Triple A Solutions considers the Residential PEEPs regulations, as currently drafted, to be deeply flawed. They present significant conflicts with existing primary legislation, including the Regulatory Reform (Fire Safety) Order, the Equality Act 2010, the Housing Act 2004, the Housing Health and Safety Rating System, Awaab’s Law, and the Data Use and Access Act. These conflicts create legal ambiguity around scope, duties, data use, and accountability, undermining lawful and consistent implementation despite the intention to improve evacuation support for residents who may require assistance.
The regulations must be interpreted within the existing legislative framework. The Fire Safety Order expressly excludes domestic premises, meaning Residential PEEPs duties apply only to the common parts of residential buildings. Primary legislation takes precedence over secondary legislation and guidance, and failure to align the regulations accordingly risks operational inconsistency, legal challenge, and unintended equality and data protection consequences.
Triple A Solutions’ RPEEPs Regulation Stakeholder Feedback, submitted in August 2025, identify numerous disparities and implementation risks. We therefore call for urgent clarification and alignment across all relevant legislation and guidance to ensure the regulations are legally robust, operationally deliverable, and capable of supporting safe, inclusive evacuation outcomes.
