PEEPs and Fire Safety: Who Needs One

A Personal Emergency Evacuation Plan — a PEEP — is a written plan for how one specific person will get out of a building during a fire when they cannot do it unaided. It records what that person needs, what assistance or equipment is involved, which route is to be used, and who is responsible for each part.

Two things about PEEPs are commonly confused, and the confusion matters because it changes what you actually have to do. In workplaces and other non-domestic premises, no regulation uses the word "PEEP" — the duty arrives indirectly, through the requirement to assess risk to everyone who might be present and to establish appropriate evacuation procedures. In residential buildings in England, the position changed on 6 April 2026, when the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 came into force and set out a named, specific set of duties. This guide covers both, and is clear about which is which.

This article summarises UK fire safety law for educational purposes and is not legal advice. The responsible person carries the legal liability for fire safety in the premises. For specific compliance questions, consult a competent fire risk assessor or your local fire and rescue authority.

What a PEEP Actually Contains

There is no statutory template, which is part of why the term causes trouble. In practice a workable PEEP records:

• Who the plan is for, and what specifically limits their ability to evacuate — mobility, sight, hearing, cognitive impairment, or a condition that fluctuates.
• Where they normally are in the building, and when.
• The route they will use, including whether it depends on a lift, a refuge, or an evacuation chair.
• What assistance is needed, described concretely: one person or two, verbal guidance, physical support, equipment.
• Who provides that assistance, and what happens when that person is absent.
• What the individual does themselves — a PEEP is a plan agreed with someone, not a plan imposed on them.
• How the plan was communicated and when it was last reviewed.

The test of a PEEP is not whether it exists but whether it would work at three in the morning with the named helper on holiday. A plan that quietly assumes a specific member of staff is on site is a plan with a hole in it.

Workplaces and Other Non-Domestic Premises

Here the duty is real but indirect. The Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to assess the risks to "relevant persons" — which is everybody who may lawfully be on the premises, not only employees. Article 9(1) puts it plainly:

"The responsible person must make a suitable and sufficient assessment of the risks to which relevant persons are exposed..."

The evacuation duty then comes from Article 15, which requires the responsible person to:

"establish and, where necessary, give effect to appropriate procedures, including safety drills"

for serious and imminent danger, and to designate sufficient competent people to implement those evacuation procedures.

Put those two together and the logic is short. If a relevant person cannot evacuate unaided, then an evacuation procedure that assumes everyone can walk out is not "appropriate", and an assessment that does not consider them is not "suitable and sufficient". The individual plan is how you close that gap. The absence of the word "PEEP" from the Order is a drafting fact, not a get-out.

For assessors, the practical consequence is that identifying people at risk is not a box on a form. Our 30-point fire risk assessment checklist treats vulnerable occupants and sleeping risk as distinct items for exactly this reason.

Residential Buildings in England: What Changed on 6 April 2026

The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 (SI 2025/797) came into force on 6 April 2026. Regulation 1 states it without qualification:

"These Regulations come into force on 6th April 2026."

They apply in England only. Unlike the workplace position, these Regulations name the duties directly — and they are more demanding than most responsible persons expect, because several of them are ongoing rather than one-off.

Which buildings are covered

Regulation 3 defines a "specified residential building" as one containing two or more sets of domestic premises that also meets at least one of these tests:

• "is at least 18 metres in height above ground level"
• "has at least seven storeys"
• "is more than 11 metres in height above ground level and has a simultaneous evacuation strategy"

The third test is the one that catches people out. A building of, say, 14 metres is nowhere near the 18-metre threshold — but if it is operating a simultaneous evacuation strategy, it is in scope. Height is measured to the top storey using the Approved Document B method, below-ground storeys are excluded from the storey count, and a mezzanine counts as a storey where its internal floor area is at least 50% of the largest above-ground storey.

If a building meets none of the three tests, the 2025 Regulations do not apply to it. That is worth stating plainly, because the general Fire Safety Order duties still do.

Who counts as a "relevant resident"

Regulation 4 defines a relevant resident as a relevant person who is a resident of domestic premises in a specified residential building where those premises are:

"that person's only or principal residence"

and whose ability to evacuate independently in a fire is reduced by a cognitive or physical impairment or condition. Two limits are built into that. It is about residents, not visitors. And it is about a principal residence — a second home or a let-out flat does not bring its occupier into the definition on that basis alone.

The duties, in order

Regulation 5 — identification. The obligation is one of effort, not of certainty:

"The responsible person in relation to a specified residential building must use reasonable endeavours to identify relevant residents of that building."

Regulation 5 sets no deadline and no prescribed method. What it does mean is that "nobody told us" is not by itself an answer — the question is what reasonable endeavours were made, and whether there is a record of them.

Regulation 6 — person-centred fire risk assessment. The responsible person must offer a person-centred fire risk assessment to each relevant resident, and must ensure one is carried out for each relevant resident who requests it. Note the shape of that: the offer is mandatory, the assessment follows the resident's decision. A resident who declines has not created a breach.

Regulations 7 and 8 — mitigation and the emergency evacuation statement. Where an assessment identifies risks, the responsible person must take mitigating measures, and where appropriate agree an emergency evacuation statement with the resident recording how evacuation will work for them.

Regulation 9 — review. This is the duty most likely to be missed, because it recurs. Reviews must happen:

"no later than 12 months after the date on which the emergency evacuation statement was first recorded, or, where no approach was agreed, the person-centred fire risk assessment was completed"

and "before the end of every period of 12 months thereafter". Note the second limb: where no approach was agreed under Regulation 8, so there is no statement to date the clock from, the 12 months still run — from completion of the person-centred fire risk assessment. A review is also triggered if there is reason to believe the assessment or statement needs amending, or at the reasonable request of the resident. In other words, this is a standing annual cycle per resident, not a project with an end date.

Regulation 10 — telling the fire and rescue authority. The responsible person must provide the local fire and rescue authority with resident information — flat number, floor number, basic information about the assistance needed, and whether an emergency evacuation statement exists. Critically, Regulation 10(2) requires the resident's explicit consent before that information is shared. Information goes either by electronic means or as a hard copy in a secure information box — "by whichever of the following means the local fire and rescue authority chooses", so the method is the authority's call, not the responsible person's. Where the authority chooses hard copy and no secure information box exists, the responsible person must install and maintain one.

Regulation 13 — the building emergency evacuation plan. Separately from the individual plans, the responsible person must prepare a building emergency evacuation plan, give it to the local fire and rescue authority, and — "where the building has a secure information box" — place a copy in that box. It covers the instructions residents are given about the evacuation strategy, whether relevant residents are present, and other evacuation arrangements. It runs on the same 12-month review cycle, and amended copies go to the fire and rescue authority as soon as reasonably practicable.

The Regulations also amend the Fire Safety (England) Regulations 2022, so they sit alongside the secure-information-box and resident-information duties already introduced there rather than replacing them. If you assess residential blocks, our walkthrough of the Fire Safety (England) Regulations 2022 covers that earlier layer regulation by regulation.

Two Regimes, Side by Side

What This Means for Your Fire Risk Assessment

If you assess buildings in England, three things follow.

Scope check first. Before anything else, establish whether the building meets one of the Regulation 3 tests. The 11-metre-plus-simultaneous-evacuation limb is the one to check deliberately, because it does not follow from height alone and a building can move into scope when its evacuation strategy changes.

Record the evidence trail, not just the conclusion. "Reasonable endeavours" and "offered" are both things you may later need to show. What was done, when, to whom, and what the response was.

Treat the 12-month cycles as live. Two separate annual clocks now run in a specified residential building — one per resident statement, one for the building plan — on top of the ordinary review duty for the fire risk assessment itself under Article 9(3). Missing them is the most likely failure mode, because nothing prompts you. Our free FRA review date calculator helps set the review date for the assessment, and our guide to how often a fire risk assessment should be reviewed covers the trigger events.

Be clear about who owes the duty. All of these duties sit on the responsible person, who in a residential block is often a freeholder, management company or managing agent rather than an individual. If that is unclear in a building you assess, our guide to who is responsible for a fire risk assessment works through how the Order allocates it, and fire risk assessments for flats and blocks of flats covers the common-parts boundary.

Summary

A PEEP is an individual plan for getting one person out of a building who cannot get out unaided. In non-domestic premises the duty is derived rather than named: Article 9 requires you to assess risk to all relevant persons, and Article 15 requires appropriate evacuation procedures, and an individual plan is how those two are satisfied for someone who needs assistance.

In England's specified residential buildings the position is now explicit. The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 came into force on 6 April 2026 and require the responsible person to make reasonable endeavours to identify relevant residents, offer each a person-centred fire risk assessment, mitigate identified risks, agree emergency evacuation statements, share consented resident information with the fire and rescue authority, prepare a building emergency evacuation plan, and review all of it every 12 months. The recurring reviews, not the initial exercise, are where this regime will be won or lost.

For assessors carrying this into practice, AssessKit structures every assessment to a recognised methodology (PAS 79-1 for non-domestic premises, BS 9792:2025 for housing), tracks remedial actions through to completion, and holds review dates per site so annual cycles like these surface before they lapse rather than after. Start free — the Free plan covers two assessments a month, no card required. See pricing or read about who is building it.

Sources

• The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 — SI 2025/797 (legislation.gov.uk)
• Regulation 3 — Meaning of "specified residential building" (legislation.gov.uk)
• Regulation 4 — Meaning of "relevant resident" (legislation.gov.uk)
• Regulation 5 — Identification of relevant residents (legislation.gov.uk)
• Regulation 6 — Person-centred fire risk assessment (legislation.gov.uk)
• Regulation 9 — Review by the responsible person (legislation.gov.uk)
• Regulation 10 — Provision of information to local fire and rescue authority (legislation.gov.uk)
• Regulation 13 — Building emergency evacuation plan (legislation.gov.uk)
• Regulatory Reform (Fire Safety) Order 2005, Article 9 — Risk assessment (legislation.gov.uk)
• Regulatory Reform (Fire Safety) Order 2005, Article 15 — Procedures for serious and imminent danger (legislation.gov.uk)
• The Fire Safety (England) Regulations 2022 — SI 2022/547 (legislation.gov.uk)