What 'Reasonable Steps' Looks Like Five Weeks After the PEEPs Deadline

TL;DR: Five weeks on from the 6 April PEEPs deadline, "reasonable steps" is the test Fire and Rescue Authorities will apply. The phrase is not defined as a target percentage in the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025. It is an evidential standard: what the Responsible Person can demonstrate on paper. For RTM and RMC directors, that means dated letters, a response log, booked person-centred fire risk assessments, written or draft emergency evacuation statements, and a written record of contact with the local FRS.

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#"Reasonable Steps" Is Not a Number

The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 came into force on 6 April 2026. They sit on top of the Regulatory Reform (Fire Safety) Order 2005, which is the enforcement instrument Fire and Rescue Authorities apply.

Fire and Rescue Authorities assess whether the Responsible Person is taking reasonable steps toward PEEPs compliance. The 2025 Regulations do not set a threshold percentage of completed plans by a specific week.

— Residential PEEPs guidance for Responsible Persons

That distinction matters when reviewing your building's position five weeks after the deadline. The question is not "what percentage of residents have a finalised PEEP". The question is: if a Fire and Rescue Authority inspector arrived next Wednesday, what could they read from your file?

A file with dated letters to every flat, a response log with timestamps, follow-up attempts on non-responses, booked or completed person-centred fire risk assessments, and written or draft emergency evacuation statements for engaged residents reads as work in progress. A file that is empty or contains only generic templates reads as inaction. The catch-up plan in our 4-week post-deadline post gets a building from zero to a credible file. This piece is for buildings mid-way through that work and trying to understand what the file should look like at 30, 60, 90 days.

#What Goes in the Evidence File

Every entry below should carry a date, a method, and an author. "Letters went out" is not evidence. "Letters dated 7 April 2026 sent by hand-delivered notice and Royal Mail second class to 47 of 47 flats; recorded by [name] on building management system" is evidence.

Resident identification letters. Keep the template (so you can reproduce what you asked), the date sent, the delivery method, the flat list, and any follow-up attempts. The 2025 Regulations require "reasonable endeavours" to identify residents; a single unanswered letter does not meet that bar.

Response and refusal log. A flat-by-flat log of who replied, when, what they said, and whether they consented to a person-centred fire risk assessment. Refusals carry the date and the resident's stated decision. The GOV.UK Residential PEEPs factsheet confirms the decision to participate lies with the resident.

Follow-up trail on non-responses. A second letter on a different date, a door knock with the date and the person who knocked, a phone call where you have a number on file, a notice on the building noticeboard. The file shows you did not stop at one attempt.

Person-centred fire risk assessment bookings. For residents who identified as needing assistance, a record that the assessment was booked with a named assessor. This differs from the building's general fire risk assessment; the assessor brief should reflect that. Once the assessment has happened, the report and recommendations sit in the file.

Per-resident evacuation statements and mitigation records. For each relevant resident who consented to a person-centred fire risk assessment, the file holds the written emergency evacuation statement. Paragraph 7.31 of the GOV.UK guidance for Responsible Persons prescribes no format for the statement beyond "in writing", and recommends a short, clear statement of what the resident has agreed to do in the event of a fire affecting them, including any arrangement made with a neighbour to provide support. Alongside the statement sits the RP's record of the reasonable and proportionate mitigation measures decided through the PCFRA (paragraph 7.23), plus any measure the resident declined to fund. The first 12-month review date is set from when the statement is recorded, or from the PCFRA date where no statement is agreed (paragraph 8.1). Drafts and short statements are both compliant; what the file demonstrates is that each statement is written, dated, and on a review cycle.

Building emergency evacuation plan and FRS contact record. The building-level plan that wraps the individual PEEPs, plus a written record of when and how you contacted your local Fire and Rescue Authority about format and submission. Some FRAs use online portals, some accept email; the file shows you asked.

Resident consent records. Each PEEP carries the resident's consent to its content and to sharing with the FRA. Consent is dated and either signed or recorded in writing.

#Tenure Considerations for RTM and RMC Directors

The Responsible Person under the Fire Safety Order is the person in control of the premises. In a higher-risk building under Right to Manage, the RTM company is in control of the common parts under section 96 of the Commonhold and Leasehold Reform Act 2002 once acquisition is effective. The RTM company is the RP for the common parts, and the PEEPs duty sits there.

Three practical consequences for directors:

• The duty sits on the company, not on individual directors. Directors do not personally carry the RP duty, but they are responsible for the company discharging it. Board minutes that record the RTM's PEEPs decisions, instructions to any managing agent, and review cadence are themselves part of the file.
• Appointing a managing agent does not transfer the RP duty. If the RTM has instructed an agent to handle PEEPs operationally, the instruction should be in writing and the agent's deliverables specified. The RTM remains the RP. The file shows what the agent was asked to do and what they returned.
• Shared control with a freeholder requires a written allocation. Where the freeholder retains control of parts of the building (the structure or external walls, for example), the Fire Safety Order recognises that more than one person can be the RP for different parts. If no written allocation exists, that gap should close before the next FRA visit.

For RMC directors, the logic is identical: the company in control of the common parts is the RP. Where management is delegated to a managing agent or to the freeholder under a tripartite lease, the allocation should be written down.

#How Fire and Rescue Authorities Are Likely to Read the File

The enforcement ladder under the Fire Safety Order is the same whether the building is RTM-managed, RMC-managed, or freeholder-managed:

1. Informal advice. The inspector flags gaps verbally and in writing.
2. Enforcement notice. A formal notice requiring specific actions within a set timeframe.
3. Prohibition notice. Restricts use of the building (or part of it) where there is an imminent risk to life.
4. Prosecution. Reserved for ignoring an enforcement notice. A criminal offence under Articles 30 and 32 of the Fire Safety Order.

The Fire Safety Order does not prescribe the order in which inspectors use their powers; FRAs apply enforcement discretion. Where the RP can produce a credible evidence trail of work in progress, informal advice is the usual first step. The pattern that triggers escalation is not a missing evacuation statement for one resident; it is a building file that shows no engagement with the regulations at all. A file containing letters dated 7 April, a response log with three quarters of flats logged, six PCFRAs booked for the next two weeks, and a written enquiry to the FRS about how it wants the prescribed information shared is reading as a building taking the duty seriously.

Two practical points the file should address:

• Storage and access. The per-resident emergency evacuation statement holds sensitive personal data on a resident's disability or impairment, and the RP must comply with data protection law when storing or sharing it (paragraph 9.4). Two artefacts go to the Fire and Rescue Authority: the prescribed information about relevant residents, namely flat number, floor, basic information on the degree of assistance the resident may require, and whether they have an evacuation statement (paragraph 9.1); and the building emergency evacuation plan, including a copy in the building's secure information box where one is present (paragraph 10.1). The FRA decides whether the prescribed information is shared digitally or in the secure information box (paragraphs 9.10 to 9.12). The file should record where each artefact lives, who has access, and the FRA's stated format preference.
• Review triggers. PEEPs are not a one-off exercise. The file should show the next review trigger: when a resident's circumstances change, when a new resident moves in, after any fire-related incident, and at minimum annually alongside the fire risk assessment.

Read the full PEEPs implementation guide →

#What the File Should Show at 30, 60, 90 Days

The 2025 Regulations assign no milestones. The pattern below is the working sequence for RTM and RMC directors who started the catch-up on or around 7 April:

• 30 days. Identification letters out to every flat. Response log live with at least one follow-up attempt for non-responses. PCFRAs booked for residents who self-identified. First contact with the local FRS to confirm submission format.
• 60 days. PCFRAs largely complete. Draft PEEPs in version control for residents who have engaged. Refusals recorded. Building emergency evacuation plan drafted.
• 90 days. Finalised PEEPs with resident consent for residents who have engaged. Building emergency evacuation plan submitted to the FRS in the format they have specified. Annual review trigger set in the compliance calendar. Board minute recording the position.

A building faster than this is in a stronger position; a building slower needs to record why. Genuine reasons (a resident hospitalised and the assessment paused, a managing-agent handover, a contractor change) sit in the file as dated entries. Silence does not.

Plan your evacuation tracking →

#Frequently Asked Questions

#What does "reasonable steps" actually mean for PEEPs compliance?

"Reasonable steps" is not a quantified threshold in the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025. It is an evidential standard. Fire and Rescue Authorities decide whether the Responsible Person took reasonable steps based on the dated paper trail: letters sent, response logs, person-centred fire risk assessments booked, written or draft emergency evacuation statements, communications with the local FRS. There is no target percentage of completed plans by week N.

#What evidence should an RTM director hold five weeks after the deadline?

At minimum: dated copies of every resident identification letter, a response and refusal log, follow-up attempts on non-responses, person-centred fire risk assessment bookings or completions, written emergency evacuation statements (drafts acceptable) for residents who have engaged, and a written record of how and when the building emergency evacuation plan will be shared with the local Fire and Rescue Authority and, where present, placed in the building's secure information box. Each item should carry a date and an author.

#Is the RTM company itself the Responsible Person under the Fire Safety Order?

In a Right to Manage company that has acquired management functions under the Commonhold and Leasehold Reform Act 2002, the RTM company is typically the Responsible Person for the common parts under the Regulatory Reform (Fire Safety) Order 2005. Directors do not personally hold the duty, but they direct the company that does. The PEEPs duty sits on the RP, which is the RTM company in this scenario.

#What if the RTM has appointed a managing agent: does the agent become the Responsible Person?

Appointing a managing agent does not transfer the Responsible Person duty. The RTM company remains the RP for the common parts. The agent may be acting on the RTM's behalf operationally, and the RTM should record in writing what the agent has been instructed to do on PEEPs and what evidence the agent will return. If the agent is also responsible for fire safety on the building under the management contract, that overlap should be documented.

#Will a Fire and Rescue Authority issue an enforcement notice if reasonable steps are evident?

An enforcement notice is the formal step requiring specific actions within a set timeframe. The Fire Safety Order does not prescribe the order in which inspectors use their powers, but where the RP can produce a credible evidence trail of work in progress, informal advice is the usual first step. A notice is reserved for files that show no engagement with the regulations or where informal advice has not been actioned. Articles 30 and 32 of the Fire Safety Order reserve criminal liability for ignoring an enforcement notice once issued, so the priority is to keep the file current and act on any informal advice in writing.

#Further Reading

• PEEPs Deadline Has Passed: Your 4-Week Catch-Up Plan: the companion post for buildings still mid-way through the initial catch-up.
• Residential PEEPs: Complete Implementation Guide: step-by-step with templates.
• Download the PEEPs Compliance Guide (2026): printable PDF for boards and managing agents.
• Residential PEEPs: Guidance for Responsible Persons: official GOV.UK guidance.
• Fire Safety (Residential Evacuation Plans) Regulations 2025: the primary legislation.

Informational only. For building-specific advice, consult a qualified fire safety professional.