Visitor attractions

Escape rooms, fire safety law and insurance, explained

Escape room fire safety means the duties the Regulatory Reform (Fire Safety) Order 2005 places on whoever controls the venue, above all keeping players able to get out. It matters for insurance because a game built on locked doors raises the question insurers commonly ask first: can everyone leave at once if something goes wrong?

Part of: Visitor attraction insurance

In short

In England and Wales, the Fire Safety Order makes a “responsible person”, usually the employer running the venue, take general fire precautions and carry out a suitable and sufficient fire risk assessment. Since 1 October 2023 every responsible person must record that assessment in full. Article 14 says emergency doors must not be locked or fastened so that they cannot be easily and immediately opened. Government guidance for small and medium places of assembly says escape doors should open from the inside without a key, and that time-delay locks are not usually acceptable for the public. Scotland and Northern Ireland have their own rules.

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Who is responsible, and for what

Last reviewed 7 October 2026 by the Apex commercial team.

The Fire Safety Order applies in England and Wales. GOV.UK says Scotland and Northern Ireland have different fire safety rules.

The responsible person. In a workplace, it is the employer, if the workplace is to any extent under their control (art. 3). Anyone else with control, such as a landlord with repair obligations, shares the duties so far as matters are within their control (art. 5(3) and (4)).
General fire precautions. These must ensure the safety of employees so far as reasonably practicable, and make the premises safe for others, such as players (art. 8).
Risk assessment. It must be suitable and sufficient, reviewed regularly, and reviewed after significant changes to the premises or how they are used (art. 9).
Records. Since 1 October 2023, changes made by the Building Safety Act 2022, s.156, require every responsible person to record the assessment in full, the name of anyone engaged to help with it, and their fire safety arrangements. Before then, only some premises had to record significant findings.
Enforcement. Local fire and rescue authorities enforce in most premises and can issue enforcement, prohibition and alterations notices. Failing a fire safety duty in a way that puts people at risk of death or serious injury is an offence; on indictment, it carries an unlimited fine, up to two years’ imprisonment, or both (art. 32). Directors can be liable too (art. 32(8)).

Fire is not the only duty. Health and safety law protects players from other risks, such as props and electrics (Health and Safety at Work etc. Act 1974, s.3(1)), and the Occupiers’ Liability Act 1957 imposes a common duty of care to visitors.

Locks, maglocks and means of escape

This is where escape rooms differ from most venues. Article 14 sets out, where necessary for safety, that:

people must be able to evacuate as quickly and safely as possible (art. 14(2)(b));
emergency doors must open in the direction of escape (art. 14(2)(d));
emergency doors must not be so locked or fastened that they cannot be easily and immediately opened by anyone who needs them (art. 14(2)(f));
emergency routes and exits must be signed (art. 14(2)(g)) and, where they need lighting, have emergency lighting (art. 14(2)(h)).

The government guide Fire safety risk assessment: small and medium places of assembly (up to 300 people) adds detail:

Game feature	What the guidance says
Locked room doors	Escape doors should be unlocked while people are inside and never fastened so they cannot be opened from inside without a key. If fastened, use a panic latch or bar.
Code or card exit locks	Electromechanical devices are normally unacceptable on escape doors unless they have a manual override or fail safe open.
Magnetic locks	Seen as more reliable because they fail safe unlocked; release can be by switch, green break-glass point or a link to the fire alarm.
Delayed release	Time-delay devices are not usually acceptable for members of the public.
Rooms reached through other rooms	Avoid “inner rooms” where possible; otherwise give early warning of a fire in the outer room and limit the inner room to 60 people.
Dark rooms and effects	Lasers, strobes and other high-intensity lighting are not suitable for emergency use.

The guide says enforcing authorities may accept electronic door controls if the responsible person can show, through a risk assessment for each door, both the need and adequate management controls.

What it means in practice

These examples are illustrative, not real cases.

A two-room game. The second room opens only from the first. That makes it an inner room, so the risk assessment needs to address how players learn of a fire in the outer room, and how both doors release.
A venue in a leased unit. The operator is the responsible person for its space; the landlord may be for shared corridors. Since 2023 each must take steps to find the other and co-operate.
A refit adding a new room. New partitions, locks or effects are a significant change, so the risk assessment must be reviewed (art. 9(3)(b)).

How insurance responds

Insurance pays for liabilities and losses, subject to the policy terms. It does not make a locking system lawful.

Risk	Cover usually engaged	Where gaps appear
Player injured by a prop, fall or panic in the dark	Public liability	Physical or “live actor” games not declared; venues off-site
A player says they were held against their will	Some public liability wordings extend to wrongful detention	Many cover bodily injury and property damage only
Staff injured	Employers’ liability, compulsory for most employers in Great Britain	Freelance game hosts treated as employees
Fire, flood or theft of sets, props and electronics	Contents and equipment cover	Bespoke builds undervalued; electronics breakdown
Closure after damage, or a prohibition notice	Business interruption	Usually needs insured damage first; a notice alone is not commonly covered
Fines after a prosecution	Commonly excluded by liability policies	Defence costs may be available under some legal expenses or liability extensions

How locks affect insurers. Insurers commonly ask how players get out, whether locks fail safe and who watches the room. Some set conditions, for example that release mechanisms are tested. Under the Insurance Act 2015, s.11, an insurer cannot rely on breach of a risk-reducing term if the insured shows the breach could not have increased the risk of the loss that actually happened, but a broken release linked to the injury is a different matter.

Common misunderstandings

“Players agreed to be locked in.” The fire duties are statutory. And under the Consumer Rights Act 2015, s.65(1), a booking term cannot exclude liability for death or personal injury caused by negligence.
“The Fire Safety Act 2021 changed the rules for us.” That Act clarified that, in buildings with two or more homes, the Order covers the structure, external walls and flat entrance doors. It matters if your venue is in a mixed-use block, but it did not add rules about game locks.
“We’re small, so nothing needs writing down.” Since October 2023 every responsible person must record the assessment in full.
“The fire service will do the assessment.” GOV.UK says fire and rescue authorities can advise but cannot carry out risk assessments for you.

What to check

That every lock on a route out fails safe and is released by the fire alarm or a break-glass point.
That your written risk assessment covers each room and door, and is reviewed after every refit.
Who monitors each game, and how they get people out in the dark.
That your insurer knows how the locks work and which game formats you run.

Running an escape room?

If this affects your business, these are the points a broker will ask about:

How many rooms you run and how many players each holds.
How players leave in an emergency, and how locks release.
Whether rooms are monitored throughout each game.
Your fire risk assessment, its date and who carried it out.
Any physical challenges, live actors or special effects.
Your landlord, lease and the building you share.

Speak to a broker

Escape room cover, placed by a named broker

Send us your current schedule, or tell us about the property if you are arranging cover for the first time. Or leave your number and a named broker will call you back, usually the same working day.

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How Apex places this cover

Apex Insurance Brokers is an independent insurance broker based in Bristol, established in 2009 and authorised and regulated by the Financial Conduct Authority. We are not tied to one insurer: we work with over 30 markets, including Lloyd’s syndicates through wholesale brokers, and every client has a named broker who handles the placement, mid-term changes, certificates for clients and the renewal.

A short fact-find. We ask what you actually do, for whom, under what contract terms, and what has gone wrong before.
A written presentation to insurers. Under the Insurance Act 2015 you must make a fair presentation of the risk. We help you meet that duty, and a well-presented risk gets better terms.
Quotes you can compare. Limits, excesses, retroactive dates, exclusions and premium side by side, with a plain-English recommendation.
No gap in cover. If you are moving from another insurer or broker, we line up the new policy to start the moment the old one ends.

Related guides

Sources

Frequently asked

Are escape rooms allowed to lock people in?

Article 14 of the Fire Safety Order says emergency doors must not be so locked or fastened that they cannot be easily and immediately opened by anyone who needs them. Government guidance says escape doors should open from inside without a key and that time-delay locks are not usually acceptable for the public. Fail-safe release is the usual approach.

Who is the responsible person for an escape room?

Usually the business running it, as the employer in control of the workplace (art. 3 of the Fire Safety Order). A landlord or anyone else with control of parts of the building shares the duties for the matters within their control, and since 2023 responsible persons must take steps to identify each other and co-operate.

Does an escape room need a written fire risk assessment?

Yes, in England and Wales. Since 1 October 2023, changes made by the Building Safety Act 2022 require every responsible person to record the fire risk assessment in full, along with their fire safety arrangements and the name of anyone engaged to help carry it out.

What insurance does an escape room business need?

Most need public liability for players and visitors and, if they employ anyone, employers’ liability. Contents and equipment cover protects sets and electronics, and business interruption covers lost income after insured damage. Insurers will usually ask how players get out and how your locks release.

Does the Fire Safety Act 2021 apply to escape rooms?

Not directly. It clarified that, in buildings containing two or more homes, the Fire Safety Order covers the structure, external walls and flat entrance doors. If your venue is in such a building, that matters to whoever is responsible for it, but your own duties come from the Order itself.

Ready to compare cover?

Apex arranges liability, contents and business interruption cover for escape room venues. Tell us how your rooms and locks work, and we’ll look for cover that fits. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information, not advice on your individual circumstances. Cover is always subject to the insurer’s acceptance and the policy terms, and this page does not guarantee that cover will be available or on what terms.