Navigating Residential Personal Emergency Evacuation Plans (RPEEPs)

In our recent fire safety webinar, ‘2026 Fire Safety Updates: RPEEPs, BS 9792, and Approved Document B’, we received a variety of questions covering Residential Personal Emergency Evacuation Plans (RPEEPs), Person-Centred Fire Risk Assessments (PCFRAs), and wider building safety regulations.

This blog will share these questions and our expert answers to help you navigate the  Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 which is coming into force on 6th April 2026. 

To catch up on the webinar and insights, you can access the full session on demand here.

Q: Who is responsible for completing RPEEPs and PCFRAs when a building is sublet?  

A: The legal duty always sits with the responsible person under the Regulatory Reform (Fire Safety) Order 2005, typically the accountable person, building owner, or head leaseholder with control of the common parts. This does not automatically transfer just because units are sublet. That said, the subletting organisation may still have a role to play, particularly if it is in direct contact with the resident and manages the tenancy day-to-day. They may be best placed to identify vulnerabilities and assist with completing PCFRAs. The key is clear communication between both parties, with responsibilities documented in writing, never assumed.

Webinar timestamp – 28:53

Q: What competencies does someone need to complete an RPEEP, and is there any regulation around this? 

A: There is currently no prescribed qualification in law, but the person must be competent. This means having a robust understanding of the building's fire strategy, escape routes, fire compartmentation, and whether the building operates a stay-put or simultaneous evacuation policy.

They also need the ability to assess mobility and cognitive impairments. While not yet mandatory, a NEBOSH qualification or background in fire risk assessment is considered good practice. Organisations should think carefully about who is undertaking this work and be confident they have the necessary knowledge to do so.

Webinar timestamp – 31:41

Q: If a resident has an impairment but says they can evacuate independently, do they still need an RPEEP?

A: Not necessarily. The duty is triggered by an inability to self-evacuate, not simply by the existence of an impairment. If you are satisfied that someone can react to an alarm, understand what's happening, and exit the building without assistance, an RPEEP would not be required. However, you must still document your decision-making process. Record that you asked the question, assessed the capability, and concluded that an RPEEP was not needed. Circumstances change, and when you come to reassess in six or twelve months, having that audit trail is essential.

Webinar timestamp – 33:30

Q: What is the expectation for a resident without mobility who requires an RPEEP?

A: The expectation is a thorough PCFRA that considers both the individual's needs and the building's risks, with reasonable and proportionate mitigations put in place. The mitigation has to be reasonable; not every mitigation will be feasible, and cost proportionality matters. In some cases, if the risks cannot be adequately mitigated, a managed move may need to be considered. Every resident should receive a fair, equal PCFRA process, with a clear evacuation statement, and if at any point they wish to withdraw consent, the process stops there.

Webinar time stamp – 36:09

Q: Who bears the cost of any mitigations that need to be put in place?

A: This is assessed case by case. The regulations are broad on this point. Costs may fall to the responsible person, the resident, or, in some cases, be spread across all residents in the building, particularly where a mitigation, such as a fire alarm upgrade or sprinkler system, benefits everyone. Leaseholder protections remain in place throughout, so any cost-sharing approach must not impinge on leaseholder rights.

Webinar timestamp – 37:58

Q: How do these regulations apply to leaseholders?

A: Leaseholder protections apply in the same way as they do across wider building safety legislation. The regulations don't create a separate framework for leaseholders; the same approach, the same rights, and the same cost protections apply.

Webinar timestamp – 39:01

Q: What is the position when a managing agent is involved?

A: It comes back to the same question: who is the responsible person? If the managing agent holds that role, as defined under Article 3 of the Regulatory Reform (Fire Safety) Order 2005, then the duty to comply with these regulations sits with them. How they go about meeting those requirements is an organisational decision; there is no single prescribed approach. What matters is that they can offer PCFRAs, have the necessary back-of-house processes in place, implement reasonable mitigations, produce evacuation statements, and share those with the local fire service.

Webinar timestamp – 39:35

Q: Will evacuation chairs need to be installed as part of the RPEEP process?

A: Not automatically. Installing an evacuation chair is only appropriate if the PCFRA or evacuation statement identifies a clear need for one. Crucially, for an evacuation chair to be effective, there must be trained staff available to use it; if there is no staff presence overnight, for example, a chair alone will not provide a reliable means of escape. Mitigations must reflect what a resident actually needs, not a one-size-fits-all approach.

Webinar timestamp – 41:14

Q: Are there regulations around battery recycling pods or e-bikes stored in communal areas?

A: There is no specific regulation covering this directly, but the principle is clear: communal areas should be kept sterile. Fire risk assessment guidance is built around the assumption that a fire is most likely to start within a dwelling or plant area, not a communal space. Storing items like e-bikes or charging equipment in communal areas is strongly inadvisable. The NFCC has published specific guidance on mobility scooters and charging that is worth consulting.

Webinar timestamp – 42:09

Q: Do high-rise buildings still require A2-rated or better cladding, and does this extend to mid-rise buildings?

A: Yes, to both. Buildings of 18 metres and above have specific requirements on external wall materials. These requirements also already apply to buildings over 11 metres, with additional considerations for buildings below that threshold depending on things like relevant boundaries.

If you are unsure whether your building is a higher-risk building, join our upcoming free live webinar, ‘Building Safety: Gateways, Golden Thread, and Building Heights’, on Wednesday 18^th March at 12pm for expert insights into how to accurately measure your buildings.

Webinar timestamp – 43:06

Q: Isn't a fire risk assessment just a snapshot inspection? How can it properly evaluate risk without reviewing wider information like cladding assessments and servicing records?

A: It is true that a Fire Risk Assessment (FRA) will always capture the building as it is on the day; a surveyor cannot account for housekeeping issues that appear and disappear, for example. This is why it is so important to make as much information available to the assessor in advance.

BS 9792 sets out a consistent framework for what a thorough FRA should include, covering things like external walls and cladding. If your current FRA is falling short of what BS 9792 requires, it's worth reviewing your approach and your assessor.

If you’re looking for a competent and experienced fire risk assessor, get in touch with our team of experts who can provide you with a tailored programme of FRAs.

Webinar timestamp – 43:46

Q: Is there a competency framework for fire risk assessors, similar to what we have seen in building control?

A: Yes, it arrived relatively recently. BS 8674 was published in August 2025 and provides a formal competency framework for fire risk assessors within a British Standard, making it significantly more robust than previous industry guidance. Prior to this, many practitioners worked to the Fire Sector Federation's competency framework, but BS 8674 is now what everyone in the industry should be working to.

Webinar timestamp – 45:14

Q: Do properties with vulnerable residents fall under the RPEEP regulations even in low-rise buildings?

A: No, the regulations apply specifically to buildings of 18 metres or above (or seven or more storeys) containing at least two residential premises, and to buildings between 11 and 18 metres (about five or six storeys) with two or more domestic premises, but only where a simultaneous evacuation strategy is in place. That last point is critical: not every 11–18 metre building is captured, only those with a simultaneous evacuation strategy. Buildings outside these definitions are out of scope. That said, there is nothing to stop an organisation applying the same processes to out-of-scope buildings as a matter of best practice or ethical duty of care.

Webinar timestamp – 46:07

Q: Should RPEEPs be recorded on the golden thread for higher-risk buildings?

A: Yes, RPEEPs form part of the golden thread. The golden thread covers anything relevant to the fire and structural safety of a building and its residents. There is no prescribed list of documents to be included in the golden thread, but RPEEPs clearly fall within scope. Having this on your golden thread is as important as having this within your CRM system or PEEP register, providing an evidential base that can be shared with the Building Safety Regulator if required.

Webinar timestamp – 47:43

Q: How do we engage residents in the building's fire evacuation strategy if they haven't given consent?

A: You should always be engaging with your residents. The building's fire evacuation strategy, whether that is stay-put, simultaneous, or phased evacuation, does not require resident consent. It is information you provide to all residents, ideally at the start of a tenancy and at least annually thereafter, alongside fire door information as required under the Fire Safety (England) Regulations 2022.

Consent only becomes relevant when a resident is asked to share personal information as part of the RPEEP process. If consent is withdrawn for that, the RPEEP process stops, but sharing the building's general evacuation strategy continues regardless.

Webinar timestamp – 48:58

Q: How often do you need to re-engage residents and seek fresh consent for RPEEPs?

A: At a minimum, every 12 months from the date the evacuation statement was created, or from when the PCFRA was created if no evacuation statement exists. But the 12-month mark is not the only trigger. You should also review whenever you become aware of any change in a resident's circumstances, for example, a worsening condition, a recovery from a temporary impairment, or a change in the building itself. Consent must be reconfirmed at each review, as it underpins the robustness of the whole process.

Webinar timestamp – 50:10

Q: Which comes first: the PCFRA or the PEEP?

A: The PCFRA must come first. The findings of the PCFRA directly inform the PEEP, so attempting it the other way around would likely result in having to revise the PEEP anyway once the PCFRA is completed.

Webinar timestamp – 51:53

Q: Will the Fire and Rescue Service actually be able to use RPEEP information in a real incident?

A: That is largely down to your engagement with your local Fire and Rescue Service. Your duty under the regulations is to comply and share the information; how the service uses it is their operational matter. That said, proactive engagement with the Fire and Rescue Service is strongly encouraged: find out how they want to receive the information, whether they want to be notified of changes, and how it feeds into their incident planning.

It is also worth noting that the Fire Safety (England) Regulations 2022 already require information on residents needing assistance to be passed to the Fire and Rescue Service. However, the Fire and Rescue Service should not be treated as the primary evacuation solution. Relying on them to evacuate residents is not a substitute for a robust evacuation statement.

Webinar timestamp – 52:20

Q: Is there a template for an evacuation statement?

A: There is no prescribed template; the evacuation statement is bespoke to each individual. There are, however, a number of pro formas available for the PCFRA element, and working through one of those will likely help shape how you structure the evacuation statement that follows.

Webinar timestamp – 54:14

Q: Is BS 9792 free to access?

A: It is not freely available, but members of the IFSM can access it through the member resource library. Otherwise, it can be purchased through the BSI.

Webinar timestamp – 54:43

Q: Is BS 9792 relating to fire risk assessments of individual dwellings, communal areas, or is it relevant to PCFRAs?

A: BS 9792 applies to the areas of a building subject to an FRA under the Regulatory Reform (Fire Safety) Order 2005. This is where there is more than one dwelling that shares communal areas. In some cases, such as supported housing operating as a single dwelling, the Fire Safety Order may also apply. The scope depends on the building type and whether the Fire Safety Order applies.

Webinar timestamp – 55:05

Q: What happens if a PEEP statement cannot demonstrate that a resident can be successfully assisted to evacuate?

A: If a resident is unable to evacuate independently or be assisted to a place of safety through any practical means, the likely outcome is that their evacuation statement would direct them to remain within their flat, which under normal circumstances acts as a protected compartment, until they can be rescued by the Fire and Rescue Service, who would have the relevant information either in advance or via on-site information points.

However, this situation should also prompt an organisational conversation about whether the property remains suitable for that resident. If circumstances have changed to the point where evacuation is genuinely unachievable, a managed move to more appropriate housing may need to be considered.

Webinar timestamp – 55:47

Q: What is the difference between a PCFRA and a Fire Service Safe and Well check?

A: A PCFRA is carried out by the housing provider. This is your assessment of the risks specific to an individual resident and your responsibility to put appropriate mitigations in place. A Safe and Well check is a service delivered by the Fire and Rescue Service and sits outside the housing provider's obligations. They are not interchangeable, and housing providers with residents who require additional support must ensure a PCFRA is in place regardless of whether a Safe and Well check has taken place.

Webinar timestamp – 58:07

If these answers helped you identify any gaps within your understanding of RPEEPs, PCFRAs, or your general fire safety approach, reach out to get in touch with our experts to ensure you are prepared for the upcoming regulation changes coming in April 2026.