Summary

Most landlord gas safety checks are now recorded on a phone or tablet and sent as a PDF. That is lawful, but only if the digital record carries everything the regulations demand and is handled in a way HSE and Gas Safe Register will accept. The commonest problems a Gas Safe engineer runs into are not the check itself but the paperwork: a PDF with the engineer's name but no registration number, a tenant who never received a copy, an agent who cannot produce the record 18 months later, or a landlord who assumes the boiler service invoice counts as the gas safety record.

This article sets out what a digital record must contain, how HSE's guidance treats electronic signatures, storage and tenant copies, what the 2018 "MOT-style" flexibility means for record-keeping, and where the record fits into tenancy law in England, Wales and Scotland. It is written for the engineer issuing records, but the same points apply to a letting agent choosing software.

A common misconception is that Gas Safe Register "approves" apps or that there is an official digital CP12 form. There is no official form, paper or digital. "CP12" is just the old CORGI form number. Any layout is acceptable if it carries the regulation 36(3)(c) content. For the check itself and the engineer's revenue model, see gas safety certificate.

Key Facts

Quick Reference Table

Need to quote gas work? squote generates accurate, professional quotes fast.

Try squote free →
Requirement Paper record Digital record (PDF, app, portal)
Content per reg 36(3)(c) Mandatory Mandatory, same list
Engineer signature Wet signature Electronic signature or unique engineer ID accepted
Gas Safe registration number Mandatory Mandatory, must be visible on the document
Reproducible in hard copy n/a Must be printable on request
Secure from loss or alteration Locked filing Backed-up storage, access-controlled, not editable after issue
Copy to existing tenant Within 28 days Within 28 days, by email or portal if tenant can access it
Copy to new tenant Before occupation Before occupation, same rule
Retention 2 years (or until 2 further checks under reg 36A) Same
Short lets under 28 days Display prominently A printed copy must still be displayed
Official form None, "CP12" is historic None, any layout with the required content

Detailed Guidance

What a digital LGSR must show

Whatever app or template produces the record, check it against regulation 36(3)(c) line by line before you press send:

Item What to enter Common failure
Date of check The day the check was completed on site App defaults to issue date, not check date
Premises address Full address including flat number Postcode only, or agent's office address
Landlord name and address The landlord, or the agent acting for them "Care of" the tenant
Each appliance and flue Type, make, model, location (e.g. "Combi boiler, kitchen; open-flued gas fire, lounge") Boiler recorded, fire or hob omitted
Defects identified Specific wording, not "fail" Blank field where a defect was found and fixed
Remedial action What was done, or that the appliance was isolated with the customer's agreement No record of the warning notice issued
Reg 26(9) confirmation Flue, ventilation, pressure/heat input, safety devices, each ticked Section skipped on multi-appliance records
Engineer name and signature Name as on your Gas Safe ID card; electronic signature or app ID Initials only
Gas Safe registration number Business registration number (and your licence number where the form provides) Omitted because the app only shows the company logo

Most good software also prints a "next check due" date, the appliance's CO reading or combustion ratio, and whether a tightness test was done. None of that is required by regulation 36 but it protects you if a dispute arises.

Signatures, ID and the engineer's identity

The regulations require the record to carry the "name and signature" of the person who did the check. HSE's position in L56 is that an electronic record satisfies this if the engineer is uniquely identifiable: a drawn signature on a tablet, a typed name tied to a logged-in user account, or a payroll or licence number all work. The point is that the landlord, the tenant or an HSE inspector can trace the check to one registered individual.

Two practical rules follow:

Storage, security and reproducing the record

"Secure from loss and interference" means two things for an electronic record. First, it must survive a lost phone or a lapsed software subscription: keep records in cloud storage with a backup, and export a copy to the landlord at the time of issue rather than relying on your portal as the only copy. Second, once issued, the record must not be editable. If you need to correct a mistake, issue a replacement record clearly marked as superseding the first, and keep both.

The landlord's 2-year duty is theirs, not yours, but engineers are regularly asked for copies when an agent changes or a landlord sells. There is no legal duty on the engineer to keep records, but Gas Safe Register and most insurers expect you to keep a copy of every record you issue for at least 2 years, and 6 years is a sensible business default given the Limitation Act 1980 period for contract claims.

Issuing copies to tenants electronically

HSE accepts that a copy of the record may be provided to a tenant electronically, provided the tenant can access it and is happy to receive it that way. In practice:

The 2018 flexibility and what it does to your dates

Since 6 April 2018, regulation 36A allows the check to be done up to 2 months before the deadline without the renewal date moving earlier. A record dated 15 March with a deadline of 10 May keeps 10 May as next year's deadline. For this to work, the record must show both the date of the check and the date the previous check was due, so the landlord must retain the earlier records until two further checks have been done. Good software calculates this; if yours does not, write the "deadline date" on the record by hand.

If the landlord misses the deadline entirely, the flexibility is lost and the new 12-month period runs from the date of the late check.

Where the record sits in tenancy law

England. The Deregulation Act 2015 and the Assured Shorthold Tenancy Notices and Prescribed Requirements (England) Regulations 2015 (SI 2015/1646) made a valid gas safety record a precondition of a section 21 "no fault" notice. The Court of Appeal in Trecarrell House Ltd v Rouncefield [2020] EWCA Civ 760 held that late provision could be cured before the notice was served, provided the check itself had been done on time. Section 21 is abolished for new tenancies under the Renters' Rights Act 2025 from 1 May 2026 (see renters rights act 2025 landlord compliance), but the gas safety duty under regulation 36 is unchanged and remains enforceable by HSE and, through the Housing Act 2004 Housing Health and Safety Rating System, by local authorities.

Wales. Under the Renting Homes (Wales) Act 2016 and the Renting Homes (Fitness for Human Habitation) (Wales) Regulations 2022, a landlord must give the contract-holder a copy of a valid gas safety certificate before the occupation date or within 14 days of it, and after each subsequent check.

Scotland. Landlords must meet the Repairing Standard under the Housing (Scotland) Act 2006 and provide the tenant with a copy of the gas safety record. The same GSIUR regulation 36 duties apply.

HMOs and licensed property. Licensing conditions in England and Wales routinely require the latest gas safety record to be supplied to the council on request or annually. A digital copy is normally accepted. See hmo licensing.

Digital records and defects: what the PDF should say when something fails

Where you find an appliance Immediately Dangerous or At Risk under the Gas Industry Unsafe Situations Procedure, the record must say so in the defects field, state the action taken (appliance isolated, warning label attached, Riddor-reportable where applicable) and whether the customer agreed to the disconnection. Issuing a clean-looking PDF with a separate "warning notice" that the landlord never sees is the classic failure. Attach the warning notice to the digital record, or describe it on the record itself. See unsafe situations.

An appliance recorded as "Not to current standards" (NCS) is still a pass for the record, but write the reason, for example "flue terminal 280mm from opening window, NCS, advised" so the landlord has an audit trail.

Frequently Asked Questions

Does a boiler service record count as the gas safety record?

No. A service checks and cleans the appliance against the manufacturer's instructions; the gas safety record documents the regulation 26(9) safety checks on every landlord-owned appliance and flue. Many engineers do both on one visit and issue two documents. A service invoice or Benchmark page is not a gas safety record. See boiler servicing.

Can a landlord sign up to an online portal and never hold a copy themselves?

The landlord must be able to produce the record for 2 years. Relying on an engineer's or agent's portal is risky if that relationship ends. Advise landlords to download and store their own copy at the time of issue.

Is a photograph of a paper record a valid digital record?

Yes, provided it is legible, complete and the original paper record exists. A phone photo of a handwritten pad is still an accurate copy of a record that has all the reg 36(3)(c) items. The weakness is security and legibility, not legality.

Do I need to record CO readings or combustion ratios on the LGSR?

Not by regulation 36, but a flue gas analysis reading to BS 7967 on each appliance is the best evidence that the "safe operation" check was done. Most digital templates include fields for it. See flue gas analysis.

What if the tenant refuses access for the check?

The landlord must take "all reasonable steps". HSE expects a written record of at least three attempts, including a clear explanation to the tenant of why access is needed. Keep copies of letters, texts and emails. The engineer's no-access visit should be recorded on the job sheet with date and time.

Regulations & Standards