The Residential PEEPs regulations and supporting guidance have now been published, and while they provide welcome clarity on identifying “relevant residents”, completing PcFRAs, implementing mitigations and sharing information with Fire & Rescue, they also expose some practical legal friction points with other regimes.
The Fire Safety Order (FSO) is framed around protecting “relevant persons” broadly, whereas Residential PEEPs duties only trigger for the narrower group of “relevant residents” (creating a scope gap risk if teams assume PcFRA covers everyone); the Residential PEEPs framework allows some mitigations to be resident-borne (and not implemented if the resident declines to pay), while the Equality Act can prohibit charging where the measure is a reasonable adjustment for a disabled person; and the PEEPs regulations include explicit-consent gates for certain disclosures to Fire & Rescue, at the same time as the Data (Use and Access) Act 2025 context is intended to support proportionate data use/sharing for safeguarding and emergency response without always relying on consent – meaning organisations need very careful governance to avoid either unlawful disclosure or dangerous delay.
