The Rise of Fire Safety Enforcement in 2026
Fire safety enforcement across England is entering a more robust phase. Following reforms introduced under the Fire Safety Act 2021 and the Building Safety Act 2022, a further regulatory shift is now confirmed.
The Fire Safety Residential Evacuation Plans Regulations 2025 come into force on 6 April 2026.
This is not a minor administrative update. It places a direct, operational duty on Responsible Persons in high rise residential buildings. Enforcement expectations will increase accordingly.
To get customised support specific to your organisation, please get in touch with us.
The Problem: PEEPs Are Now a Legal Requirement
Under the new Regulations, Responsible Persons must implement Personal Emergency Evacuation Plans for vulnerable residents in residential buildings over 18 metres in height.
The key implications are clear:
• Stay Put strategies can no longer be treated as a universal solution
• Vulnerable residents must be individually assessed
• Evacuation arrangements must be documented and actionable
• Fire Risk Assessments must reflect these new duties
Historically, many high rise residential buildings relied on compartmentation and a Stay Put approach. While compartmentation remains fundamental, regulators now expect contingency planning for those who cannot self evacuate.
The phrase Stay Put is not a defence if a resident cannot escape independently.
Responsible Persons must demonstrate that:
• They have identified residents who may require assistance
• They have assessed evacuation feasibility
• They have documented proportionate and practical measures
• These arrangements are reviewed and maintained
Failure to do so will create enforcement risk and potential liability exposure.
Understanding the Enforcement Climate
The direction of travel is clear. Fire and Rescue Authorities are increasing scrutiny on high rise residential buildings. Post Grenfell enforcement has focused heavily on governance, documentation, and evidence of management control.
National guidance has consistently emphasised that risk information must be resident focused and operationally useful.
In practical terms, this means:
• Fire Risk Assessments must be dynamic documents
• Vulnerable person identification cannot be informal
• Evacuation planning must be structured
• Systems must be auditable
A tick box approach will not withstand inspection.
The Solution: Updating Your Fire Risk Assessment
Your Fire Risk Assessment is the control document that underpins compliance.
To align with the 2025 Regulations, Responsible Persons should review and update their FRA methodology in the following areas.
1. Identify Vulnerable Residents
Introduce a structured process for identifying residents who may require evacuation assistance. This may include mobility impairment, sensory impairment, cognitive conditions, or temporary vulnerability.
Ensure:
• There is a lawful and sensitive data collection process
• Information is kept secure
• Residents understand the purpose of the data collection
The FRA must record how this process operates.
2. Assess Evacuation Capability
For each identified resident, evaluate:
• Ability to self evacuate
• Time to evacuate
• Stair usability
• Refuge provision
• Lift strategy where applicable
This assessment should be risk based and proportionate to building design and fire strategy.
3. Develop and Document PEEPs
Each PEEP must clearly outline:
• The evacuation method
• Required assistance
• Equipment needed
• Roles and responsibilities
Critically, the plan must be realistic. If the building design does not support assisted evacuation, this becomes a strategic issue requiring further risk control measures.
4. Record Control Measures in the FRA
The FRA must explicitly reference:
• The existence of PEEP procedures
• How residents are identified
• How plans are reviewed
• Any residual risk
Enforcement officers will look for alignment between policy and practice.
Integrating PEEPs Into Your Safety Management System
PEEPs must not sit in isolation. They must integrate into your existing Safety Management System.
If you operate under ISO 45001 or ISO 9001 frameworks, this is a governance and process control issue.
Integration should include:
Policy Level
Update your fire safety policy to reflect duties under the 2025 Regulations. Clearly define accountability for identifying vulnerable residents and maintaining PEEPs.
Planning and Risk Management
Incorporate PEEP identification into your risk assessment cycle. This ensures reviews occur when:
• Residents change
• Building layouts change
• Fire strategy changes
Operational Control
Create a documented procedure that governs:
• Resident engagement
• Plan development
• Review frequency
• Secure information handling
This procedure should be version controlled.
Competence and Training
Ensure staff and managing agents understand:
• Their responsibilities under the Regulations
• How to escalate concerns
• How to maintain confidentiality
Training records should evidence competence.
Monitoring and Review
Include PEEP compliance within your internal audit programme. Review:
• Percentage of vulnerable residents assessed
• Timeliness of reviews
• FRA alignment
This demonstrates active management rather than passive compliance.
Common Risk Areas to Address Now
Before April 2026, Responsible Persons should evaluate:
• Whether their current FRA references vulnerable resident planning
• Whether Stay Put is assumed without contingency
• Whether there is a formal data capture process
• Whether documentation can withstand regulatory scrutiny
Delaying preparation increases both compliance risk and reputational risk.
Final Thoughts
The Fire Safety Residential Evacuation Plans Regulations 2025 mark a significant cultural shift in fire safety governance.
The emphasis is no longer solely on building fabric and compartmentation. It is now equally focused on resident capability and evacuation reality.
Responsible Persons who treat this as a documentation exercise will fall short. Those who embed PEEPs into their Fire Risk Assessment and Safety Management System will be better positioned for inspection, enforcement, and most importantly, resident protection.
April 2026 is a compliance deadline. Effective implementation should begin now.
Get a Free Fire Safety Compliance Quote
If your Fire Risk Assessment does not yet address vulnerable residents, documented PEEPs, and structured review controls, now is the time to act.
Whether you manage a single high rise building or a wider residential portfolio, you need clear, defensible compliance before April 2026.
Request a free, no obligation quote today to:
• Review your current FRA against the 2025 Regulations
• Identify compliance gaps in your evacuation planning
• Strengthen integration within your Safety Management System
• Reduce enforcement and liability exposure
Complete the free quote form and take a proactive step towards compliant, resident focused fire safety management.
