Residential Evacuation Plans: The 6 April 2026 Deadline

On 6 April 2026 the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 came into force, and the duty they create sits on the Responsible Person — typically the building owner or manager. In a mixed-use development that means you. Not the managing agent's call centre, not the resident who never returned the form. If a fire safety audit finds no person-centred fire risk assessment for a resident who cannot self-evacuate, the enforcement conversation starts with the name on the Responsible Person record.

That is the consequence. The rest of this article is what the regulation actually requires, where mixed-use buildings tend to fail it, and what an inspector will ask to see.

The duty applies to more buildings than most managers assume

The regulations apply in England only, and they catch two categories of building. The first is any building containing two or more sets of domestic premises that is at least 18 metres above ground level or has at least seven storeys. The second is any building more than 11 metres in height above ground level that has a simultaneous evacuation strategy in place — meaning the Responsible Person has determined that all residents should leave on a fire alarm rather than stay put.

Mixed-use developments sit awkwardly across both tests. A residential block above a retail parade may be 14 metres to the roof but only six storeys, so it fails the first test — until someone confirms a simultaneous evacuation strategy, at which point the 11-metre threshold brings it in. The same building can move in and out of scope depending on a fire strategy decision made years ago and never revisited.

Your first practical task is a scope register: for every building you run, record the height, the storey count, and the evacuation strategy as documented. If you cannot state the strategy for a building, you cannot state whether the regulations apply to it. The Residential PEEPs factsheet sets out the scope tests in the government's own words.

What the Responsible Person must actually produce

The regulations introduce a process called Residential Personal Emergency Evacuation Plans, or Residential PEEPs. The Responsible Person must use reasonable endeavours to identify residents whose ability to evacuate without assistance is affected by a physical or cognitive impairment — reduced mobility, a sight or hearing impairment, a long-term health condition, or a cognitive condition affecting awareness or decision making.

For each relevant resident, the Responsible Person must offer a person-centred fire risk assessment. This is a conversation between the Responsible Person and the resident, and it must be carried out if the resident requests one. The assessment considers the resident's specific risks and the measures that could be reasonably and proportionately introduced to mitigate them.

Where the resident agrees, the outcome is recorded in an emergency evacuation statement — a written record of what that resident should do in a fire. A copy goes to the resident. Minimal prescribed information may be shared with the local Fire and Rescue Service, but only with the resident's explicit consent, and that information is limited to flat number, floor number, a basic indication of the assistance likely required, and whether an emergency evacuation statement exists. No medical or personal detail goes into the Secure Information Box.

Separately, the Responsible Person must prepare a building-wide emergency evacuation plan, share it with the Fire and Rescue Service, and keep it under review. That plan should include the instructions given to residents, whether there are any relevant residents, and any additional safety features such as an evacuation alert system. The Residential PEEPs guidance for Responsible Persons runs to 26 pages and includes a toolkit with worked examples. If your portfolio also faces the 2026 evacuation lift mandate, our article on evacuation lifts for new residential towers over 18m is worth reading alongside this because the two duties interact on assisted evacuation.

The 12-month review clock, and why it resets early

Both the person-centred assessments and the building-wide plan must be reviewed at least every 12 months. The review must also happen earlier if something changes — a resident's condition, a new relevant resident, a change to the building's evacuation strategy — or at a relevant resident's reasonable request.

This is where mixed-use portfolios quietly fall behind. A single review date per building is easy to hold. What is harder is the trigger-based review: the resident who moves in during month three, the resident whose mobility changes after surgery, the tenancy change that brings a new relevant resident into a block that was reviewed last month. Each of those resets the clock for that individual, and each needs a record.

Build the review as a rolling register rather than an annual event. One line per relevant resident, with the date of the last person-centred assessment, the date of the last emergency evacuation statement, and the next review date. When an inspector asks, you produce the register, not a folder of certificates.

What enforcement looks like in practice

The Fire and Rescue Authority is the enforcing authority for these buildings under the Fire Safety Order, and compliance is checked during fire safety audits. Where evidence of non-compliance is found, enforcement action follows in line with the authority's statutory duties. The Cheshire Fire & Rescue Service summary of the 2025 regulations is a useful plain-English reference for what auditors will look for.

Two points matter for how you prepare. First, participation is voluntary for residents — they can decline the assessment, decline the statement, and withdraw consent to information sharing at any time. Your obligation is to use reasonable endeavours to identify and offer, and to record that you did. A resident who declines is not a gap in your compliance; a resident you never asked is.

Second, the cost of mitigating measures sits with the Responsible Person, and the government's guidance covers how that is approached. Reasonable and proportionate is the test, not gold-plated. A ground-floor resident with a hearing impairment may need nothing more than a linked alarm; a resident on the ninth floor with reduced mobility may need a documented assisted-evacuation arrangement and a named member of staff. The assessment decides which.

Your 60-second self-check

• Could you produce, today, a scope register showing the height, storey count and evacuation strategy for every building in your portfolio?
• Could you produce the current person-centred fire risk assessment and emergency evacuation statement for every relevant resident, with the date of the last review?
• Could you show that the building-wide evacuation plan has been shared with the Fire and Rescue Service and reviewed within the last 12 months?

If any of those three would take you longer than 60 seconds to answer, you are carrying compliance exposure you cannot currently quantify. The free 5-minute Director's Risk Check gives you a control score for the portfolio and the breach exposure with official sources attached, so you know where you stand before a director or insurer requests it. You can access the check here and send it to a colleague to answer if the records sit with them.

Herman's verdict

The regulation is not the hard part. The hard part is the resident who declines the assessment, the one who moves in mid-cycle, and the one whose needs change without anyone telling you. A register that only updates once a year will look compliant on the day it is signed and be wrong within a month. Build the rolling record, or the audit will build it for you.

— Herman