Emergency Lighting Regulations: Who Needs It, Where It Goes and Testing
Updated: Oct 9
The core rule is short. Under the Regulatory Reform (Fire Safety) Order 2005, which applies in England and Wales, "emergency routes and exits requiring illumination must be provided with emergency lighting of adequate intensity in the case of failure of their normal lighting." The responsible person for the premises decides what that means for their building through the fire risk assessment, and the detailed design normally follows BS 5266-1, the code of practice for the emergency lighting of premises.
There is no single rule saying every building needs a particular number of emergency lights. What the law requires is that people can find their way out safely if the power fails, and that whatever is installed is maintained and tested.
Who needs emergency lighting?
The Fire Safety Order applies to almost all premises other than private homes. That covers:
offices, shops, workshops, warehouses and factories
pubs, restaurants, gyms, churches and community buildings
the common parts of blocks of flats, such as stairs, corridors and entrance halls
the shared areas of houses in multiple occupation (HMOs)
Private homes are excluded, but the Order's definition of "domestic premises" is a private dwelling and its own garden, garage and outbuildings, not areas used in common by more than one dwelling. So a landlord's shared hallway and stairs are covered even though each flat is not.
The person responsible is the "responsible person": the employer for a workplace, or otherwise the person who controls the premises for a business, or the owner. Government guidance lists employers, owners, landlords, occupiers and managing agents as people who can hold that role. Their duties include carrying out a fire risk assessment and putting in place, and maintaining, suitable fire safety measures.
For new buildings, the Building Regulations also have a say. Approved Document B expects escape lighting on the common escape routes of blocks of flats other than two-storey blocks, conforming to BS 5266-1, and escape lighting to windowless accommodation in live/work flats.
Where emergency lighting must go
The government's fire risk assessment guidance for offices and shops says an emergency escape lighting system should normally cover:
each exit door and the escape routes
intersections of corridors and changes in floor level
stairways, so each flight gets enough light
outside each final exit and along external escape routes
emergency exit signs, fire alarm call points and firefighting equipment
equipment that would need to be shut down in an emergency, and lifts
windowless rooms and toilets over 8 m²
any area of the premises larger than 60 m²
It does not need a separate fitting for each item, as long as the overall level of light makes them visible and usable. In very small, simple premises, the same guidance accepts that reliable borrowed light (from street lighting, for example) or torches placed for trained staff may be enough. Larger or more complex buildings, basements and places open to the public usually need a fixed automatic system. Our lighting installation and repairs team designs and installs these systems to BS 5266-1 around the escape routes your risk assessment identifies.
Maintained vs non-maintained emergency lighting
Maintained: the emergency lamps are lit all the time, as part of the normal lighting, and stay lit on battery when the mains fails.
Non-maintained: the emergency lamps only light when the normal lighting supply fails.
Fittings can be stand-alone units, emergency versions of normal light fittings, or signs with a built-in lamp. They can run from a battery in each fitting, a central battery system or a generator.
How long emergency lighting must last
Emergency lighting units are designed to run for between one and three hours. Government guidance notes that three-hour units are the most popular, partly because they allow limited continued use of the premises during a power cut. The right duration for your building comes from the risk assessment and BS 5266.
Testing and record keeping
Government guidance says testing typically includes:
a daily visual check of any central control equipment
a monthly function test (often called a flick test), using the test facility long enough to confirm every emergency lamp lights
an annual full discharge test, running the system for its full rated duration
After a full discharge test, batteries typically take 24 hours to recharge, so the test is best done when the building can stay empty or other arrangements are in place. Many systems use a "fishtail" key switch near the distribution board for testing, and some modern fittings test themselves. Keeping a written record of every test is good practice, and it is how you show the system has actually been checked.
The guidance says most routine tests can be done by you or your staff once shown how. Anything you are unsure of, plus repairs and changes to the system, needs a competent person, and many businesses fold the annual test into a planned electrical maintenance visit alongside other checks.
Common problems we see
Batteries at the end of their life: the fittings light during a quick test but fail well short of their rated duration.
Changed layouts: partitions or new rooms leave part of an escape route in the dark.
No test records: the system may work, but there is nothing to show it has been checked.
Unlabelled test switches: nobody knows which key switch tests which area.
Fittings on the wrong circuit: a non-maintained fitting is meant to light when the normal lighting around it fails. Fed from a different circuit, it can stay dark while the room goes black.
Emergency lighting questions, answered
Does a small shop need emergency lighting?
It depends on the risk assessment. If escape routes are short, simple and lit by daylight or reliable street lighting, torches or a small number of self-contained units may be enough. Premises used after dark or with internal routes usually need more.
Do HMOs need emergency lighting?
The shared escape routes in an HMO fall under the Fire Safety Order, so the landlord's fire risk assessment decides. Longer or more complex escape routes, and routes without natural light, are where emergency lighting is most likely to be needed.
Can I install emergency lighting myself?
Government guidance says installation or changes should be carried out by a competent person to the appropriate standards. Most emergency lighting is wired into lighting circuits, and it needs designing around your escape routes.
Staying compliant
As an electrician in Shifnal, SM Electrical installs, tests and maintains emergency lighting for businesses and landlords across Wolverhampton, Telford, Shropshire and Staffordshire. If your system has not had a full duration test in the last year, contact us to arrange one.
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