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Knocking on the Door: The Real-World Impact of the New RPEEPs Regulation

Written by Elspeth Grant | 20/08/2025


The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 are a big step forward in how we think about the safety of disabled and vulnerable people living in high-rise and other shared buildings. They were laid before Parliament on 4 July 2025, will officially become law on 6 April 2026 and apply to buildings in England only.

The Grenfell Tower Inquiry Recommendation

These Regulations are a response, in part, to Recommendation 33.22 from Phase 1 of the Grenfell Tower Inquiry, which stated:

"That the owner and manager of every high-rise residential building be required by law to prepare personal emergency evacuation plans for all residents whose ability to self-evacuate may be compromised."

This recommendation was aimed at ensuring that residents with mobility impairments or other vulnerabilities are not left behind in an emergency. The new Regulations attempt to address the recommendation by introducing a new layer of fire safety with Person-Centred Fire Risk Assessments (PcFRAs) and an Emergency Evacuation Statement, which is essentially a Personal Emergency Evacuation Pan (PEEP).

Where do the new Regulations apply?

Within England, the Regulations cover all buildings that:

  • Contain two or more sets of domestic premises; and
  • Are either:
  1. a) At least 18 metres above ground level or have at least seven storeys; or
  2. b) More than 11 metres in height with simultaneous evacuation strategies in place.

These buildings fall under new duties concerning Residential Personal Emergency Evacuation Plans (PEEPs), which must be created, maintained, and reviewed for residents who may need help evacuating during a fire. Regulation 5 also requires the Responsible Person to make reasonable efforts to identify relevant residents, not just those who self-identify.

The Regulation Impact Assessment (Table 1.4) estimates 28.3% of social housing and 16.4% of private housing residents are evacuation impaired. This helps housing providers to estimate how many residents of in-scope buildings need a PcFRA and a PEEP plus how many staff must be trained to develop them.

A Legal Grey Area: Going Inside the Front Door

The Fire Safety (England) Regulations 2022, along with the new 2025 updates, are built on the foundations of the Regulatory Reform (Fire Safety) Order 2005. But here’s where it gets tricky: Article 6 of that Order specifically says it doesn’t apply to domestic premises.

Even so, the new Regulations now expect RPs to develop PcFRAs, and that means going into people’s homes to check for and resolve risks.

That puts everyone in a bit of a legal grey zone. What happens if a resident refuses access? Or doesn’t want to take part in the assessment? There’s no clear route for enforcement, yet RPs still carry the responsibility. That raises tough questions about consent, liability, and what can be done when residents say no.

It’s an area that’s likely to create real-world challenges — and it’s one RPs need to navigate carefully.

The heart of the matter: Disabled residents and reasonable adjustments

One of the more controversial aspects of the new Regulations is around cost. Regulation 7(3) states that the Responsible Person (RP) is not required to implement a mitigating measure, such as installing fire safety equipment, unless the resident agrees to pay for it.

This raises several serious questions. Under the Equality Act 2010, specifically Section 20(7), a person subject to a duty to make reasonable adjustments cannot pass the cost of those adjustments on to the disabled person. So, does Regulation 7(3) conflict with this? It certainly appears to, and it’s something that needs to be clarified by the Equality & Human Rights Commission (EHRC) in due course.

What the Regulation means in practice

A PEEP is straightforward; it’s basically a written plan that explains how someone will evacuate the building in an emergency.

A PcFRA is a different story, it goes way beyond just planning. It’s about spotting real, individual risks in someone’s flat and doing something about them. That could mean installing a water mist system, adding extra electrical sockets to reduce the need for extension leads, or whatever’s needed to make that person safer in their own home.

All of this comes with a price tag, and often a steep one. So compared to a PEEP, a PcFRA is much more complex and expensive to put in place.

Let’s say a building manager (the RP) carries out a PcFRA and finds a hazard, perhaps a mobility scooter being charged or medical equipment is overloading sockets. That hazard must be mitigated but if the resident refuses or cannot afford the necessary changes, what happens?

Now the RP is aware of a fire risk that hasn’t been resolved. This has serious implications for the RP, and by extension the building owner, who could face legal and financial consequences, if a fire were to occur and someone was injured or worse. It might also affect their insurance as insurers don’t take kindly to known, unmitigated risks, especially if those risks were identified in a formal assessment but not resolved.

The problem with self-purchased equipment

Another scenario is where a resident, keen to be independent, purchases their own assisted evacuation device (AED) from the internet, perhaps even second-hand. On the surface, that might seem like a positive step that reduces costs for the RP. But what if the device is not suitable for the escape route? What if it blocks corridors or stairwells during an evacuation? What if it malfunctions? If the device blocks a means of escape for others, that’s not just a risk for the disabled resident, it’s a danger to everyone in the building.

Worse, who maintains it? Most building managers aren’t going to service a resident-owned device. That leaves the resident responsible, which is a big ask, particularly if they’re vulnerable or have limited mobility or support.

Ongoing responsibilities

The new regulations are clear: fire safety isn’t something you can just tick off and forget about. For RPs, it’s now an ongoing activity, especially when it comes to reviewing PEEPs, the PcFRA and the emergency evacuation statement.

The regulation states reviews must happen:

  • At least once a year, either 12 months after the evacuation statement is first recorded, or (if no statement was agreed) 12 months after the PcFRA was completed.
  • Sooner, if there’s a reason to think the information’s out of date, for instance if the building layout changes.
  • Whenever a relevant resident reasonably asks for it, say, if their health condition changes or worsens.

And here’s the reality: staying on top of all this comes with a significant increase in costs. More assessments, more updates, and more coordination all add up.

Train Your Staff

With the new Regulations, fire safety responsibilities are more demanding, and that means your staff need the right training. Under Article 21 of the Fire Safety Order, anyone involved in fire safety duties must be properly trained and competent to do the job.

Staff need accredited training as it is about giving them the confidence and knowledge to assess real risks and recommend meaningful solutions, especially for residents who need the most support. That includes those carrying out potentially thousands of PcFRAs and PEEPs in your in-scope buildings.

All of this brings a significant increase in cost, not just in terms of training, but also time, staffing, and ongoing development. But it’s essential. Without properly trained people doing this work, the whole process risks becoming a box-ticking exercise, and that’s not what these changes are about.

The goal is safer outcomes, not just more paperwork. And that starts with competent, confident people on the ground.

What needs to happen next

There’s now a lot to work through in preparation for when the new Regulation becomes a legal requirement in April 2026. These are some of the practical steps that Responsible Persons, building owners, and housing providers should consider now:

  1. Start mapping your residents: Regulation 5 requires you to make reasonable efforts to identify relevant residents who may need a PcFRA and PEEP, not just rely on self-identification. Start by identifying all sources of information across your organisations
  2. Train your staff: Start staff training programmes now in preparation for rolling out PcFRAs and PEEPs.
  3. Set a review calendar: It’s easy to lose track of annual reviews. Set reminders, use scheduling tools, and ensure someone is accountable for follow-up.
  4. Engage with residents: Communication is key. Residents need to know what’s happening, why it matters, and what their options are. Trust is critical when discussing risks and responsibilities.
  5. Get legal and insurance advice: Especially around the intersection of the Equality Act and Regulation 7(3), and to understand the impact of unmitigated risks on your policies.

A Final Thought

These new Regulations are more than just policy changes and raise complex issues but they’re a response to the hard lessons learned from the Grenfell Tower Inquiry. At their heart is a simple but powerful principle: no one should be left behind during a fire.

But turning that principle into reality isn’t easy. The challenges are real, and the path forward is complicated. Fires don’t wait for paperwork to be filed or budgets to be approved and people’s safety shouldn’t depend on their ability to pay or navigate complex systems.

That’s why it’s now more important than ever for everyone involved, housing providers, fire services, residents, and regulators to make these changes truly meaningful will take collaboration, care, and a shared commitment to fairness. Because in the end, fire safety is about people, and everyone deserves to feel safe in their home.