Navigating new responsibilities under Residential PEEPs

The new Fire Safety (Residential Emergency Evacuation) (England) Regulations 2025 introduce substantial new operational obligations for Responsible Persons (RP), significantly strengthening their role in ensuring the safety of vulnerable residents in their building. The regulations require robust arrangements to ensure individuals who are not able to evacuate on their own can do so safely in an emergency.

While RPs can outsource elements of the process to a competent external provider, the legal duty and accountability remain with the Responsible Person.

To understand the full impact of the regulations, it is first essential to understand the specific duties placed on the Responsible Persons and how they must be implemented in practice.

Identification of relevant residents

Responsible Persons must use multiple reasonable paths to identify vulnerable residents in their building(s).

Vulnerabilities can include (but are not limited to):

• Blind/partially sighted
• Dear/hearing impairment
• Physically impaired
• Cognitive impairment
• Breathing or heart condition
• Sensory/neurological
• Communication impairments

Resident participation in the Residential PEEPs process is completely voluntary; they cannot be forced to engage with the process.

Offer Person-Centred Fire Risk Assessment

All residents identified as vulnerable must be offered a person-centred fire risk assessment (PCFRA). The RP must also undertake the risk assessment if the resident requests one.

Resident consent to completing a PCFRA is essential, and it can be withdrawn at any time.

PCFRAs are specific to the individual and must consider the risks and needs relating to the resident and the premises, in light of their impairments. The assessment must also consider the president’s ability to evacuate the building without assistance and detail any barriers to evacuation.

While there are no requirements for residents to share specific medical information, the RP must gain as much information as possible to be able to assess the risks relating to the residents’ impairments in the event of an emergency.

Mitigation of risks

After the PCFRA is carried out, the RP must have a discussion with the resident to identify ‘reasonable and appropriate’ measures to put in place to reduce the risk.

Whether a mitigation measure is ‘reasonable and proportionate’ will typically depend upon who bears the cost of the means/equipment, the risk consideration and its practicality. If a resident’s safety is at serious risk, decisions about mitigation measures to implement must not be based solely on cost.

Cost of mitigations

The cost of a mitigation measure can fall onto either the resident, the RP, or the whole building. However, if the cost falls onto the relevant resident, and they decline, the RP isn’t obligated to implement the mitigating means or equipment.

In order for the cost to be shared by all residents of a building, the mitigation measure must benefit the majority of the building’s residents.

It is important to note that Residential PEEPs do not override existing leaseholder rights. A proposed mitigation would not be reasonable and proportionate if it impinges on another leaseholder’s rights without that leaseholder agreeing to the mitigation.

Emergency Evacuation Statements

The RP must come to an agreement with the resident on what they should do in the event of an emergency. This should be written down as an Emergency Evacuation Statement (EES).

While there is no prescribed format for the statement, just that it must be in writing, providing the resident with an understandable, accessible and practical statement will help them recall and follow the actions in an emergency.

Review

The RP has a duty to ensure the PCFRA and EES are reviewed at appropriate intervals:

• 12 months after the statement is recorded
• If there are changes in circumstances or in the building
• At the request of the resident

Information Sharing

As part of the process, information must be shared with the local fire and rescue service for operational assistance and targeted assistance.
RPs must only share the following information:

• The resident flat number
• Floor number
• Basic information regarding the degree of assistance required by the resident to evacuate the building
• Whether the resident has an emergency evacuation statement

The sharing of this information must only be done if the resident explicitly consents to it.

Building Emergency Evacuation Plan

Under the scope of the regulation, the RP is also required to complete an updated building emergency evacuation plan, outlining if there are any Residential PEEPs in the building, share this with their local fire and rescue service, and if the building has one, place it in the secure information box.

If the process of Residential PEEPS highlights overall systematic building issues, the RP may need to consider the building’s overall evacuation assumptions.

The RP also has a duty to review this plan every 12 months, or if circumstances change. If the plan is changed, this must be shared with the local fire service and replaced in the secure information box.

Documentation and Audit Trails

Critical for demonstrating compliance with the legislation, the process must be meticulously documented, including:

• Record offered PCFRAs, and document any residents who decline
• Record refusals of mitigation measures
• Keep evidence of information sharing
• Ensure version control across all documents

Last Updated: 22th January 2026