties, such as RPs’ duty to follow the residential PEEPs process.

• Regulations 1-4 make provision relating to the coming into force date, territorial extent and application, and scope of the Regulations. They provide definitions of key terms used in the Regulations, detail the buildings that are within scope of the Regulations and define who a relevant resident is for the purposes of the Regulations.
• Regulation 5 makes it a legal requirement from 6 April 2026 for the RP to use reasonable endeavours to identify their relevant residents. It is worth noting that this regulation does not constrain RPs to specific ways of identifying relevant residents, so RPs do not need to change any existing processes unnecessary as long as these meet the requirements of the policy. The Responsible Persons toolkit outlines practical examples as to how RPs can achieve this in practice by adopting similar measures where appropriate.
• Regulation 6 provides that the RP must offer a person-centred fire risk assessment to each relevant resident they identify and, where the resident requests one, ensure the person-centred fire risk assessment is undertaken. The person-centred fire risk assessment must include: an assessment of the risks relating to the relevant resident and the premises, in light of that resident’s cognitive or physical impairment or condition, and consideration of the resident’s ability to evacuate the building (without assistance) in the event of a fire. Accordingly, whilst the scope of the Fire Safety Order is limited only to the common parts of building, the implication of Regulation 6 is to consider private dwellings as well.
• Regulation 7 provides that the RP must then discuss with the resident, with a view to identifying reasonable and proportionate measures for the RP to take to mitigate the risks identified through the person-centred fire risk assessment.
• Regulation 8 outlines the responsibility of the RP to ensure that an emergency evacuation statement is written at the end of the person-centred fire risk assessment, providing for what the resident should do in the event of a fire.
• Regulation 9 mandates RPs to undertake reviews of the residential PEEPs process, i.e. the person-centred fire risk assessment, mitigating measures, and emergency evacuation statement. Such reviews must occur at least every 12 months, and at any time if there is a reason to believe it may require updating.
• Regulation 10 makes it a legal requirement for the RP to share the following prescribed information on all relevant residents with their local fire and rescue authority, subject to the explicit agreement of each relevant resident to this information being shared: the resident’s flat number, their floor number, basic information regarding the degree of assistance that the resident may require to evacuate the building, and whether the resident has an emergency evacuation statement.

Guidance

To provide more clarity as to how residential PEEPs will work in practice and to outline how the Regulations ought to be complied with, the Ministry of Housing, Communities and Local Government released operational guidance, resources and toolkits, accessible via the links below:

1. Residential PEEPs: Factsheet
2. Residential PEEPs: Guidance for Responsible Persons
3. Responsible Persons toolkit
4. Responsible Persons toolkit - Annexures of additional resources
5. Residential Personal Emergency Evacuation Plans and Building Level Evacuation Plans - Impact Assessment

Conclusion

The Regulations represent a major step forward in strengthening fire safety and complete the implementation of the Inquiry's recommendations. The Regulations aim to reduce the number of fire-related injuries and fatalities whilst ensuring that consent from residents is required throughout every stage of residential PEEPs.

For RPs to effectively address the challenges posed by the Regulations and contribute to a safer living environment for all residents, RPs will want to proactively engage with the Regulations and seek legal advice on their responsibilities, where necessary.