In our recent blog, we explored the requirements for Residential Personal Emergency Evacuation Plans (PEEPs), which will take effect on 6 April 2026, and what these changes mean for Responsible Persons managing in-scope buildings.  

As a reminder, in-scope buildings include 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.

On 2 December 2025, the Government published updated guidance for Responsible Persons on implementing Residential PEEPs. Below, we have outlined five key points from the guidance for Responsible Persons to consider:

1. Proactive engagement: Identifying and engaging with residents who may need help evacuating should not be a one-off exercise. The guidance recommends engagement at move-in, annually (as a reminder to all residents) and whenever a resident requests support.

2. The ‘Trusted Person’: In addition to Responsible Persons being able to take instructions from a resident’s representative, the guidance introduces the role of a ‘Trusted Person’ – someone who the resident, regardless of their ability to cognitively engage with the Residential PEEP process, chooses to assist with discussions. However, unlike when dealing with the resident’s representative, the resident must be present during any discussions with the Trusted Person, personally agree to all measures and the evacuation statement, and give explicit consent before any information is shared with the Fire and Rescue Service.

This distinction is important to ensure the wishes and feelings of the resident are respected throughout, and to ensure compliance with data protection requirements. 

3. Person-Centred Fire Risk Assessments (PCFRAs): The completion of PCFRAs does not require Responsible Persons to instruct external specialists. They can be completed by trained staff through conversations with the resident or their representative, making implementation more practical and cost-effective. Whilst Responsible Persons are encouraged to explore various ways to engage with residents and to explain the fire safety benefits to them, residents cannot, however, be compelled to engage in the Residential PEEP process.

4. Reasonable and Proportionate Measures: Measures that compromise compartmentation, significantly increase service charges or require paid staff solely for evacuation support are ‘extremely unlikely’ to be considered reasonable or proportionate. However, Responsible Persons are encouraged to assess any measures identified through PCFRAs on a case-by-case basis.

5. Data protection compliance: Only minimal, necessary information should be recorded and shared with Fire and Rescue Services, and always with the resident’s consent and in line with data protection laws. The ‘RP Toolkit’ includes examples of compliant approaches. Where a resident refuses or withdraws consent, the Responsible Person should explain to the resident that, whilst this does not mean the local Fire and Rescue Service would not evacuate or rescue them if needed, the Fire and Rescue Service will not have the specific information signposting them to the resident or on the level of assistance the resident may require to evacuate the building.  

For more information

These new duties represent a significant shift in the responsibilities for Responsible Persons of in-scope buildings and set out clear expectations for an area that has previously lacked this. Responsible Persons should review the updated guidance and Toolkit in full, alongside their current policies and procedures, to prepare for the introduction of these requirements in April 2026.

For advice on your obligations under the new regulations or wider fire safety issues, please contact us.