New requirements for Residential PEEPS (Personal Emergency Evacuation Plans)

Written by Louise Mansfield and Elspeth Lee

The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 introduce new obligations on building owners and managers, in high-rise and higher risk residential buildings, to improve the fire safety and evacuation of residents who would have difficulties evacuating a building by themselves, in the event of a fire. These obligations include Residential ‘Personal Emergency Evacuation Plans’ (PEEP’s) and will come into force on 6 April 2026. 

This requirement has been introduced by the Ministry of Housing, Communities and Local Government following the recommendations made in the Grenfell Tower Phase 1 Inquiry Report, which recommended that “that the owner and manager of every high-rise residential building be required by law to prepare personal emergency evacuation plans (PEEPs) for all residents whose ability to self-evacuate may be compromised (such as persons with reduced mobility or cognition)”.

The duties under these Regulations fall upon a ‘Responsible Person’, The RP is the person who is responsible for the fire safety of themselves and others who use a regulated premises and on whom most of the duties set out in the Fire Safety Order are imposed, typically the building owner or manager.

The Regulations will only apply to buildings that contain two or more sets of domestic premises, and which is either (a) at least 18 metres above ground level or have at least seven storeys; or (b) is more than 11 metres in height above ground level that has simultaneous evacuation strategies in place.

A resident for the purposes of the Regulations is someone whose principal residence is the domestic premises in which they reside, whose ability to evacuate the building without assistance in the event of a fire is compromised as a result of a cognitive or physical impairment or condition. 

The PEEP’s

Residents with disabilities and vulnerabilities will be entitled to:

1. A person-centred fire risk assessment to consider their specific individual risk 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 residents should do in a fire 
4. Information shared with their local Fire and Rescue Service so they are aware of where vulnerable residents reside, and can support their evacuation or rescue, in the event of a fire 

Resident consent is required throughout every stage of Residential PEEP’s namely, whether they wish to participate, whether they agree the emergency evacuation statement or whether they consent to their information being shared with the Fire and Rescue Authority. This level of engagement with the PEEP is up to the Resident.

A person-centred fire risk assessment to consider their specific individual risk and ability to evacuate in the event of a fire 

The RP must offer a person-centred fire risk assessment to each relevant resident they identify and where the resident requests one, ensure it is undertaken. It 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 consider the resident’s ability to evacuate the building (without assistance) in the event of a fire. 

There is no requirement in the regulations for the resident to share medial records or specific information with the RP. The person-centred fire risk assessment is not intended to duplicate or repeat the building’s fire risk assessment required. The focus should be on whether the resident faces specific fire safety challenges due to their impairment or condition. 

The measures that could be reasonably and proportionately introduced to mitigate against their risks 

The RP must discuss this with resident to identify reasonable and proportionate measures for the RP to take to mitigate the risks identified. Reasonable and proportionate differs depending on who bears the cost. 
For instance, a measure may not be considered reasonable and proportionate, if all residents were to bear its costs. Consideration is required if the costs in implementing potential measures were to fall to; the RP, the relevant resident or where the measure benefits the majority, to all residents for the time being of the building. 

The RP must implement reasonable and proportionate measures, with the exception of measures where costs would fall to the resident and the resident declines to pay costs. In that case, the resident may decline to have the measures or equipment provided. It will ultimately be the decision of the RP as to which measures are reasonable and proportionate and therefore will be implemented. 

These regulations will not override leaseholder rights and any mitigation affecting shared property, must be agreed upon. 

A written statement recording what residents should do in a fire 

The RP must use reasonable endeavours to agree with the relevant resident, at the end of the person-centre fire risk assessment, what the resident should do in the event of a fire. The RP also has the responsibility under the Regulations to ensure this is written down as a statement, referred to as the emergency evacuation statement. There is no prescribed format for this, other than it should be in writing. Clarity and brevity will assist the resident’s ability to recall and follow this statement. 

A resident can support their evacuation through the use of volunteers and get their agreement to help. There is no specific duty on the RP to facilitate this, although they are able to do so if they choose to. This of cause raises concerns around putting others at risk, and whether such volunteers would actually be available at the time of a fire.

Information shared with their local Fire and Rescue Service so they are aware of where vulnerable residents reside, and can support their evacuation or rescue, in the event of a fire 

The RP must share, subject to the explicit agreement of each relevant resident to this information being shared, the following prescribed information on all relevant residents, with their Local Fire and Rescue Authority;

• The resident’s flat number 
• The resident’s floor number 
• Basic information regarding the degree of assistance that the resident may require to evacuate the building 
• Whether the resident has an emergency evacuation statement

It is for the local Fire and Rescue Authority to determine whether the information should be shared digitally or physically. 

Enforcement 

These obligations will come into force on 6th April 2026. Enforcing authorities, such as Fire and Rescue Authorities have the power to enforce the RP’s compliance with their duties, such as the RP’s responsibility to follow the Residential PEEP process. The Fire and Rescue Authority are not expected to arbitrate any disagreements. Residents can raise concerns with the building’s ‘Accountable Person’ and escalate to the Building Safety Regulator if the issue is not addressed adequately. 

The Toolkit

The government have also published a toolkit which supplements the new Regulations. It sits separately from the Residential PEEP policy in that it is intended as a resource accessible to all Responsible Persons, even if their building falls outside the scope of the Residential PEEPs policy. The Toolkit can be found here. 

It is based on successful local initiatives which RP’s have in place, to improve the fire safety and evacuation of their residents with disabilities or impairments. There are four key themes;

1. Use of person-centred fire risk assessments
2. Identifying and engaging residents 
3. Provision of in-flat fire safety measures 
4. Information sharing with Fire and Rescue Services 

For example, in relation to the provision of in-flat fire safety measures, devices such as light alarms, vibrating pillows, misters and sprinklers and pull cords could be utilised. These measures sit within a broader range of measures regarding communication and engagement with residents who request assistance and, how they should evacuate in an emergency. 

To assess those at risk and how to best assist them, RP’s could task staff with visiting residents to assess their risk of causing a fire, their ability to recognise a fire is happening and their ability to evacuate. For those identified as at risk, a Person-Centred Fire Risk Assessment (PCFRA) could be undertaken, and a fire technician and housing officer could review what may be needed to reduce risks. This could include internal alarm systems, fire doors or sprinklers. 

If residents are not able to evacuate unaided and do not live on the ground floor, a move to a ground floor property could be offered. However, a resident cannot be forced to move. If a resident does not want to move, RP’s could work with the Fire Service to conduct home safety checks to identify if there are any other mitigations that could be put in place. 

We await the further statutory guidance that will be published under Article 50 of the Regulatory Reform (Fire Safety) Order 2005 in Autumn this year but, recommend that RP’s begin by reading the Toolkit and sharing learning around effective, best practices. RP’s should look to devise strategies as to what content to include in the assessments, common risks that can be mitigated, and how to deal with information sharing and collection, whilst complying with UK GDPR laws.  

If your organisation is impacted by these new Regulations, we would be happy to assist in ensuring compliance.