Residential PEEPs: What Property Managers Must Do Before April 2026
New fire safety regulations require property managers and building owners to have Personal Emergency Evacuation Plans in place for vulnerable residents — and the clock is ticking.
On the night of the Grenfell Tower fire in June 2017, 72 people died. Of the 37 disabled residents in the building, 15 lost their lives — 41% of disabled occupants. The Grenfell Tower Inquiry's Phase 1 Report was unambiguous: the absence of Personal Emergency Evacuation Plans for residents who could not self-evacuate was a critical failure. Nearly nine years on, Parliament has finally closed that gap.
The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 come into force on 6 April 2026. For property managers, landlords, Residents Management Companies, and Right to Manage Companies across England, this is not a consultation or a pilot, it is a legal duty, enforceable from day one.
The Regulations apply to residential buildings in England that contain two or more sets of domestic premises and fall into one of two categories: buildings that are at least 18 metres high or have at least seven storeys; or buildings over 11 metres in height that operate a simultaneous evacuation strategy — meaning all residents are expected to leave at the same time when the alarm sounds, rather than staying put.
If you manage a building in either category, the duties apply to you. Our strong advice — and that of specialists across the sector — is not to assume you are out of scope. Identify your buildings, check their heights and evacuation strategies, and document your conclusions. The Building Safety Regulator will expect evidence of that process.
The Regulations assign duties to the "Responsible Person" as defined under the Regulatory Reform (Fire Safety) Order 2005. In practice, that typically means the building owner, managing agent, landlord, Residents Management Company, or Right to Manage Company — whoever has control of the common parts and fire safety management of the building.
If you are a managing agent acting on behalf of a freeholder or RMC, it is essential to clarify in your management agreement who holds the Responsible Person status and, therefore, where liability sits. This is not a question to leave vague.
The core duty is straightforward in principle, though demanding in practice. The Responsible Person must identify residents who may need additional support to evacuate — those with mobility, sensory, or cognitive impairments — and take reasonable, proportionate steps to ensure they can get out safely. In regulatory language, these are "relevant residents."
- Offer a Person-Centred Fire Risk Assessment (PCFRA) to every relevant resident, and carry one out if they request it
- Implement mitigating measures that are reasonable and proportionate to enable safe evacuation
- Agree an evacuation approach with the resident, document it in an Emergency Evacuation Statement, and share a copy with them
- Prepare a building-level Emergency Evacuation Plan covering the overall evacuation strategy
- Review PEEPs and resident records at least annually
- Share relevant information securely with the local Fire and Rescue Service
- Handle all resident data in compliance with UK GDPR and the Data Protection Act 2018
One element that has attracted scrutiny from disability advocates deserves particular attention. The duty to identify relevant residents is based on "reasonable endeavours" — not "best endeavours." This distinction has legal weight. It means a property manager who can demonstrate a systematic, documented effort to identify and engage with vulnerable residents will be on solid ground, even if some residents are not identified. That said, this should not be read as licence for minimal effort. Fire and Rescue Services will expect evidence of a genuine, well-documented process.
Here lies one of the more complex operational challenges. A resident can decline to engage — they can refuse the PCFRA, decline to provide information, or choose not to have a PEEP prepared. The law permits this. What it does not permit is a failure to offer the assessment and to make genuine attempts at engagement.
This means resident communication is at the heart of compliance. Letters that go unanswered, intercom calls that receive no response, and residents who actively decline — all of these need to be documented carefully. The record of the outreach is as important as the PEEP itself. If a resident declines to engage, record that, continue to offer support at each annual review, and ensure your building-level evacuation plan accounts for residents whose individual circumstances you may not know.
Data protection is an important thread running through all of this. The personal information gathered for a PEEP — disability status, mobility needs, contact details — is sensitive data under UK GDPR. You will need a clear lawful basis for processing it, appropriate retention policies, and secure storage and sharing protocols, particularly when sharing with the Fire and Rescue Service.
The mitigating measures required under a PEEP — whether that is installing a visual fire alarm in a flat, providing evacuation chairs, or making structural alterations to a refuge area — can carry significant costs. For most private sector buildings, these costs can be recovered through a variable service charge. Leaseholders do have the right to challenge charges at the First-tier Tribunal (Property Chamber) if they believe them unreasonable, so it is worth ensuring that any expenditure is well-documented and proportionate.
For social housing providers, the government has committed to a Residential PEEPs Social Housing Fund, though the details of that fund had not been fully published at the time of writing. If you manage social housing stock, it is worth monitoring developments closely.
Compliance here is not merely about paperwork. It is about genuinely changing how you manage buildings and how you engage with the people who live in them. The property managers and housing associations who have already piloted these approaches have found that structured resident engagement, well-trained staff, and clear internal processes make this very manageable. The common thread in successful implementations is starting early, keeping the resident at the centre of the process, and treating the PEEP as a living document rather than a form filed and forgotten.
The government's toolkit, published alongside the Regulations, contains real-world examples of initiatives already deployed at scale — from light alarms and vibrating pillows for residents with hearing impairments to pull cords, misters, and structured communication plans. It is a genuinely useful resource and worth reading alongside the statutory guidance.
Fire and Rescue Authorities can enforce the Regulations under the Fire Safety Order. For buildings above 18 metres, the Building Safety Regulator adds another layer of oversight, and residents in those buildings can escalate complaints directly to the Regulator. The combination of local FRS enforcement and BSR scrutiny means that the risk of non-compliance is real and multi-directional. We would expect enforcement activity to follow relatively swiftly after April 2026, particularly where evidence suggests that the Responsible Person has not made any systematic attempt to comply.
Directors of RMCs and RTM companies — many of whom are still coming to terms with the duties that building safety legislation has placed on them over the past two years — should be briefed now. They need to understand what is required, the costs involved, and the personal accountability that comes with the Responsible Person role. This is not something that can be quietly delegated and forgotten.
We work with property managers, landlords, and RMC directors across Chester, the North West, and North Wales to navigate exactly these challenges. If your building is in scope and you are not yet sure where to start, get in touch — we can help you build a compliant, practical approach that works for your residents and your management obligations, as part of a professional fire risk assessment.
© Fletcher Risk Management Ltd, March 2026. This article provides general information only and does not constitute legal or regulatory advice. Managing agents and Responsible Persons should seek independent legal advice in relation to their specific obligations.
We support property managers, landlords, and RMC directors across Chester, the North West, and North Wales with practical, compliant fire safety management.
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