The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 (Regulations) introduce new legal duties requiring certain residential buildings to prepare Personal Emergency Evacuation Plans (PEEPs) and building-wide evacuation strategies.

The measures aim to ensure that people who may struggle to escape unaided during a fire, such as those with mobility, sensory, or cognitive impairments (Vulnerable Guests) are properly identified and supported.

These Regulations form part of the Government’s wider post-Grenfell reforms, responding to the Inquiry’s finding that all residents, including those with additional needs, must have safe, effective evacuation arrangements, not just generic fire procedures.

Which buildings are in scope?

The Regulations apply to multi-occupied residential buildings in England that meet either of the following criteria:

  • The building is 18 metres or higher, or has 7 or more storeys; or
  • The building is 11 metres or higher and operates a simultaneous evacuation strategy (where all residents evacuate together rather than following a ‘stay put’ approach).

Blocks of short-term rentals (STRs) may fall within scope if they meet these height or evacuation conditions.

Core duties under the Regulations

From 6 April 2026, the Responsible Person (RP) for an in-scope building must ensure that:

  1. Vulnerable guests are identified: take reasonable steps to identify residents or guests who may need assistance to evacuate.
  2. Person-Centred Fire Risk Assessments (PCFRAs): offer Vulnerable Guests an assessment of their individual needs, covering potential aids or assistance measures.
  3. Record risk-reduction measures: work collaboratively with each Vulnerable Guest to agree reasonable adjustments (e.g. visual alarms, evacuation chairs, or improved signage).
  4. Prepare an evacuation statement: where the Vulnerable Guest consents, prepare a personalised evacuation plan outlining how they will raise the alarm, where to go, and who will assist them. This must be provided in accessible formats.
  5. Share information with the Fire & Rescue Service (FRS):
  • With the guest’s consent, share essential details such as flat number and assistance requirements to aid emergency responders.
  • The RP must also keep a paper copy of each PEEP on site for use in an emergency.
  1. Maintain a building-wide evacuation plan: create and regularly review a plan covering alarms, systems, and evacuation procedures for all residents.
  2. Review regularly: update PCFRAs and evacuation plans at least annually, or sooner if a resident’s circumstances change.

The Responsible Person (RP)

The RP is the individual or organisation with control over a building’s common parts, typically the freeholder, head leaseholder, or managing agent. If an STR operator only has leases or rights to let units (under a management agreement or otherwise) and is not responsible for the common areas.

The RP is legally accountable for compliance under both the Regulatory Reform (Fire Safety) Order 2005 and the new Regulations. These obligations cannot be contracted out of.

Pre-implementation requirements

By 6 April 2026, every RP for an in-scope building must have:

  1. A process to identify residents who may require help evacuating;
  2. A procedure to offer and record PCFRAs;
  3. A written evacuation plan for each consenting Vulnerable Guest;
  4. A building-wide evacuation plan shared with the local FRS; and
  5. Records, review systems, and trained staff familiar with these duties.

Implications for STR operators

The requirements apply differently depending on the STR operator’s relationship to the property.

If an STR operator owns or controls the common parts within an in-scope building, they will be treated as the RP and must comply directly with all requirements of the Regulations. Where STR operators rent one or more units within a multi-occupied block, the building owner or managing agent will normally be the RP. However, STR operators must cooperate with the RP on evacuation planning and fire safety matters.

In practice, STR operators are best placed to identify whether a guest may be a Vulnerable Guest. Before check-in, operators should:

  • Ask whether the guest considers themselves a Vulnerable Guest; and
  • Obtain explicit, GDPR-compliant written consent if the guest agrees for their details to be shared with the RP and/or the FRS so a PCFRA can be arranged.

If consent is not given, the STR operator cannot lawfully share the guest’s personal information.

It is best practice for operators to maintain records confirming for every guest. This record-keeping will demonstrate due diligence in the event of inspection or incident.

Delegation and shared responsibility

While RPs can delegate certain functions (e.g. conducting PCFRAs or drafting evacuation plans) to competent contractors, legal responsibility always remains with the RP.

In buildings with multiple RPs, such as a freeholder, leaseholder, and managing agent, each party must take all reasonable steps to cooperate with the others.

RPs should:

  • Instruct only accredited fire safety professionals (e.g. FRACS, IFE, or Fire Risk Assessor Register members);
  • Periodically review contractor performance and documentation;
  • Keep comprehensive records of contractor vetting, communications, and resident consents; and
  • Consider requiring contractors to indemnify the RP in case of enforcement or claims.

Data protection obligations

The Regulations do not override data protection law. Whether or not an STR operator is the RP, guest data must not be shared with building managers, RPs, or the FRS without explicit written consent.

Where consent is withheld, the STR operator should maintain a simple record noting that consent was not provided. This demonstrates compliance with GDPR obligations while protecting guest privacy.

Enforcement and penalties

Local Fire & Rescue Services have inspection and enforcement powers under the Regulations. Non-compliance may result in enforcement notices; financial penalties or prosecution. In addition, failure to comply may affect insurance coverage if an RP or operator is found to have disregarded fire safety duties or building evacuation procedures.

The 2025 Regulations represent a major shift in residential fire safety compliance, requiring individual evacuation planning for those unable to self-evacuate.

For STR operators, the key takeaway is that responsibility cannot be ignored or assumed to rest solely with the building owner. STR operators must cooperate actively with RPs, manage guest consent processes carefully, and maintain clear records.

Buildings owners and managing agents should act now to identify affected properties, engage competent fire safety professionals, and establish systems for resident engagement and ongoing compliance.

If you have questions or concerns about PEEPS, please contact Nadia Milligan.