Section 21 is going. The workflow that replaces it.
The Landlord’s Gas Safety Record (officially the CP12) is the most fined and least understood piece of UK property compliance. Most landlords think of it as “the annual gas check”. The tribunal thinks of it as a chain of evidence.
This is what passes, what fails, and what you need to keep on file when someone asks.
The certificate itself
A CP12 is issued by a Gas Safe registered engineer after they have inspected every gas appliance, the flue, and the gas tightness of the installation. The certificate has to show:
- The address and name of the duty-holder.
- The engineer’s Gas Safe registration number.
- Each appliance, with its make, model and location.
- The check carried out and the result for each appliance.
- Any defects identified, and the action taken or recommended.
- The date of the next inspection (12 months from today, not 12 months from the last expiry).
An engineer who turns up, checks the boiler and leaves you with a one-line “passed” note has not given you a CP12. They have given you something a tribunal will throw out.
The failure codes that catch people
The two codes worth knowing:
ID — Immediately Dangerous. The appliance must be disconnected with the user’s permission. If the user refuses, the engineer is required to notify the Gas Emergency Service. ID does not just mean “the boiler is broken”; it usually means a CO risk, a flue gas spillage, or an unsafe gas escape.
AR — At Risk. One or more recognisable faults exist. The engineer should turn the appliance off with the user’s permission. If the user refuses, the engineer is still required to label the appliance and write to the user.
If a CP12 carries an AR or ID classification and the appliance was left in use without remediation, the certificate has not really been completed. A landlord relying on it as “up to date” is exposed.
The 28-day rule
Section 36(6) of the Gas Safety (Installation and Use) Regulations 1998 sets it out:
- A copy of the most recent record must be given to each existing tenant within 28 days of the inspection.
- A copy of the most recent record must be given to a new tenant before they move in.
- You must keep records for at least two years.
Most landlords miss the second one. The certificate sits in a folder; the new tenant signs the AST and moves in; nobody hands over the CP12 because nobody has it on the printed checklist. When that tenancy ends in dispute, the missing CP12 is the first thing the tenant’s solicitor reaches for.
The audit chain
If a local authority inspector asks for evidence of compliance, the tidy answer is not “here is the certificate”. It is:
- The certificate itself, in PDF, dated and engineer-signed.
- A timestamped record of when the tenant was given a copy.
- A timestamped record of any remediation work that followed an AR or ID code.
- The certificate from the previous year, to demonstrate continuity.
That chain, kept for the duration of the tenancy plus two years, is the difference between a clean inspection and a fine.
The practical bit
A spreadsheet of expiry dates is not a system. The mistakes we have seen most often, in order:
- Engineer finishes the check, forgets to email the certificate, landlord assumes everything is fine.
- Landlord receives the certificate, files it in their email, never sends it to the tenant.
- Tenancy renewed under a new fixed term, the 28-day clock restarts but nobody re-sends the CP12.
- An ID-classified appliance gets remediated, but the remediation paperwork is not attached to the certificate.
The fix is administrative discipline. The discipline is easier when the system enforces it: the certificate goes into the property record, the system auto-notifies the tenant, the renewal is calendared 90 days before expiry, and the engineer’s portal lets them upload the new cert directly.
Our property platform handles the whole CP12 chain — engineer upload, tenant notification, expiry escalation, and a clean audit log when someone asks. If you would like to see it on your own portfolio, tell us.