Residential PEEPs Now in Force; What the 2025 Regulations Mean for Your Building

Planning

Bernard Sims Associates | Building Safety Insight

The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 are now in force, and for everyone connected to higher-risk residential buildings,  whether you designed them, developed them, manage them, or are responsible for the people who live in them, the obligations are live. The 6th April 2026 was not a deadline to prepare for; it was the date the law changed. 

This post sets out what the Regulations require, who carries the duty, and what a competent compliance position actually looks like.

The core purpose

The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 exist because a significant number of people living in multi-storey residential buildings cannot get out unaided in a fire. That might be because of a mobility condition, a sensory impairment, or a cognitive difficulty. Until now, there has been no consistent legal framework requiring building owners to identify those residents and to plan specifically for their evacuation. These Regulations close that gap.

They also respond directly to recommendations from the Grenfell Tower Inquiry Phase 1 report, including those that had been outstanding for some time. None of this came without warning, but moving from guidance into enforceable law is a significant step up.

Scope: Which buildings are covered?

The Regulations apply to residential buildings in England containing two or more dwellings that fall into one of two categories: buildings that are 18 metres or above in height, or that have seven or more storeys; and buildings between 11 and 18 metres in height where a simultaneous evacuation strategy is in operation. If your building fits either description, you are in scope.

What the Regulations require

The duty sits with the Responsible Person; the building owner, landlord, or managing agent, as defined under the Regulatory Reform (Fire Safety) Order 2005 (RRFSO).

Their obligations are as follows: They must take reasonable steps to identify residents in the building whose ability to evacuate without assistance would be compromised by a physical or cognitive impairment, and where the property is their only or principal residence. These are defined under the Regulations as “relevant residents.”

Where a relevant resident is identified, the Responsible Person must offer them a person-centred fire risk assessment, a structured conversation, and an evaluation of the specific risks posed by their impairment and what practical measures might help them get out safely. If the resident agrees to engage, the outcome of that assessment must be documented in an emergency evacuation statement, shared with the resident, and reviewed at least annually or whenever their circumstances change.

Reasonable and proportionate mitigating measures must then be put in place. The Regulations allow for the cost of these measures to be met in different ways depending on the nature of the measure and who benefits from it.

In addition to individual plans, a building-wide emergency evacuation plan must be developed. A summary of key resident information must be stored on-site in a Secure Information Box, accessible to fire crews attending an emergency, but only with the resident’s explicit consent to share their personal data.

The compliance challenges most teams are underestimating

The headline duties are straightforward enough to describe. The practical challenge is different.

Identifying relevant residents is not a one-off exercise. Residents move in and out. Conditions change. The process needs to be embedded into ongoing building management, not completed once and filed away.

The data handling requirements are substantive. The information collected during the person-centred fire risk assessment process includes sensitive personal data relating to health and disability. That data must be collected with proper consent, stored securely, kept accurate, and managed in line with current data protection law. There is also an interaction with the Equality Act 2010 that building managers need to be alert to when deciding what measures are and are not reasonable. Getting this wrong carries legal and reputational risk well beyond a fire safety enforcement notice.

The Secure Information Box requirement adds a physical infrastructure dimension to what might otherwise seem like a documentation exercise. Fire and rescue services have the power to inspect these boxes and, where compliance is absent, to take enforcement action.

Implications across the professional chain

These are not just asset management obligations. They have implications for everyone involved in the lifecycle of in-scope buildings.

For architects and designers working on higher-risk residential schemes, the building emergency evacuation plan needs to be considered as part of the design, not bolted on at handover. The information systems that support it, the Secure Information Box, the resident data trail, and the Golden Thread, need to be planned from early in the project.

For developers and asset managers, compliance does not end at practical completion. These are ongoing duties across your portfolio. If you hold stock that falls within scope, the question is not whether you will need to comply; it is whether your current processes can deliver and maintain compliance across multiple buildings simultaneously.

For project managers, estate directors, and development leads, your role is to ensure that the Responsible Person for each building in scope has a functioning process in place and the documentation to prove it. That is not always easy to establish from a distance.

For local authority officers, the Regulations sit squarely within the broader building safety framework that has been reshaping expectations of Responsible Persons since the Building Safety Act. Understanding what a compliant position looks like and what red flags to look for is part of effective oversight.

What Bernard Sims Associates offers

We work with the full range of professionals that these Regulations touch. Our work spans building safety compliance, fire risk management, Principal Designer support, and the Golden Thread, meaning that we understand not just the text of the Regulations but what a defensible, audit-ready compliance position looks like in real buildings.

We can help you assess whether your buildings are in scope, review the adequacy of your current processes, and put in place documentation frameworks that will withstand scrutiny from the BSR, fire and rescue services, and your own insurers.

If you are not yet confident that compliant Residential PEEP (Residential Personal Emergency Evacuation Plans) arrangements are in place across your portfolio, the time to address that is now.


Bernard Sims Associates provides specialist building safety consultancy to architects, developers, asset managers, project managers, and building owners across England. Contact us to discuss how the Regulations affect your buildings or your project.

We also carry out fire risk assessments, training for fire marshals, and general fire safety awareness. Call BSA on 01483 467 270, or reach us via our contact form below.