What questions should you ask to ensure your emergency lighting system is compliant and fit for purpose?
To meet legal requirements and make sure your emergency lighting system performs during a power failure, you need to ask a clear set of practical questions. These should focus on lighting design, building coverage, routine emergency light testing, documentation, and legal responsibility. Asking specific questions helps expose gaps quickly and encourages responsible management.
Here's What We Have Covered In This Article
Why emergency lighting compliance is often misunderstood
Some people assume that simply having emergency lights means a building is compliant. But the law requires more. Emergency lighting systems must be properly designed, regularly tested, well maintained, and supported by clear written records.
Another common mistake is believing that once emergency lights are installed, they will always meet current standards. However, changes to the building or missing documentation can mean the system no longer complies.
The difference between having emergency lights and being compliant
Emergency lights may be installed in a building, but that does not mean the system meets legal standards. True compliance involves meeting the Fire Safety Order and applying British Standards such as BS 5266-1 and BS EN 50172.
A compliant system includes:
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A layout that matches current escape routes
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Regular emergency lighting maintenance with up-to-date test records
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A system type suited to how the building is used
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Documentation that shows the system is functional and properly managed
Pro Tip: After any layout change or refurbishment, always reassess your lighting coverage. Old designs can leave new gaps.
Why a question-led approach exposes gaps quickly
Structured questions can uncover issues that basic checklists often miss. They help identify:
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Areas with poor lighting coverage
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Lighting based on outdated building layouts
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Missing emergency lighting inspection records or unclear responsibilities
This approach helps the responsible person identify and address areas that need attention.
Who this guide is for: landlords, managing agents, responsible persons
This guide is intended for:
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Landlords and property owners
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Managing and facilities agents
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Employers and duty holders
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Anyone defined as the responsible person under fire safety law
If you are responsible for safety in a building, this guide applies to you.
How to use this guide as a self-audit tool
Use this guide to assess your emergency lighting system. For each question, check whether you can give a confident answer backed by clear evidence. If not, that topic may require further review.
Combine this guide with your fire risk assessment to ensure the system supports your current evacuation strategy.
What does compliant and fit for purpose actually mean for emergency lighting?
Legal compliance vs practical effectiveness
Meeting legal standards is only part of the solution. A system that looks good on paper might still fail if it is not positioned correctly or fails to operate during an emergency.
Why compliance is evidence-based, not assumption-based
Inspectors will require written proof rather than verbal assurances. You should have:
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Drawings showing how the system was designed
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Emergency light testing records from regular checks
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Maintenance logs
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Documents confirming that faults were repaired and lights retested
The role of British Standards in defining fit for purpose
British Standards offer guidance on emergency lighting systems. BS 5266-1 sets requirements for layout and design, while BS EN 50172 outlines testing and record-keeping duties.
Common reasons systems fail despite being installed
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The design has not been updated after changes to the building
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The system type does not suit how the building is used
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The wrong type of system was selected for the level of risk
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There is no routine emergency lighting inspection or testing
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Changes during refurbishment were not matched by lighting updates
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Who is legally responsible for emergency lighting in this building?
Explanation of the responsible person
The responsible person is the individual or organisation with control over the premises. This could be a landlord, managing agent, employer, or facilities team.
How responsibility changes across landlords, agents, freeholders, employers
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In offices, the employer is usually responsible
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In residential blocks, it may be the freeholder or managing agent
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In mixed-use buildings, responsibility may be shared depending on lease terms
Responsibility in residential blocks, HMOs, and mixed-use buildings
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Landlords are typically responsible in HMOs
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In mixed-use properties, responsibility depends on how shared areas are managed
Why responsibility cannot be delegated away
Even if you appoint a contractor to manage testing and maintenance, legal responsibility remains with the designated responsible person.
Consequences of unclear responsibility
When roles are not clearly defined, important tasks can be missed. This may lead to:
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Missed emergency light testing
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Unresolved faults
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Missing or outdated maintenance records
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Greater risk of enforcement after a fire safety inspection
Pro Tip: Keep your emergency lighting logbook on site and up to date. Inspectors almost always ask to see it first.
Which standards and regulations apply to emergency lighting systems?
Overview of the Regulatory Reform (Fire Safety) Order 2005
This legislation places legal duties on the responsible person to ensure that emergency escape routes are illuminated and maintained.
Role of BS 5266-1
BS 5266-1 explains how to plan, install, and maintain emergency lighting systems. It provides guidance for lighting stairwells, corridors, exits, and high-risk areas.
Relevance of BS EN 50172
BS EN 50172 outlines how emergency lighting should be tested and the frequency of record keeping.
Importance of using the most up-to-date standards
As buildings and occupancy types change, emergency lighting systems must also be reviewed to maintain compliance.
What happens when standards are updated
Older systems may not require immediate upgrades. However, the fire risk assessment should consider whether changes to the system are needed.
Quick compliance checklist for responsible persons
Use this list to check whether your emergency lighting system is compliant:
- Are all escape routes clearly illuminated during a power failure?
- Are monthly and annual emergency light tests being recorded?
- Is your emergency lighting logbook available on-site and up to date?
- Has the system been reviewed following layout changes?
- Can you provide written proof of emergency lighting maintenance and repairs?
- Do you know who the responsible person is for your building?
If you answer “no” to any of these, it is a strong indication that action is required.
Prepare for your next fire safety inspection by reviewing your emergency lighting logbook and testing records in advance.
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