Gas, EICR and EPC: UK landlord certificate deadlines
Most compliance failures in the private rented sector are not failures of intent. They are failures of diary. A gas record that expired eleven days ago, an EICR that was never sent to the tenant, an exemption that was never registered — each of them is an administrative slip, and each of them can be expensive.
This guide sets out every recurring certificate and check in a typical England tenancy: the interval, who the paperwork has to reach and by when, and the consequence of getting it wrong. Where a penalty figure is set in law we give it. Where enforcement is by prosecution rather than a fixed penalty, we say that instead of inventing a number.
Quick reference
| Requirement | Interval | Who must receive it, and when |
|---|---|---|
| Gas safety record (CP12) | Every 12 months | Existing tenants within 28 days of the check; new tenants before they occupy |
| Electrical Installation Condition Report (EICR) | At least every 5 years | Existing tenants within 28 days; new tenants before occupation; the council within 7 days of a request |
| Energy Performance Certificate (EPC) | Valid 10 years | Prospective tenants when marketing; the tenant free of charge |
| Smoke alarms | Checked at the start of each tenancy; repaired or replaced when reported faulty | n/a — a physical requirement, not a certificate |
| Carbon monoxide alarms | As above | n/a |
| Legionella risk assessment | No statutory interval; review when circumstances change | Kept on file — there is no certificate |
| Fire risk assessment (common parts) | Kept up to date and reviewed | Produced to the enforcing authority on request |
Gas safety: the annual check and the CP12
Under the Gas Safety (Installation and Use) Regulations 1998, a landlord must ensure that every gas appliance, fitting and flue provided for a tenant’s use is maintained in a safe condition, and that a gas safety check is carried out on each of them at least every 12 months by a Gas Safe registered engineer.
What the record must show and who gets it
- The engineer records the check on a landlord gas safety record — the document everyone calls a CP12.
- A copy must be given to existing tenants within 28 days of the check.
- New tenants must receive a copy before they occupy the property.
- Records must be kept for at least two years, so you always hold the current one and its predecessor.
- In an HMO, the record must also be produced to the local authority on request.
Practical points that catch people out
- The check and a service are not the same thing. The annual safety check is the legal requirement; servicing to the manufacturer’s schedule is separate, strongly advisable, and often what keeps the appliance passing.
- Tenants’ own appliances are outside the duty, but the pipework and flue serving them is not, and you remain responsible for the installation they connect to.
- Do not let the clock slide. You may have the check done up to two months before the current one expires and keep the original expiry date, which is the sensible way to stop annual renewals drifting later every year.
- Access refusal is not a defence on its own — but documented, repeated, escalating attempts to gain access are the evidence you will need. Write every attempt down.
Penalty: gas safety is enforced by the Health and Safety Executive through prosecution rather than by a fixed civil penalty. Offences can lead to an unlimited fine and, in serious cases, imprisonment. There is no tariff to quote, which is precisely why it is the duty least worth gambling on.
EICR: electrical safety every five years
The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 require landlords to ensure the fixed electrical installations in a rented property are inspected and tested by a qualified and competent person at least every five years, and that national standards for electrical safety are met. The requirement applied to new tenancies from 1 July 2020 and to all existing tenancies from 1 April 2021.
The disclosure clocks
- A copy of the report goes to existing tenants within 28 days of the inspection.
- A copy goes to a new tenant before occupation, and to any prospective tenant within 28 days of a written request.
- A copy goes to the local authority within 7 days of a request from it.
- The report is retained and given to the person carrying out the next inspection.
Remedial work
Where the report identifies a C1 (danger present), C2 (potentially dangerous) or FI (further investigation required) outcome, remedial or further investigative work must be carried out within 28 days, or within any shorter period the report specifies. You then need written confirmation from the electrician that the work has been done and the installation now meets the standard, and that confirmation must be supplied to the tenant and the local authority within 28 days of the work being completed.
A C3 (improvement recommended) code does not require work. A report with outstanding C1 or C2 items is not a satisfactory report, and an “unsatisfactory” EICR sitting in a file with no evidence of remediation is one of the quickest ways to collect a penalty.
Penalty: a local authority can impose a financial penalty of up to £30,000 for a breach of these regulations. Where a C1 hazard is present the council can also serve a remedial notice and, if it is not complied with, arrange the work itself and recover the cost.
EPC and MEES: the energy efficiency clock
An Energy Performance Certificate is valid for ten years and is required when a property is marketed and let. On top of that sits the Minimum Energy Efficiency Standard, under the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015.
Where the standard is today
- The current minimum is EPC band E. It applied to new tenancies and renewals from 1 April 2018 and to all existing tenancies from 1 April 2020. Letting a sub-band-E property without a valid registered exemption is unlawful.
- Improvements are subject to a cost cap of £3,500 including VAT per property. If the property still cannot reach band E after spending up to the cap, an “all improvements made” exemption can be registered.
- Exemptions — high cost, wall insulation that would damage the property, consent refused, devaluation, recently become a landlord — must be registered on the PRS Exemptions Register. An unregistered exemption is no exemption at all, and this is the most common MEES failure we see.
- Exemptions are time-limited and generally do not transfer on sale, so they need re-examining when ownership or circumstances change.
Where it is going
Government has proposed raising the minimum to EPC band C for all private rented homes by 1 October 2030. A higher cost cap and changes to how EPCs are calculated have both been consulted on; because the final figures and the final methodology are what matter for planning, check the current GOV.UK position rather than relying on a number from an article.
The planning point is simple, though, and it does not depend on the detail: if you own band D or band E stock, the works needed to reach band C are usually fabric works — insulation, glazing, heating — which are cheapest when they are scheduled alongside voids and refurbishments rather than done in a rush in 2029. Get an assessor to model the route to band C now, and sequence it.
Penalty: local authorities can impose penalties for MEES breaches, with a maximum of £5,000 per property and per breach, and can publish details of the breach on the exemptions register.
Band E also has a hidden second cost: a cold, hard-to-heat property is a prime candidate for an excess cold hazard and often a damp and mould hazard under the HHSRS, and those come with their own enforcement regime entirely separate from MEES.
Smoke and carbon monoxide alarms
The Smoke and Carbon Monoxide Alarm (England) Regulations 2015, as amended with effect from 1 October 2022, require landlords of relevant tenancies to:
- Provide at least one smoke alarm on every storey of the property used as living accommodation;
- Provide a carbon monoxide alarm in any room used as living accommodation that contains a fixed combustion appliance, excluding gas cookers;
- Ensure the alarms are in working order at the start of each new tenancy;
- Repair or replace an alarm once informed by the tenant that it is faulty.
“Used as living accommodation” is broader than it sounds — it includes bathrooms and lavatories, so a bathroom with a gas boiler needs a CO alarm. Day-to-day testing is the tenant’s job during the tenancy, but the duty to repair on being told is yours, which makes the record of when a tenant reported a fault important.
In HMOs and larger buildings the alarm regulations are a floor, not the whole duty. Fire risk assessment and the LACORS fire safety guidance commonly require interlinked, mains-wired detection covering the escape route and risk rooms, with the grade and category set by the risk — see our HMO inspection checklist.
Penalty: a council that believes a landlord is in breach serves a remedial notice. If it is not complied with, the council may arrange the works and can impose a penalty charge of up to £5,000.
Legionella: an assessment, not a certificate
There is a great deal of mis-selling in this area, so to be clear: there is no legal requirement for a landlord of ordinary residential premises to hold a Legionella certificate, and in most cases no requirement to carry out water sampling.
What does apply is the general duty to assess and control the risk from exposure to Legionella bacteria. For a typical house or flat with a combi boiler and no stored hot water, a simple assessment by a competent person — which can be the landlord or agent, if they understand what they are looking at — is usually sufficient, and the sensible controls are mundane:
- Remove dead legs and redundant pipework when you find them
- Keep hot water hot and cold water cold, and insulate accordingly
- Make sure cold water tanks, where they exist, are covered and in good condition
- Flush through showers and taps after a void, and tell incoming tenants to run outlets if the property has been empty
- Clean and descale shower heads and hoses periodically
- Review the assessment if the system is altered, the property is empty for a long period, or occupancy changes materially
Larger systems — stored hot water, communal systems, cooling towers, spa baths — are a different matter and warrant a proper written scheme by a specialist.
The other recurring duties worth diarising
- Fire risk assessment of the common parts where the building has shared areas, kept up to date and reviewed when things change.
- Fire-fighting equipment and fire alarm systems maintained, with test and service records — in HMOs this is an express duty under the management regulations.
- Landlord-supplied electrical appliances must be safe. Portable appliance testing is not a statutory requirement for domestic lets, but you need to be able to show the appliance was safe when supplied and has been maintained, and PAT records are the easiest way to do that.
- Soft furnishings supplied by the landlord must comply with the Furniture and Furnishings (Fire) (Safety) Regulations 1988 — check the permanent labels before anything goes into a property.
- Tenancy deposits protected in an approved scheme, with prescribed information served, within 30 days of receipt.
- How to Rent guide served in its current version, and right to rent checks completed before the tenancy begins in England.
- HMO licence renewal, and the licence conditions themselves — several of which carry their own recurring obligations.
- Oil and solid fuel appliances have no statutory annual check equivalent to the gas regime, but annual servicing by a competent engineer, and chimney sweeping, are what your insurer and the carbon monoxide hazard both expect.
Building a system that does not rely on memory
Four habits remove most of the risk:
- Diary from expiry, not from completion. Set reminders at 60 and 30 days before expiry for every certificate, per property.
- Record the disclosure, not just the document. The breach is often failing to send the report to the tenant, not failing to get it done. Keep the dated email or signed receipt alongside the certificate.
- Treat remedial work as part of the certificate. An unsatisfactory EICR is not closed until the remedial confirmation has been issued and circulated.
- Keep one file per property that a stranger could follow. The test is whether someone else in your business could produce the full pack for a council officer tomorrow, without you.
One further reason to tidy this up now: the Renters’ Rights Act 2025 received Royal Assent on 27 October 2025, the new tenancy system commenced on 1 May 2026, and a private rented sector database begins rolling out from late 2026. Compliance information becomes considerably more visible than it has ever been.
Never miss a renewal again
Hybrid Comply tracks every certificate against every property — gas, EICR, EPC, fire risk assessments and licences — with expiry alerts, the evidence attached, and portfolio-wide reporting that shows exactly what is in date and what is not. Book a demo and we will load a few of your properties in.
Book a demoPrimary sources
- HSE / GOV.UK — landlords’ duties under the Gas Safety Regulations
- GOV.UK — electrical safety standards in the private rented sector
- GOV.UK — domestic private rented property: minimum energy efficiency standard
- GOV.UK — smoke and carbon monoxide alarms: landlord booklet
- HSE — Legionella and landlords’ responsibilities