The green indicator is illuminated and the service label is in date. Neither proves that the emergency light will operate when the normal supply fails, provide enough illumination or last for its rated duration. Responsible persons need a testing and defect-management system that reflects the premises, the fire risk assessment and the people who may need to escape.
Start with the fire risk assessment
Article 14 of the Regulatory Reform (Fire Safety) Order 2005 requires emergency routes and exits that need illumination to have emergency lighting of adequate intensity if normal lighting fails. Article 17 requires relevant fire-safety facilities, equipment and devices to be maintained in an efficient state, efficient working order and good repair. The legal duty is therefore outcome-based: the system must be suitable for the premises and continue to work.
The fire risk assessment should establish where emergency escape lighting is necessary, who relies on it and how it supports the evacuation plan. It should consider the complete route to a place of safety, including changes of direction or level, stairs, intersections, final exits, fire-alarm points, firefighting equipment and areas where occupants could otherwise become disorientated.
A monthly tick sheet cannot correct inadequate coverage. If partitions, racking, machinery, occupation, shift patterns or escape routes change, review and update the statutory fire risk assessment. Where the existing assessment lacks technical detail, arrange a linked emergency-lighting survey or assessment and incorporate its findings into the main FRA, emergency arrangements and control plan.
Fire Safety Order 2005: article 14 ↗ · Fire Safety Order 2005: article 17 ↗ · Related guide: workplace fire evacuation plans →
Know what the indicator can—and cannot—tell you
A charge indicator usually shows that the unit is receiving power or charging. It does not, by itself, prove that the emergency lamp works, the battery has adequate capacity, the diffuser is clean or the light reaches the area it is meant to protect. Maintained fittings remain illuminated during normal use; non-maintained fittings normally illuminate only when the normal supply fails. Both still need appropriate testing.
Keep an asset list or plan that uniquely identifies each luminaire, internally illuminated sign, central battery control and test point. Without reliable identification, repeat failures are easily missed and contractors cannot show which unit was repaired or retested. Include external areas immediately beyond final exits where people must continue to a safe place if the assessment requires illumination there.
Carry out a short functional test each month
Government fire-safety guidance describes a monthly function test that operates the test facility long enough to confirm each emergency lamp illuminates. The test should simulate failure of the normal lighting supply without creating electrical danger or unnecessarily isolating unrelated equipment. Use the manufacturer's instructions and a suitable test key, local switch, central control or automatic test system for the installation.
Walk the route while the normal lighting is interrupted. Check every expected fitting and illuminated sign, not just the unit beside the test switch. Look for failure to illuminate, obvious damage, dirty or painted diffusers, reduced light output, missing legends and building changes that cast new shadows. Restore the normal supply, confirm charging indicators return and record the result.
Schedule the test when the system is unlikely to be immediately required. If testing leaves any part unavailable, apply suitable temporary precautions. Automated self-test results still need reviewing, recording and action; automation does not repair the failed fitting or assess whether the layout remains adequate.
Arrange an annual full-duration test
The same government guide describes an annual full discharge test. Each fitting should operate for its full rated duration so battery capacity—not just initial illumination—is tested. The required duration belongs to the designed system and risk; do not assume every installation has the same rating or shorten the test because a lamp remains bright for the first few minutes.
Plan the test carefully. Government guidance warns that batteries typically need 24 hours to recharge after a full discharge. The premises should not be reoccupied until the system is fully functioning unless suitable alternative arrangements have been made. For occupied premises, this may require phased testing, temporary lighting, additional staffing, restriction of affected areas or an agreed low-occupancy period.
Use a competent person where the installation, controls, duration test or results exceed in-house capability. Sleeping accommodation, healthcare and care settings, complex buildings, basements and high-occupancy venues need particularly careful planning because a failure can have more serious consequences and evacuation may take longer.
Check the route, test method and defect plan together.
HR + SAFETY can help North East SMEs review emergency-lighting arrangements, connect findings to the fire risk assessment and prioritise practical actions.
Discuss an emergency-lighting reviewRecord the result and close every defect
GOV.UK requires regular checks to confirm emergency lighting is working and faults are recorded. A useful log states the date and time, test type, person completing it, areas and asset references tested, result, faults found, immediate precautions, repair owner, target date and successful retest. Retain service reports with the fire-safety records, but do not treat an invoice as evidence that every identified defect was closed.
Triage failures against the actual escape strategy. A single failed fitting in a well-lit low-risk area may allow a prompt controlled repair. A dark stair, protected route, change of level, windowless area or route used by people needing assistance may require immediate restriction or alternative lighting. Do not wait for the next planned service when the route is no longer adequately illuminated.
Treat standards as technical guidance—not a substitute for assessment
The BS 5266 series provides recognised technical guidance on emergency lighting design, installation and testing. Government guidance refers to it for further information. It is not the legislation, a blanket certificate of compliance or a substitute for the responsible person's statutory fire risk assessment. The applicable edition, system design and premises-specific recommendations should be confirmed by a competent adviser where necessary.
A test certificate demonstrates only the scope and condition recorded at that time. It does not prove that later alterations, blocked light distribution, failed repairs or a changed evacuation strategy are acceptable. Connect the test programme with change control, routine workplace inspection, fire drills and the FRA action plan.
Responsible person's checklist
Legal requirements and official guidance were checked on 1 October 2026. The monthly and annual routines are recognised ways to support compliance, but the responsible person must still decide what is suitable for the premises and maintain the system in effective working order.
- Confirm the FRA identifies where emergency escape lighting is required and why.
- Maintain a current asset list or plan with unique luminaire and test-point references.
- Check central controls or indicators visually where the system requires it.
- Complete and record the monthly function test for every expected fitting and sign.
- Arrange the annual full-rated-duration test and plan for battery recharge time.
- Record failures, temporary precautions, repair ownership, deadlines and retest results.
- Provide additional controls for occupants who may need assistance or longer to evacuate.
- Use a competent person for technical design, complex systems or uncertain test results.
- Review the FRA after layout, occupation, escape-route or system changes and after significant defects.
Emergency lighting testing is a complete control loop: identify the required coverage, prove short-term operation, verify full battery duration, record the result, control defects and update the fire risk assessment whenever the premises or evacuation strategy changes.
This guide provides general information for UK employers. It is not legal advice and should not replace advice based on the facts of a specific matter.