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
- Legal basis — Gas Safety (Installation and Use) Regulations 1998 (SI 1998/2451), regulation 36, as amended in 2018 (SI 2018/139). Applies in England, Scotland and Wales. Northern Ireland has parallel regulations (Gas Safety (Installation and Use) Regulations (Northern Ireland) 2004).
- Check frequency — each landlord-owned gas appliance and each flue serving one must be checked within 12 months of installation and at intervals of not more than 12 months (reg 36(3)(a)).
- Who can do it — only a Gas Safe registered engineer whose licence covers the appliance types involved (reg 3 and reg 36(4)).
- Record content (reg 36(3)(c)) — date of check; address of premises; landlord's (or agent's) name and address; description and location of every appliance and flue checked; defects found; remedial action taken; confirmation that the reg 26(9) checks were done; engineer's name, signature and Gas Safe registration number.
- Reg 26(9) checks — flue effectiveness, supply of combustion air, operating pressure and/or heat input, and safe operation of the appliance including its safety devices.
- Retention — the landlord must keep the record for 2 years from the date of the check (reg 36(5)). If the 2018 flexibility is used, keep it until two further checks have been carried out so the chain of dates can be shown.
- Tenant copies — to existing tenants within 28 days of the check (reg 36(6)(a)); to new tenants before they occupy (reg 36(6)(b)); displayed prominently where the let is under 28 days (reg 36(7)).
- Digital acceptance — HSE's ACOP L56 (5th edition, 2018) accepts electronic records if they can be reproduced on paper when required, are secure from loss or alteration, and identify the engineer uniquely (electronic signature, unique ID or similar).
- Electronic copies to tenants — acceptable where the tenant can access them. If a tenant asks for paper or cannot access a digital copy, supply a hard copy.
- No wet signature required — an electronic signature or a unique engineer identifier plus the Gas Safe registration number satisfies reg 36(3)(c).
- 2018 flexibility (reg 36A) — a check carried out in the 2 months before the deadline keeps the original anniversary date, so landlords do not lose days by checking early.
- Tenant's own appliances — not covered by the landlord's check (reg 36(3) applies to "relevant gas fittings" the landlord owns), but any landlord-owned flue serving a tenant's appliance is. HSE recommends tenant appliances are still visually inspected for obvious danger.
- Pipework — the annual check is of appliances and flues. A visual inspection of pipework and a tightness test are not strictly required by reg 36 but are strongly recommended in L56 and are standard practice. See tightness testing.
- Penalties — breaches are prosecuted under the Health and Safety at Work etc. Act 1974: unlimited fines and up to 6 months' imprisonment in the magistrates' court, more in the Crown Court.
- Data protection — a record naming the tenant is personal data under the UK GDPR and Data Protection Act 2018. Store it securely and do not share it beyond landlord, agent, tenant and regulators.
Quick Reference Table
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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:
- Sign your own records. Office staff must not "sign" a record on the engineer's behalf. If the app allows anyone with the company login to generate the PDF, use individual logins.
- Carry your Gas Safe ID card and let the tenant or landlord check it. Landlords are told by HSE and Gas Safe Register to verify the engineer at gassaferegister.co.uk before accepting a record. A digital record with a registration number that does not match a licensed business is worthless to them and a prosecution risk to you.
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:
- Ask at the check whether the tenant wants it emailed. Record the email address on the job sheet.
- If the tenant has no email, or asks for paper, leave or post a printed copy. The 28-day clock does not stop because the tenant did not open an email.
- For new tenancies, the landlord or agent must give the record before the tenant moves in. A portal upload the tenant cannot see until they have keys does not satisfy this.
- For lets under 28 days (holiday lets, serviced accommodation), a copy must be displayed in the property, which in practice means a printed copy in the welcome folder or on a notice board.
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
Gas Safety (Installation and Use) Regulations 1998 (SI 1998/2451), regulation 36 — landlord duties, annual check, record content, retention and tenant copies; regulation 26(9) — the checks the safety check must include; regulation 36A — the 2-month flexibility inserted by SI 2018/139 from 6 April 2018
HSE Approved Code of Practice L56 — Safety in the installation and use of gas systems and appliances, 5th edition 2018, including guidance on electronic records and tenant copies
Health and Safety at Work etc. Act 1974 — the enforcement and penalty framework for GSIUR breaches
Gas Safety (Installation and Use) Regulations (Northern Ireland) 2004 — the equivalent duties in Northern Ireland
Deregulation Act 2015 and Assured Shorthold Tenancy Notices and Prescribed Requirements (England) Regulations 2015 (SI 2015/1646) — gas safety record as a precondition of section 21 notices for tenancies before the Renters' Rights Act 2025 reforms
Renters' Rights Act 2025 — abolition of section 21 for new tenancies from 1 May 2026
Renting Homes (Wales) Act 2016 and Renting Homes (Fitness for Human Habitation) (Wales) Regulations 2022 — gas safety certificate duties to contract-holders in Wales
Housing (Scotland) Act 2006 — Repairing Standard gas safety duties in Scotland
Housing Act 2004 — HHSRS enforcement by local authorities; HMO licensing conditions
UK GDPR and Data Protection Act 2018 — handling of personal data in digital records
BS 7967 (series) — portable combustion gas analysers for CO and combustion performance measurement
Gas Industry Unsafe Situations Procedure (current edition) — classification and recording of unsafe appliances
Gas Safety (Installation and Use) Regulations 1998, regulation 36 — legislation.gov.uk
Gas Safety (Installation and Use) (Amendment) Regulations 2018 — legislation.gov.uk
HSE: Landlords' gas safety duties — Health and Safety Executive
HSE L56: Safety in the installation and use of gas systems and appliances — Approved Code of Practice
Gas Safe Register: Landlords — Gas Safe Register
Trecarrell House Ltd v Rouncefield [2020] EWCA Civ 760 — BAILII
gas safety certificate — what the CP12 covers, who can issue it and how the renewal pipeline works
gas safety checks — the on-site procedure for the regulation 26(9) checks
unsafe situations — classifying and recording ID, AR and NCS findings
landlord certificates — the full set of certificates a landlord needs alongside the gas record
renters rights act 2025 landlord compliance — the 2026 tenancy reforms and what they change for compliance paperwork
tightness testing — the tightness test most engineers add to the annual check