EICR vs PAT vs Gas Safety: The 3-Certificate Audit London Landlords Get Wrong (2026)
The three statutory certificates every London landlord conflates: EICR (5-yearly), Gas Safety/CP12 (annual), PAT (situational). What each covers, what each misses, and the audit gaps.
EICR (Electrical Installation Condition Report), Gas Safety Certificate (CP12) and PAT (Portable Appliance Testing) are three different statutory or industry-recommended checks that London landlords routinely confuse. EICR is required every five years under the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 and covers the fixed electrical installation. Gas Safety is required annually under the Gas Safety (Installation and Use) Regulations 1998 and covers every gas appliance and flue. PAT is not legally mandatory for most London tenancies but is good practice for any portable electrical appliance supplied by the landlord (lamps, kettles, fridges in furnished lets), and is mandated by some selective licensing schemes and HMO licence conditions. Confusing the three creates audit gaps that local councils and disrepair lawyers find immediately — typically because the landlord assumes one certificate covers ground that legally sits inside a different one.
Three certificates. Three regulators. Three completely different installations. And one consistent audit gap that London council compliance officers, disrepair-claim solicitors and selective licensing inspectors find at almost every prosecution they bring: the landlord thinks one certificate covers what another one is actually responsible for. The EICR doesn't cover the boiler. The Gas Safety doesn't cover the consumer unit. PAT covers neither. And in the 19 London boroughs running selective licensing schemes, the licence conditions impose a fourth and fifth layer that often catches landlords who genuinely believed they were fully compliant.
This guide is the deep audit walk-through we run with every new landlord client we onboard at Emergency Repairs London. It covers what each certificate legally covers, who can issue it, how long it lasts, what it costs in 2026 London, and — most usefully — the five places landlords routinely fall into a compliance gap that they did not know existed.
The Three Certificates At a Glance
Before the deep dive, the side-by-side summary that almost no commercial template captures correctly:
- EICR (Electrical Installation Condition Report): 5-yearly. Fixed wiring only. NICEIC or equivalent electrician. Required under the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 since 1 April 2021. Penalty for non-compliance: up to £30,000 civil penalty.
- Gas Safety Certificate (CP12): Annual. Every gas appliance, flue and the gas pipework. Gas Safe registered engineer only. Required under the Gas Safety (Installation and Use) Regulations 1998 since the same regime began in October 1998. Penalty for non-compliance: criminal offence, HSE prosecution, fines and possible imprisonment.
- PAT (Portable Appliance Testing): Frequency depends on appliance class and use. Portable appliances supplied by the landlord only — not the tenant's own kit. Any competent tester with the IEE Code of Practice training. Not directly statutory in most ASTs, but mandated in HMO licence conditions and in most London selective licensing schemes.
Notice the boundary lines: EICR stops at the socket outlet, PAT picks up at the appliance plug, Gas Safety lives entirely inside a separate regulatory universe. A fully compliant landlord needs all three running on independent schedules with independent contractors.
EICR — What It Actually Covers
An EICR is an inspection and test of the fixed electrical installation of the property. The inspector follows BS 7671:2018+A2:2022 (the 18th Edition Wiring Regulations) and checks:
- The consumer unit — modern RCBOs or older RCD-protected boards. Plastic consumer units installed pre-2016 in domestic premises are flagged as C3 (improvement recommended) because of the Grenfell-era amendment that requires metal enclosures.
- The cables in walls, floor voids and lofts — to the extent they can be reasonably inspected. A typical London Victorian terrace EICR will sample 20-30% of accessible cabling.
- The lighting circuits — including bathroom IP-rated fittings, switch positions, and any low-voltage transformers.
- The socket outlets — polarity, earth continuity, RCD trip times.
- Main and supplementary bonding — including the bonding to gas and water service pipes within the property, which is the only point at which the EICR formally touches the gas installation.
- External and outbuilding circuits — garden lighting, garage supply, EV charge points if installed.
The report assigns a classification code to every observed item: C1 (danger present, immediate action required), C2 (potentially dangerous, urgent remedial work), C3 (improvement recommended, not required for satisfactory), and FI (further investigation required). The 2020 Regulations require the landlord to remediate C1 and C2 items within 28 days of receiving the report, with written contractor confirmation that the work has been done. C3 and FI items do not block the certificate's satisfactory status but become valuable evidence in any later disrepair claim.
Re-inspection is five-yearly maximum — the report can set a shorter retest period (three years on a 1970s installation, two years on a deteriorated socket outlet group) and the next certificate is then due at that shorter interval. We always advise landlords to read the retest box on page two of the report and diarise it.
Gas Safety / CP12 — The Annual Non-Negotiable
The CP12 (Landlord's Gas Safety Record) is the strictest of the three certificates because it sits behind a criminal-offence regime. The Gas Safety (Installation and Use) Regulations 1998 — Regulation 36 specifically — requires the landlord to:
- Ensure every gas appliance, flue, and pipework in the property is checked for safety annually by a Gas Safe registered engineer.
- Receive a copy of the gas safety record within 28 days of the check, or before a new tenant moves in.
- Give the tenant a copy of the record within 28 days of the inspection, or before move-in for new tenants.
- Retain the record for at least two years (most managing agents now retain for seven years to match the Awaab's Law record-keeping period).
The check itself covers every gas appliance: boiler, hob, oven, gas fire, gas water heater — including the flue, ventilation provision, and the gas pipework feeding the appliance. The engineer tests gas tightness, flue performance (smoke test or analyser), ventilation adequacy, and combustion ratios. Any unsafe finding is classified using the Gas Industry Unsafe Situations Procedure: ID (Immediately Dangerous — appliance is disconnected on the spot), AR (At Risk — appliance can be left in service only with tenant written acknowledgement and a defect notice), or NCS (Not to Current Standards — record only).
Critically, the gas check does not cover the cooker if the cooker is the tenant's own and not provided by the landlord. The boundary line is provided-by-landlord versus tenant-owned. Furnished and part-furnished London lets where the landlord supplies the hob and oven absolutely include those in the CP12; unfurnished lets where the tenant brings their own do not.
PAT — When London Landlords Actually Need It
PAT — Portable Appliance Testing — is the most misunderstood of the three. The straight answer is that PAT is not directly mandated by the Landlord and Tenant Act 1985, the GSIUR 1998, the Electrical Safety Standards Regulations 2020, or the Renters' Rights Act 2025. The duty that creates the practical need for PAT is the Electrical Equipment (Safety) Regulations 2016, which requires that any electrical equipment supplied to a tenant by the landlord must be safe at the point of supply.
"Safe" can be demonstrated in several ways — visual inspection, manufacturer's certification, or PAT — but PAT is the only one that creates a documentary audit trail. That's why HMO licence conditions, most selective licensing schemes in London, and any landlord facing a serious disrepair or personal-injury claim end up needing PAT to demonstrate compliance with the 2016 Regulations.
The IEE Code of Practice (5th edition, 2024) sets the recommended frequency by class of appliance:
- Class I appliances (earthed metal-cased — fridges, kettles, toasters, vacuum cleaners): formal visual check every six months, combined inspection and PAT every twelve months in let property.
- Class II appliances (double-insulated — most modern lamps, hair dryers, small kitchen appliances): formal visual check every twelve months, combined inspection every two years.
- IT equipment (TVs, microwaves with electronic boards): visual check annually, PAT every two to four years.
For a typical furnished London flat with 10-15 portable appliances, a competent PAT contractor can complete the round in 90-120 minutes at a labour cost of £80-£150 depending on zone. Most NICEIC-registered electricians offer PAT as an add-on to the EICR — booking both together on the same visit saves the call-out fee on the second contractor.
The 5 Audit Gaps Landlords Get Wrong
The five gaps we see at every onboarding audit, in descending order of severity:
- Boiler in the EICR, not the CP12. The landlord shows an EICR with the boiler circuit marked satisfactory and assumes the boiler is signed off. It isn't — the EICR only covers the electrical supply to the boiler, not the boiler's combustion, flue or gas connection. A CP12 is needed in addition, separately, every twelve months. If the landlord has not booked a Gas Safe engineer for the boiler the CP12 is missing and the landlord is in criminal breach of GSIUR 1998.
- Plastic consumer unit ignored. Pre-2016 plastic consumer units are flagged C3 on the EICR — not strictly required to be replaced for the certificate to be valid, but a known fire-risk item under the Grenfell amendment. Selective licensing schemes in Tower Hamlets, Newham and parts of Hackney now treat plastic consumer units as enforceable defects under the licence conditions. The EICR satisfies the 2020 Regulations; the licence condition is breached anyway.
- PAT omitted in furnished lets. A furnished or part-furnished let with landlord-supplied kettle, lamps and fridge needs PAT (or equivalent safety demonstration) under the 2016 Regulations. Most landlords leave a kettle and a lamp from a previous tenancy in the flat without ever PAT-ing them. The discovery is usually after a tenant's hand-held appliance fails — at which point the landlord-supplied items become a personal injury claim.
- Certificate not given to the tenant. GSIUR requires the CP12 to be given to the tenant within 28 days of inspection, or before a new tenant moves in. The 2020 Electrical Regulations require the EICR to be given to the tenant within 28 days, and to any prospective tenant within 28 days of a written request. Compliance is the same on a managed property as a self-managed one — the managing agent typically holds the certificate but the duty is the landlord's.
- No retest diary. The five-year EICR cycle and the annual CP12 cycle drift. We see properties that had a CP12 in March one year, December the next, and August the year after — each one technically late by months. The 2020 Regulations require the EICR retest at the date stated on the report, not five years from the previous certificate. Without a calendar reminder these slip.
Selective Licensing Overlays in London
Nineteen of the 32 London boroughs run selective licensing or additional licensing schemes in 2026. The list, with brief notes on the licence conditions that overlay the three certificates:
- Newham — borough-wide selective since 2013, renewed 2018 and 2023, currently the longest-running scheme in England. Annual gas and electrical inspection conditions added in the 2023 renewal.
- Croydon, Waltham Forest, Brent, Tower Hamlets — borough-wide or near-borough-wide schemes with PAT requirements explicit in the licence conditions for furnished lets.
- Hackney, Haringey, Enfield, Barking and Dagenham, Redbridge — designated-area selective schemes; conditions vary by sub-area but EICR and CP12 are universal.
- Southwark, Lewisham, Greenwich — rolling additional licensing on HMOs and sub-area selective. PAT mandated in any HMO licence.
- Westminster, Camden, Islington, Lambeth, Kensington and Chelsea — additional licensing in sub-areas. London-wide HMO mandatory licensing applies on top wherever a property has five or more occupants from two or more households.
Breach of a licence condition is enforceable by the borough independently of the statutory regulations. A landlord can hold a valid EICR and a valid CP12, satisfy the 2020 Regulations and GSIUR, and still face a £30,000 civil penalty for breaching a borough-imposed licence condition that the statute itself does not cover.
Cost Matrix for All Three Certificates
The 2026 London market price ranges, for a typical two-to-three bedroom flat:
- EICR: £180-£280 for a standard inspection, rising to £300-£450 for older properties or where remedial work is found and quoted. Typical London turnaround is 24-48 hours from booking, with same-day available on emergency rates.
- Gas Safety / CP12: £80-£120 for a single-appliance property (boiler only), £120-£180 where there is a separate gas hob, £150-£240 where there is also a gas fire. Annual is the maximum interval and we recommend booking on the same calendar month each year to keep the diary tidy.
- PAT: £80-£150 for a typical furnished flat of 10-15 appliances. Per-appliance pricing on bulk PAT contracts runs at £3-£6 per item, useful for landlords with multi-flat portfolios.
Combined-visit pricing — booking the same contractor to run all three on a single visit — typically saves £40-£80 against three separate call-outs. A contractor with multi-discipline qualifications (Gas Safe + NICEIC + PAT-trained) is the cleanest option; otherwise a coordinated visit by two contractors (Gas Safe and NICEIC, with the electrician handling PAT under their general competence) is the second-best option.
Renters' Rights Act 2025 and What's Changing
The Renters' Rights Act 2025 received Royal Assent in October 2025 and began phased commencement in early 2026. Phase 1 took effect on 1 May 2026 with the abolition of Section 21 no-fault evictions and the conversion of all existing assured shorthold tenancies to assured periodic tenancies. Phase 2 and Phase 3 follow on commencement dates set by future MHCLG regulations.
The compliance-certificate implications:
- Possession on the new Schedule 2 grounds requires a valid CP12 and EICR — losing either blocks the landlord from pursuing rent-arrears or anti-social-behaviour possession.
- The Decent Homes Standard, currently social-sector only, will extend to the PRS under Phase 3. Plastic consumer units, sub-current EICR remedial works, and lapsed PAT will all become enforceable under the DHS.
- Awaab's Law extension to the PRS will impose hard timescales for hazard response — many of which are downstream of the same gas, electrical and appliance installations the three certificates cover. A live mould issue traced to a faulty bathroom extract fan, for example, becomes both a Section 11 disrepair item and an Awaab's Law trigger once Phase 3 commences.
- The new PRS Database (Phase 2, expected late 2026 to early 2027) will require landlords to register their property and upload compliance certificates. Missing or expired certificates will surface in the register and become visible to tenants, councils and prospective renters.
The direction of travel is firmly toward unified compliance enforcement. The three-certificate audit is becoming a four- and five-layer audit, and the boroughs are tooling up to enforce.
The Compliance Routine That Actually Works
The routine we hand to every London landlord we onboard at Emergency Repairs London:
- Set three independent calendar reminders — one for CP12 (annual, two weeks before due), one for EICR (matched to the retest date on the certificate itself, three months before due), one for PAT (annual on furnished lets, two-yearly on part-furnished, two weeks before due).
- Use a single contractor per discipline — Gas Safe engineer for CP12, NICEIC electrician for EICR and PAT — and keep their contact details in the property file. Continuity makes the annual visit faster and cheaper.
- Photograph every certificate and store digital copies in the property file plus a secondary cloud backup. The London disrepair-claim defence almost always turns on whether the certificate can be produced on demand.
- Send the certificate to the tenant in writing within the statutory window — 28 days for CP12 and EICR, and pre-move-in for any new tenancy. WhatsApp or email is sufficient under current case law but a Royal Mail signed-for delivery is safer for any contentious tenancy.
- Check the licence conditions for the borough at least once a year — the conditions change at renewal, and PAT requirements have been added in several borough renewals since 2023.
- Remediate every C1 and C2 EICR item within 28 days and keep the contractor's certificate of completion. C3 items go on a next-tenancy-end works list.
- Repeat the audit at every tenancy turnover — confirm all three certificates are within validity, refresh PAT if any new appliances have been added, and brief the new tenant on emergency contact details for gas leak (National Grid 0800 111 999), water leak (your contracted emergency plumber) and electrical emergency.
Three certificates. Three regulators. Three independent renewal cycles. Run them in parallel with a contractor who knows the London compliance landscape and the audit gap closes. Run them in series with a single annual phone call to whoever was cheap last year and the gap stays wide open — and the borough, the tenant's solicitor, and (under Phase 2 of the Renters' Rights Act 2025) the PRS Database, will find it.
Key Takeaways
- EICR covers the fixed wiring (consumer unit, sockets, lighting circuits, cables in walls) — 5-yearly minimum under the 2020 Regulations
- Gas Safety / CP12 covers every gas appliance and flue serving the property — annual under GSIUR 1998, criminal offence to skip
- PAT covers portable appliances supplied by the landlord (kettles, lamps, fridges in furnished lets) — not statutory in most ASTs but mandated in many London licensing schemes
- The most common audit gap: landlord assumes the EICR covers the boiler (it doesn't — gas appliance is GSIUR territory) or assumes Gas Safety covers the consumer unit (it doesn't — that's EICR)
- Selective licensing in 19 London boroughs adds further layered conditions — PAT becomes a hard requirement in Newham, Croydon and several Tower Hamlets sub-areas
- All three should be re-issued before a new tenant moves in, with copies given to the tenant either before move-in (gas) or within 28 days (electrical) — not at end of tenancy