The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025: Implementation Stage

The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 (the Regulations), which entered into force on 6 April 2026, represent one of the most significant operational changes to residential fire safety since the Fire Safety Act 2021 and the Building Safety Act 2022.

Background

These Regulations have their origins in the Grenfell Tower Inquiry Phase 1 Report, which recommended that Personal Emergency Evacuation Plans (PEEPs) and building-level evacuation plans be implemented by the owners and managers of high-rise residential buildings. The Inquiry identified that residents with disabilities or impairments were often left without any clear or agreed plan for evacuation, even where "stay put" strategies were in place.

An initial consultation in 2021 considered a workplace-style PEEPs model, but it was concluded that there were substantial difficulties with operating such a model in residential buildings, as no cases had been successfully implemented. A further extensive consultation — the Emergency Evacuation Information Sharing Plus Consultation held in 2022 — informed the development of the Residential PEEPs policy that underpins these Regulations. The Government published its response in December 2024, and these Regulations were subsequently laid before Parliament on 4 July 2025, addressing the last three outstanding Grenfell Inquiry Phase 1 recommendations.

Scope and Applicability

The introduction of the Regulations requires active management in relation to fire risk for residential and some mixed-use buildings to enhance the safety and evacuation procedures for residents who may face difficulties evacuating independently during a fire.

Part of that active management is that the Regulations require person-centred fire risk assessments and Personal Emergency Evacuation Plans (PEEPs) to be put in place by the Responsible Person (RP) of all residential buildings in England that contain two or more domestic premises and meet specific height criteria:

• at least 18 metres above ground level or have at least seven storeys; or
• more than 11 metres in height above ground level and which have “simultaneous evacuation” strategies in place (meaning all persons must leave immediately in the event of a fire).

The Regulations require PEEPs for individuals who may struggle to self-evacuate, with the Responsible Person (RP) (defined by the Regulatory Reform (Fire Safety) Order 2005 as the person with control of the premises, typically the building owner or managing agent) tasked with ensuring compliance. This includes identifying relevant residents, conducting person-centred fire risk assessments, and developing the emergency evacuation statements.

Key provisions of the Regulations include:

Identification of Relevant Residents

RPs must use reasonable endeavours to identify residents who require PEEPs. A relevant resident is a person who has their only or principal residence in a specified residential building, and whose ability to evacuate without assistance in the event of a fire is compromised as a result of a cognitive or physical impairment or condition.

Person-Centred Fire Risk Assessment (PCFRA)

RPs must offer tailored assessments to understand individual risks to the person and the premises, beyond the general building fire safety risk assessment, and conduct them for any resident who requests one. This involves evaluating the resident's ability to evacuate without assistance and considering reasonable and proportionate mitigating measures.

Emergency Evacuation Statements

RPs must agree with residents on actions to take during a fire, documented in a written statement. This ensures residents have a clear plan in case of an emergency.

Information Sharing

RPs are required to share minimal but crucial information with local Fire and Rescue Authorities. The information to be shared is deliberately limited: the resident's flat number, floor number, basic information about the degree of assistance they may require to evacuate, and whether they have an emergency evacuation statement.

Ongoing Review

The Regulations mandate regular reviews of the person-centred fire risk assessment, emergency evacuation statement, and building evacuation plan, at least every 12 months, and at any time if there is a reason to believe it may require updating.

Building Emergency Evacuation Plans

RPs must prepare a separate building emergency evacuation plan (with details of building evacuation strategies, relevant residents, and a copy of the information given to residents regarding evacuation), share this plan with the local Fire and Rescue Authority and place a copy of the plan in the secure information box. This too must be reviewed regularly and updated.

Representatives

Involvement with representatives may be required as the Regulations enable the RP to act on the instructions of a person authorised to act on behalf of the relevant resident - whether requesting a PCFRA, discussing mitigating measures, agreeing an approach to evacuation, requesting a review and/or consenting to provision of information to Fire and Rescue authorities.

Enforcement and Liability

Participation in the process by residents is voluntary, and residents cannot be compelled to engage. Individual consent is required for participation, agreement of a PEEP, and to share any information with third parties. However, the obligations on the RP are not voluntary, and enforcing authorities under the Fire Safety Order 2005 will have powers to enforce compliance.

For high-rise residential buildings, a failure to put an effective process in place may also give rise to a failure under the Building Safety Act 2022 and residents may raise concerns through the Residents Voice process.

Beyond fire safety enforcement, RPs should be mindful of risks under the Equality Act 2010, given that the Regulations primarily engage with disabled people, and under the GDPR, as the data obtained will invariably be of a highly sensitive nature.

In terms of practical next steps, RPs should be taking action now: reviewing their building portfolios for applicability, developing resident engagement procedures, creating compliant templates, training property management teams, and reviewing data protection policies. Strong record keeping – including unsuccessful attempts at contact and reseals as well as confirmed plans – will be important to prove compliance.

Impact on the Construction and Real Estate Sector

The Regulations are poised to have significant impacts across the property and construction sector. Compliance will affect building owners, managing agents, developers, and design professionals alike, and the practical challenges will vary depending on the nature and tenure of the building in question.

For example, Build-To-Rent and PBSA schemes may have particularly transient populations when compared with long leasehold developments, making it more difficult to identify relevant residents who may require a PEEP. In retirement living and sheltered housing, a higher proportion of residents may qualify as relevant residents, increasing the volume of person-centred assessments and evacuation statements required.

Across all tenure types, there may be concerns about engagement with residents — whether because of language barriers, short-term occupation, or a lack of awareness of the new requirements.

For building owners, managing agents, and freeholders, the Regulations impose clear operational obligations. Beyond identifying relevant residents, RPs will need to establish robust internal processes for conducting person-centred fire risk assessments, maintaining up-to-date evacuation statements, and liaising with local Fire and Rescue Authorities. This is likely to increase operational and management costs, particularly for portfolios with a large number of qualifying buildings.

From a development and design perspective, the requirement for regular reviews and updates to evacuation plans may influence the design and layout of new developments. Architects, engineers, and developers may wish to incorporate features that facilitate easier evacuation for vulnerable residents (such as wider corridors, evacuation lifts, refuge areas, and enhanced wayfinding signage). This proactive approach not only enhances safety but also aligns with broader societal goals of inclusivity and accessibility, potentially increasing the appeal and long-term value of residential properties.

Contractors and construction professionals involved in refurbishment or major works to existing buildings should also be mindful of the Regulations, as works that alter means of escape or fire safety strategies may trigger a need for RPs to review and update their building emergency evacuation plans and any existing PEEPs.

This is also an area which is expected to develop – the Government fact sheet on PEEPs notes:

“Government intends through future primary legislation to introduce a requirement on RPs, as part of the person-centred fire risk assessment in Residential PEEPs, to consider the fire safety risks within the relevant resident’s domestic premises.”

We are tracking developments on our Building and Fire Safety hub and timeline. For more details, please see here.

This article is a general guide only and does not constitute legal advice.

Always seek advice on your specific circumstances. Please do contact David Savage, Richard Flenley or Tegan Johnson (or your usual Charles Russell Speechlys contact) if you have any queries arising from this article.