Residential PEEPs: what the 2025 Regulations put behind the acronym

A PEEP has been standard practice in workplaces for years. What changed is that high-rise and higher-risk residential buildings now have regulations behind it, and an entitlement that belongs to the resident rather than to the building's procedures.

The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 place duties on building owners and managers in those buildings. Residents with disabilities and impairments are entitled to four things.

• –A person-centred fire risk assessment, considering their individual risks and their ability to evacuate.
• –Consideration of measures that could reasonably and proportionately be introduced to mitigate those risks.
• –A written statement recording what they should do in a fire.
• –Information shared with the local fire and rescue service, so it knows where the most vulnerable residents live.

Why this is difficult in a stay put building

A stay put strategy works because compartmentation holds and because most residents are not asked to move. A person-centred assessment asks a different question: what happens to this resident, in this flat, if they do have to leave.

Answering it honestly sometimes produces an answer the building cannot currently deliver, and that is the point of the exercise rather than a failure of it. The regulations ask what is reasonable and proportionate, which is a judgement that has to be made and recorded rather than avoided.

What they do not do is convert a stay put building into a simultaneous evacuation one. The strategy is a separate question, decided in the fire risk assessment on the building's own evidence.

The identification problem

Every duty here depends on knowing which residents it applies to, and a managing agent generally does not hold that information. It is health data about people who did not ask to be on a list.

• –Residents have to be invited to self-identify, repeatedly and in a form that reaches people who do not read notices.
• –Non-response is not consent and it is not an answer. It has to be recorded as what it is.
• –The information is special category personal data. Holding it, and sharing it with the fire service, needs a lawful basis and a retention position worked out in advance.
• –People's circumstances change. A list collected once is a list that is wrong within a year.

That last one is why this belongs with the building's other dated obligations rather than in a project folder. It is a recurring exercise with a review cycle, not a survey.

What to put in place

• –Establish which of your buildings are in scope rather than assuming — the duties attach to high-rise and higher-risk residential buildings, not to all of them.
• –Set up the self-identification route and record every invitation and every response, including the silences.
• –Diary the person-centred assessments on a review cycle, with the same rigour as a fire risk assessment review.
• –Agree the route for sharing information with the fire and rescue service before you need it, not during an incident.
• –Keep the written statements with the resident's record and in the building file, because both will be asked for.
• –Write down where a reasonable and proportionate measure was considered and not taken, with the reasoning. That is the record that matters most.

Check the current regulations and guidance below before designing a process. This is recent law, the guidance has been revised, and the detail of who is in scope is the part worth reading in the original.