Landlord gas safety record keeping: what to retain and give tenants

A landlord's gas safety record is the evidence of a completed safety check, not just a diary reminder. For premises within the Gas Safety (Installation and Use) Regulations 1998 in Great Britain, the landlord must arrange checks of relevant appliances and flues by a Gas Safe registered engineer, retain the check record for the legally required period and provide the latest record to tenants at the required time. The file should also preserve follow-up actions where a check reveals a defect. This guide explains the record workflow; it does not decide whether a particular appliance is safe.

The central retention point deserves care. Current regulation 36(3)(c) says keep the check record until two further checks have been carried out for the appliance or flue, or, where it is removed from the premises, for two years from its last check. HSE's landlord leaflet states that this may be longer than two years. Some HSE web summaries say “at least two years”; do not use that shorter phrase to delete a record before the statutory two-further-checks condition has been met. Keep delivery and defect-resolution evidence as appropriate to the case and the organisation's retention policy. Verify the current law again before publication because record rules and housing context can change.

What is the landlord gas safety record?

The record, often called a CP12 or landlord gas safety record, is completed following the relevant check by a Gas Safe registered engineer. It is different from a service invoice, booking confirmation, appliance manual or landlord's internal checklist. HSE lists minimum record particulars: the description and location of each appliance or flue checked; engineer's name, registration number and signature; check date; property address; landlord or agent name and address; safety defects and remedial action; and confirmation of the prescribed safety examination. Check the actual record on receipt. An upload with an unreadable page or missing appliance is not adequate evidence merely because a file is attached.

This guidance concerns landlord duties under the GB gas regulations. Property tenure, appliance ownership and whether a particular arrangement is a “relevant premises” matter. A solicitor or competent adviser should resolve unusual lease or accommodation questions. The landlord's general gas-safety duty should not be confused with separate rules for electrical safety, EPCs, smoke alarms or England-only rental procedures.

Build a property and appliance record

For each property, maintain a clear record of the dutyholder, agent, tenant contact, relevant appliance/flue inventory, last completed check and the next date requiring action. Attach the actual engineer-issued record rather than transcribing only a certificate number. Store enough information to distinguish an appliance replaced mid-cycle from one still in service. HSE says a single record usually covers multiple appliances and flues, but the checked items must be identifiable.

Keep the original record, any later correction and relevant follow-up linked. Do not silently overwrite a previous signed record with a revised scan. A clear version history allows a manager to explain the check date, engineer finding, action and what the tenant received.

When does a tenant receive it?

Regulation 36(6) requires a copy to be given to each existing tenant within 28 days of the check and to a new tenant before occupation. The regulations include specific display alternatives for short occupancies and certain shared situations; HSE explains these. Do not apply the display route to every tenancy. Keep a delivery record for the route used, especially when tenants change between checks.

HSE accepts electronic storage if a copy can be reproduced in hard copy, is secure from loss or interference and uniquely identifies the engineer. For electronic delivery, the tenant must be happy to receive and able to access it that way; give a paper copy if asked. A portal upload alone may not establish delivery to a tenant who cannot access the portal. Record the actual method and any paper request.

For a new tenancy, check that the record supplied is the current record for that property's relevant appliances and flues. A check booked for the week after move-in does not replace the requirement to supply the last applicable record before occupation. If the existing record identifies an unsafe appliance, deal with the engineer's safety advice and repairs; sending the document does not make the appliance usable.

Retention and the early-check window

Gas-safety checks are generally annual. The 2018 amendment explained by HSE allows a check in the two months before the existing deadline while retaining the original annual deadline, subject to the regulatory conditions. This is an option, not a reason to move a due date automatically for every early appointment. Preserve the actual check date, the old deadline and the basis for the next deadline. The record must make it possible to demonstrate that the check was carried out in the permitted window and that the sequence complied with the rule. HSE's record guidance specifically warns that landlords using the flexibility need the history until two further checks have occurred.

For example, suppose a check due on 30 November is done on 15 October, within the allowed early window. If the conditions for retaining the old deadline are met, the next annual deadline can remain 30 November of the next cycle. The property record should show both 15 October (actual check) and 30 November (retained due date), plus the earlier record from which that due date arose. If the check were carried out outside the permitted window, the conclusion could differ. Have the date calculation reviewed against regulation 36A, particularly for a newly installed appliance or a missed deadline. Do not treat this example as a universal scheduler formula.

A practical retention decision

Before disposing of an old record, ask:

1. Which appliance or flue does this record cover?
2. Has it remained in the premises, and are there two further completed checks for it?
3. If it was removed, has the statutory two-year period run from the last check?
4. Is it still needed to demonstrate a retained early-check deadline, tenant delivery or an unresolved safety case?
5. Does a justified organisational, insurance, legal-claim or litigation hold require longer retention?

This is a minimum legal-condition check, not a direction to keep every document forever. Apply an appropriate retention and access policy, especially where files contain personal data. Never erase the only evidence of a check just because the next appointment is on the calendar.

What to do when the engineer identifies a defect

HSE explains that a gas safety record may be issued with faults shown; landlords should supplement it with the remedial action taken. The check record should be issued when the check is complete, not withheld until a repair has happened. Create a separate active task for the unsafe condition, link the engineer's report, assign competent repair, keep the appliance out of use where instructed, and record the evidence of return to service. Do not mark the property “safe” merely because the annual document was uploaded.

Where an unsafe appliance affects heating or hot water, the landlord may need a separate housing-repair and resident-support response. Our unsafe-appliance landlord guide addresses that workflow. This page owns record keeping, not the engineer's technical diagnosis or the landlord's entire repair case.

Agent, portfolio and no-access workflows

If an agent arranges checks, the management agreement should clearly allocate who books them, receives records, serves tenants and follows up defects. HSE notes that duties may apply to the agent where the contract gives it responsibility. The landlord should still have a way to see the status and evidence, rather than assuming the agent's dashboard is complete. Capture the signed record, not just the agent's “done” status.

For multiple properties, review an exception list: checks approaching deadline, completed visits without engineer records, records missing an appliance, tenant delivery awaiting evidence, defects still open and removed appliances with retention dates. Assign each exception a named person and next action. Maintain the original completed-check date when a tenant refuses access; an attempted visit is not a new safety check. Our no-access guide covers the separate access and escalation task.

The Complys gas safety certificate tracking page is the relevant commercial destination for teams considering a document and reminder workflow. Before publication, verify the actual product implementation, tenant delivery capabilities, alerts, date logic and terms. Do not claim software automatically determines a lawful deadline or sends a record to tenants without proof of those functions. A system can organise evidence; it cannot perform the engineer's check or make an unsafe fitting safe.

Example: one portfolio record from check to follow-up

A letting agent books a registered engineer for a rental property's boiler and cooker. After the visit, a staff member receives the signed record and checks the property address, appliance/flue entries, engineer identifiers and outcome. The boiler has an identified defect, so the staff member logs a repair case and follows the engineer's safety instruction rather than closing the case when the PDF arrives. The record is supplied to the existing tenant within the required time and delivery is logged. The next check date is calculated from the actual legal timing rule, including any valid early-check retention of the old deadline. The old record remains stored until the applicable two-further-checks condition is met, and longer if needed for the defect or tenant-delivery trail. When the engineer confirms remedial work, the follow-up report is attached without altering the original record.

The useful distinction is between check completed, record received, tenant received copy, defect resolved and next check scheduled. These are five different states. A single green “compliant” badge can hide important work if it represents only one of them.

Frequent record-keeping mistakes

• Counting a booking, invoice or service note as the landlord gas safety check record.
• Keeping a record for exactly two calendar years and deleting it before two further checks have been completed for an in-service appliance.
• Assuming an early check always moves the next deadline to 12 months after the visit.
• Uploading a PDF without reading the engineer's unsafe or remedial findings.
• Sending an inaccessible portal link and assuming the tenant received the record.
• Failing to issue the current record before a new tenant occupies the premises.
• Losing the appliance inventory when a boiler or flue is replaced.
• Giving an agent the task without a clear contract allocation and evidence route.

Record keeping is part of an operating process, not a substitute for competent gas work. Check the current HSE and legislative text when designing a policy, keep original engineer records and make each exception actionable.

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