In the wake of the Grenfell Tower tragedy, and after years of consultation, new requirements for Residential Personal Emergency Evacuation Plans (PEEPs) are now set to come into force on 6 April 2026 under the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025. 

The regulations will apply to all buildings that contain two or more sets of domestic premises and which are either: 

• 18 metres in height/have seven storeys; or 
• more than 11 metres in height and have a simultaneous evacuation strategy in place.

From consultation to legislation

The 2021 consultation on PEEPs proposed mandating evacuation plans for residents in ‘high-rise buildings’ whose ability to self-evacuate may be compromised. However, responses to this consultation highlighted serious concerns about the feasibility and practicalities of implementing such plans in domestic settings. As a result, the Government launched a second consultation, Emergency Evacuation Information Sharing Plus (EEIS+), to explore alternative approaches. The EEIS+ consultation found broad support for a more tailored, proportionate system. This led to the development of the Residential PEEPs process.

What are the new requirements?

Under the Regulations, the Responsible Person (as defined under the Regulatory Reform (Fire Safety Order) 2005) for in-scope buildings must:

• Use reasonable endeavours to identify residents who may need assistance to evacuate during a fire. Importantly, a resident cannot be compelled to engage with the Responsible Person as part of the Residential PEEPs process – it is their choice. 
• Offer a Person-Centred Fire Risk Assessment (PCFRA) to those residents they identify. Where a resident requests a PCFRA, this must consider the additional risks and needs identified relating to that resident (beyond the generic risks in the building’s overall fire risk assessment) and the specific challenges they may face (e.g., in terms of safely evacuating the building). The guidance makes clear that the Responsible Person will need a sufficient understanding to assess the risks, but the resident is under no obligation to disclose any specific information.  
• Discuss with the resident the risks identified and determine reasonable and proportionate measures for the Responsible Person to take to mitigate the risks identified in the PCFRA. The decision as to the measures that are reasonable and proportionate ultimately falls to the Responsible Person, and it is likely to require careful consideration (including in respect of who the costs of implementing a measure will fall to).
• Using reasonable endeavours to agree with the resident what they should do in the event of a fire and document this as a written evacuation statement. 
• Share prescribed information with local Fire and Rescue Services with the resident’s explicit consent and in line with data protection legislation.
• Review the Residential PEEPs process no later than 12 months after it is first recorded, if there is reason to believe that the process needs amending/updating or at the reasonable request of the resident.

There are also separate requirements in respect of the preparation, disclosure and review of building emergency evacuation plans. 

Implications for RPs

These new duties represent a significant shift in the responsibilities of Responsible Persons for in-scope buildings. Practically, there will be several considerations and Responsible Persons will need to ensure they have policies and procedures in place to cover issues, including:

• How they will proactively engage with residents to identify those who may need support;
• how resources will be allocated to ensure initial and continued compliance with the new requirements;  
• data protection and consent management, particularly when sharing sensitive information with emergency services;
• where applicable and as prescribed by the Regulations, ensuring that instructions are obtained from a resident’s representative; and
• training and awareness for staff to ensure compliance with the new framework.

While the new Residential PEEPs model claims to avoid the impracticalities of the original proposals, it still places a clear onus on Responsible Persons to plan for the safe evacuation of vulnerable residents and we can see there is likely to be many practical challenges in ensuring compliance. The Government has published detailed guidance and a toolkit to support implementation, helping duty holders navigate this new landscape.

It is important to note that the Government’s guidance makes clear that it intends, through future primary legislation, to introduce an additional requirement on Responsible Persons to consider fire safety risks within a resident’s own domestic premises as part of the PCFRA and to identify reasonable and proportionate measures to mitigate the risks identified. 

For more information

If you would like support to understand your obligations under the new regulations, or any other aspect of fire and building safety, please contact us.