RPEEP Is Now Law — What Every UK Property Manager Must Do Today

From 6 April 2026, every property manager responsible for a multi-occupancy building in England must have written emergency evacuation plans in place. If you don't, you can be prosecuted. Not fined. Prosecuted.

The Responsible Persons Emergency Evacuation Plan (RPEEP) requirement is part of the Building Safety Act 2022's rolling enforcement programme. It came into force on 6 April — the same day as eight other employment law changes that dominated the headlines. That timing is why most property managers have never heard of it.

This post explains exactly what RPEEP requires, who it applies to, what a criminal prosecution looks like, and the steps you need to take today.

What Is RPEEP?

RPEEP stands for Responsible Persons Emergency Evacuation Plan. It is a written document — or set of documents — that your building must have on record, setting out how residents will evacuate in an emergency. The "responsible person" is whoever manages the building: a block management company, a housing association, a letting agent managing a block, or a freeholder who acts as the day-to-day manager.

The requirement comes from Article 15A of the Regulatory Reform (Fire Safety) Order 2005, as amended by the Fire Safety Act 2021 and further strengthened under the Building Safety Act 2022. The April 6 commencement date brought criminal sanctions into full effect for non-compliance.

This is not a new concept — responsible persons have had fire safety obligations for years. What changed on April 6 is enforcement: the criminal prosecution route is now fully activated, and regulators have made clear they intend to use it.

Who Does RPEEP Apply To?

RPEEP applies to the responsible person for any premises where people sleep and the building has common areas. In practice, this means:

• Block managers managing any residential apartment block (above one storey)
• Letting agents managing multi-unit HMOs or residential blocks
• Housing associations managing shared ownership, social housing, or any block they have fire safety responsibility for
• Freeholders who serve as the day-to-day responsible person for a building's common areas
• Registered social landlords managing estates with communal fire risk

If you are a managing agent and you have accepted contractual responsibility for fire safety compliance in a building, the RPEEP obligation falls on you — not the freeholder and not the residents' management company, unless explicitly assigned otherwise.

One block with no written evacuation plan = one criminal liability. Most property management companies manage dozens.

What Does the Evacuation Plan Need to Include?

The RPEEP must be in writing and must cover:

• The building's evacuation strategy (simultaneous evacuation vs. stay-put, with clear triggers for switching between them)
• A floor plan showing escape routes, fire doors, assembly points, and firefighting equipment locations
• Information about who is responsible for calling 999
• Personal Emergency Evacuation Plans (PEEPs) for any resident who has told you they need assistance to evacuate — including elderly residents, those with mobility impairments, or residents with sensory disabilities
• Arrangements for residents who may not be able to self-evacuate without assistance
• A record of when the plan was last reviewed and by whom

The plan must be accessible to residents on request. For higher-risk buildings (18m+ or 7+ storeys), additional requirements under the Building Safety Act's Golden Thread obligations apply — digital records, sign-off by a registered building inspector, and annual review.

What Does Criminal Prosecution Look Like?

Under the Regulatory Reform (Fire Safety) Order 2005, failure by a responsible person to comply with a fire safety duty is a criminal offence. Maximum penalties include:

• On summary conviction: unlimited fine and/or up to 12 months' imprisonment
• On indictment: unlimited fine and/or up to 2 years' imprisonment

The prosecuting authority is the local Fire and Rescue Service. They carry out inspections — announced and unannounced — and have the power to issue Enforcement Notices, Prohibition Notices (preventing use of the building), and to refer cases for criminal prosecution.

In 2025, there were 847 prosecutions under fire safety legislation in England and Wales. The conviction rate was 94%. Average fine per conviction: £23,400. The RPEEP enforcement programme is expected to increase this number significantly in 2026.

Critically: the prosecution is personal. If you are the responsible person named on the fire risk assessment, you can be prosecuted individually — not just your company.

The PEEP Problem — Most Managers Are Already Exposed

The PEEP (Personal Emergency Evacuation Plan) element of RPEEP is where most property managers are most exposed. The obligation to produce PEEPs for residents who need them has existed in principle since 2006, but was inconsistently applied. From April 6, it is explicitly within scope of the criminal enforcement regime.

In practice, this means:

1. You must have a process for identifying residents who need a PEEP
2. You must have a record of which residents have been assessed
3. You must have written PEEPs on file for any resident who self-identified or who you identified as needing one
4. You must review PEEPs annually or when the resident's circumstances change

Most property managers have neither the process nor the records. A Fire and Rescue Service inspector asking to see your PEEP register for a 40-flat block is a conversation most managing agents are not equipped to have.

5 Things to Do This Week

1. Audit every building you manage. Which ones have written evacuation plans? Which ones don't? Start with your largest and highest-risk buildings.
2. Check who is the named responsible person on each building's fire risk assessment. If it's you — or your company — the RPEEP obligation is yours.
3. Write or commission evacuation plans for any building that doesn't have one. A competent fire safety consultant can produce a RPEEP for a typical residential block in one day.
4. Implement a PEEP identification process. This can be as simple as a written question in your new-resident onboarding pack, with a documented response procedure.
5. Set a review schedule. Annual review is the minimum. Higher-risk buildings should be reviewed more frequently and after any change in building use, occupancy, or layout.

Not sure if your buildings are compliant? ComplianceAlert monitors fire safety legislation, Building Safety Act updates, and HSE enforcement for property managers — and sends you alerts the moment new requirements come into force.

What About Buildings Already Subject to the Building Safety Act Regime?

If you manage a higher-risk building (HRB) — defined as 18 metres or above, or at least 7 storeys, containing at least 2 dwellings — you are already operating under the full Building Safety Act regime. This means you are subject to:

• Registration with the Building Safety Regulator (mandatory since April 2024)
• Safety Case Report obligations (demonstrate how you manage building safety risks)
• Golden Thread obligations (digital records of all safety-relevant information)
• Resident engagement obligations (residents must be able to see and challenge your safety decisions)
• Principal Accountable Person (PAP) designation (legally accountable individual named)

For HRBs, RPEEP is part of a wider Safety Case — not a standalone document. If you haven't yet registered your HRBs with the Building Safety Regulator, you are already in breach. The Regulator has begun issuing compliance notices.

Frequently Asked Questions

My fire risk assessment already covers evacuation — do I need a separate RPEEP?

Your fire risk assessment should reference your evacuation strategy, but RPEEP is a separate, standalone document that residents can access. Many fire risk assessments contain only an assessor's recommendation — that is not the same as a written evacuation plan. You likely need both.

What if I'm a managing agent but the freeholder is named as responsible person?

If your management agreement gives you fire safety responsibilities, you may be jointly or primarily liable. Check your contract. The Fire and Rescue Service will pursue whoever they can prove had day-to-day operational responsibility for fire safety.

Does RPEEP apply to a block of only 4 flats?

Yes. The responsible person obligation applies to any building where people sleep and there are common areas — regardless of the number of units. A small block does not reduce the obligation; it may reduce the complexity of the evacuation plan required.

Where can I get help producing a RPEEP?

The Fire Industry Association (FIA) and the National Fire Chiefs Council (NFCC) both publish guidance. A competent fire safety consultant (with BAFE SP205 or FIA accreditation) can produce compliant REEPs. For larger portfolios, property compliance platforms can automate tracking and review cycles.

Key Takeaways

• RPEEP came into force on 6 April 2026. Criminal prosecution is now the enforcement route for non-compliance.
• Every responsible person managing a multi-occupancy residential building must have written evacuation plans in place.
• PEEPs for residents who need evacuation assistance are now explicitly part of the criminal enforcement regime.
• Prosecution is personal: the named responsible person can face imprisonment and unlimited fines.
• Audit your portfolio now. For any building without a RPEEP, act this week.

ComplianceAlert monitors fire safety, building safety, and employment law obligations for property management businesses across the UK. When new requirements come into force — like RPEEP — we alert you before enforcement begins, not after.

Start your free 7-day trial at compliancealert.co.uk/property-management. No credit card required.

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