ERP, IGH, ICPE: Which Classification Applies to Your Building in 2026

France's fire-safety architecture rests on three classification frameworks: ERP (Établissements Recevant du Public), IGH (Immeubles de Grande Hauteur), and ICPE (Installations Classées pour la Protection de l'Environnement). Each framework lives in a different code, answers to a different regulator, and triggers a different review and authorisation process. A building can fall under one of them, or two, or all three at once. Knowing which applies — and in what combination — is one of the first decisions on any French project, and one of the easiest to get wrong.

This is a disambiguation. It does not replace the work of a bureau de contrôle, an architect, or a fire-safety specialist. It is the framing every owner, developer, and operator needs before that work begins.

The three frameworks at a glance

Each framework exists to address a specific risk profile. ERP protects the public when it gathers in a building. IGH protects occupants when the building is tall enough that conventional fire-service intervention is no longer adequate. ICPE protects the surrounding environment and population when the activity inside the building presents pollution, accident, or major-hazard risks.

ERP: when the public comes to the building

An ERP is any building, enclosed area, or premises in which people are received outside their private home — paying customers, visitors, students, patients, audience members. The regime is set out in articles R143-1 and following of the Code de la construction et de l'habitation (CCH), with the operational rules in the arrêté du 25 juin 1980.

ERP buildings are classified along two axes simultaneously. The first is type, defined by the activity: J for senior facilities, L for assembly halls, M for retail, N for restaurants, O for hotels, P for entertainment venues, R for educational establishments, S for libraries, T for exhibitions, U for healthcare, V for places of worship, W for offices receiving the public, X for sports facilities, Y for museums. Specialised types cover open-air structures (PA), tents (CTS), and a handful of others. Each type has its own technical chapter in the règlement de sécurité.

The second axis is category, defined by the headcount the building can receive — public plus staff with no independent exits. The categories, set out in article R143-19 of the CCH, are: 1st category above 1,500 people; 2nd category from 701 to 1,500; 3rd category from 301 to 700; 4th category 300 and below, except 5th; 5th category below the minimum threshold fixed by the règlement for that type.

The category determines how intensive the verification is. A 1st-category ERP — a major shopping centre, a large hospital, a stadium — is reviewed by the commission de sécurité before opening and revisited periodically. A 5th-category ERP — a small clinic, a village café, a neighbourhood pharmacy — operates under simplified rules. The same building, redesigned to receive more people, can shift categories and trigger a different review pathway.

IGH: when the building is too tall for conventional intervention

An IGH is defined by a single physical measurement, set out in article R146-3 of the CCH: the height of the lowest floor of the topmost occupied level above the highest ground level usable by emergency-service vehicles. Above that threshold, the building is an IGH and falls under the arrêté du 30 décembre 2011, the IGH-specific règlement de sécurité.

The threshold is asymmetric. For residential buildings it sits at 50 metres. For every other use — offices, hotels, healthcare, education, mixed-use — it sits at 28 metres. The logic is intervention reach: above those heights, a fire on the upper floors cannot be fought from the outside by conventional means, so the building has to be designed to contain and evacuate the fire from within.

IGH buildings are then sorted into classes by primary use, set out at R146-3: GHA (residential), GHO (hotels), GHR (educational), GHS (archives), GHTC (control towers), GHU (healthcare), GHW1 and GHW2 (offices, below and above 50 metres respectively), GHZ (primarily residential buildings between 28 and 50 metres containing non-residential premises that do not meet the isolation conditions of article R146-3), and ITGH for any building above 200 metres — Immeubles de Très Grande Hauteur, a separate, stricter sub-regime.

One frequent point of confusion: a residential building between 28 and 50 metres is not automatically an IGH. The Loi ELAN created an intermediate category, the Immeuble de Moyenne Hauteur (IMH), for residential buildings in that height band, with its own façade fire-protection requirements but without triggering full IGH compliance. If the same building contains non-residential premises that do not meet defined isolation conditions, it falls back into GHZ and is reclassified as a full IGH.

ICPE: when the activity is the risk

ICPE sits in a different code entirely. The regime is established in Book V of the Code de l'environnement, articles L511-1 and following. It applies not to buildings as such, but to installations whose operations present risks to neighbours, workers, water, soil, air, biodiversity, or public health — chemicals storage, heavy industry, waste treatment, refrigeration plants above a certain capacity, large data centres through their battery storage, cooling, and back-up generator installations.

The classification is set out in the ICPE nomenclature at article R511-9 of the Code de l'environnement. Each numbered rubric (1xxx for older categories, 2xxx for activities, 3xxx for IED-equivalents, 4xxx for substances post-Seveso III) has thresholds that determine which of three regimes applies: Déclaration (D) for low-risk installations, a simple filing with the préfecture; Enregistrement (E) for medium risk, a simplified authorisation; Autorisation (A) for the highest risk, with a full impact study and public inquiry. Within the autorisation regime, substance-based thresholds at R511-10 and R511-11 trigger SEVESO classification — seuil bas or seuil haut — with additional safety-management obligations.

Most owners encounter ICPE for the first time through ancillary equipment — back-up generator fuel storage above the seuil de déclaration, refrigeration above a certain refrigerant tonnage, parking above a certain floor area. The activity does not have to be the building's primary purpose. A residential development with a sufficiently large underground car park can incidentally fall into an ICPE rubric, even when nothing else about the project is industrial.

The combinations that catch owners out

Most fire-safety surprises on French projects come from combinations. A mixed-use tower above 28 metres with retail on the ground floor is simultaneously an IGH (because of the height) and an ERP (because of the retail). A logistics campus with a public-facing showroom is simultaneously an ICPE (the warehouse activity) and an ERP (the showroom). A data centre whose ancillary installations trigger an ICPE rubric is an ICPE, and if it includes a publicly visited control or demonstration area, it becomes an ERP for that zone.

Each regime keeps its own rules in the combined building. ERP rules govern the public-facing spaces. IGH rules govern the high-rise envelope and the protected stair cores. ICPE rules govern the technical installations and the perimeter. The plans have to satisfy all of them simultaneously, with the most demanding rule winning at any given point of conflict.

How an owner determines which framework applies

The sequence we use when reviewing a new project follows the logic of the regulations themselves. First, what activities will the building host, and will any of them receive the public? If yes, ERP applies, at least to the public-receiving zones. Second, what is the planned height of the lowest floor of the topmost occupied level, and how does it relate to the 28-metre and 50-metre thresholds for the building's primary use? If the threshold is crossed, IGH applies. Third, do any of the planned installations, storage capacities, or ancillary activities appear in the ICPE nomenclature? If yes, ICPE applies, with the specific regime determined by the threshold.

The answer is then one framework, two, or all three. For each, the relevant règlement defines the review pathway, the documents required at permit, the inspections before opening, and the periodic re-verifications during operation.

Where verification work concentrates

In our compliance work across French projects in 2025 and into 2026, the regulatory category mistakes we see most often are not exotic. They are: ERP-type ambiguity in mixed-use ground floors where the occupancy calculation has not been done rigorously; failure to identify the 28-metre threshold for non-residential uses in towers that were assumed to fall under residential rules; and ancillary installations — generators, parking, data-centre cooling — that fall into ICPE without anyone on the design team having read the nomenclature. None of these are sophisticated regulatory failures. They are filing errors that compound into permit refusals or post-construction modifications when caught late.

The frameworks are stable and well-documented. The work is in reading them against the specific project, every time, with the discipline that the consequences of getting it wrong demand.